Respiratory protection in the workplace
Every fall, OSHA releases its annual top-ten violations list.
In 2021, respiratory protection – standard 1910.134 – rose up the list, finishing at no. 2. Only fall protection violations were more commonly cited.
Respiratory protection regulations are some of the easiest with which to comply, yet many employers continue violating the policies.
Last year, there were a total of 2,527 respiratory protection violations.
The most common among them? Standard 29 CFR 1910.134(e)(1) – written medical evaluations.
With over 600 citations issued under this standard, it requires that “the employer shall provide a written medical evaluation to determine the employee’s ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace.”
But, there were plenty more violations employers racked up last year.
The Need for Protection
According to NIOSH, approximately 5 million workers spread across U.S. workplaces fall within the respirator compliance standard.
(Related Article: 5 OSHA Health Fines You Can Prevent In 2022)
Most companies mandate respirator usage on job sites that contain hazardous materials.
In fact, OSHA requires in standard 1910.34(a)(2) that “a respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee.”
Too many supervisors stop reading after that sentence – a critical and potentially deadly mistake. There’s more to it than that.
Here, we break down the top five most-cited sections in the respiratory protection from 2021:
5) General Requirements of Respiratory Protection
Section 1910.134(d)(1) of the OSHA Respiratory Standard states that:
“The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.”
It was also responsible for 117 respiratory protection violations.
In order to comply, you need to choose the correct NIOSH-certified respirators, and use them in compliance with the conditions of their certification.
You’ll need to assess the respiratory hazards your workers face, and determine their contamination level. For this, you can use either objective data or mathematical approaches – in order to select the proper NIOSH-certified respirator.
There are two main types of respirator: Air-purifying and atmosphere-supplying. Additionally, variations exist for each: Tight-fitting or loose-fitting.
It’s crucial for employers to choose the right ones. That starts with knowing the OSHA Permissible Exposure Limits (PELs) for each substance in a given workplace, if available.
There are 500 established PELs and, while most are based on 8-hour time-weighted averages, many include other factors, such as ceiling and peak limits.
Inaccurate job site evaluations may lead to selecting incorrect respirators.
That mistake potentially exposes employees to chemical hazards and toxic substances.
4) Training and Education
Responsible for 130 violations in 2021, section 1910.134(k) of OSHA’s respiratory standard is all about training and educating your team.
3) Respiratory Protection Program Violations
This section requires “The employer to develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use.”
A written program outlines all of the hazards employees might face, and the requirements they’re expected to follow. As such, a trained supervisor must implement these policies.
A compliant plan includes worksite specific procedures, such as selecting the proper respirator; medical evaluations; fit testing; cleaning and storing; and training the employees in potential hazards and proper respirator use.
Keep your company in compliance by updating respiratory protection information consistently. Outdated programs lead to workplace hazards and, as depicted by last year’s statistics, OSHA citations.
(Related: Respirator Fit Testing)
2) Fit Testing
Clocking 519 violations, section 1910.134(f), which covers fit testing, was the second most common OSHA respiratory standard violated in 2021.
Fit testing isn’t just a one-time thing. It’s required annually.
Employees using a tight-fitting facepiece respirator must pass an appropriate qualitative fit test or quantitative fit test.*
Of course, they’ll need a fit test when first starting to wear their respirator, but there are several other circumstances that require it as well.
Respirators must conform to one’s face shape in order to work properly. Even something as simple as a change in weight can create inadequacies for a tight-fitting respirator.
Additionally, if the employee or his/her supervisor notices any physical changes affecting the fit of the respirator – an increase in facial hair, facial scarring, and/or, as mentioned above, an obvious change in body weight – a new fit test must be performed.
Fit testing is one of the easier violations you can avoid, and yet too many businesses fail to conduct them properly.
*Masks used voluntarily in non-hazardous areas are not required to be fit-tested.
1) Medical Evaluation
With 618 instances in 2021, neglecting this crucial step was the most common OSHA respiratory violation of 2021.
Most employers know that employees need to wear respirators when hazardous chemicals, dusts, and pollutants fill the air in their workplaces.
Many also know which respirators to use, and to schedule fit tests annually. Unfortunately, one section of the respiratory protection regulation is overlooked all too often.
Section 1910.134(e)(1) states that,
“The medical evaluation must be provided before the employee is fit tested and uses the respirator in your workplace for the first time.”
OSHA mandates medical evaluations prior to respirator usage, as referenced several times in the respiratory standard. Yet, the most violations come from this section.
Wearing a respirator makes breathing difficult, especially for older and/or asthmatic employees. Respirators may also impair vision and/or trigger claustrophobia.
Don’t hold off on medical clearances until your employee passes out or suffers from a panic attack.
It’s not just the right thing to do, it’s required.
When it comes to workplace safety, it’s critical that you remain proactive, not reactive. The well-being of your organization depends on it.
Stay in Compliance with Worksite Medical
In most cases, OSHA requires medical surveillance testing, and at no cost to employees.
Worksite Medical makes that program easier with mobile medical testing.
We conduct on-site respirator fit tests, as well as audiometric exams, pulmonary function tests and heavy metal lab work, right on your job site. We also keep accurate, easy-to-access medical records for your convenience. You’ll keep your employees at work, and stay ahead of OSHA inspections.
With Worksite Medical, a mobile medical testing unit — we can bring all the resources of a lab to you. Our certified lab technicians can perform both qualitative and quantitative respirator tests to ensure a perfect fit.
Protect your team and your workplace now with Worksite Medical. Not sure what you need? Try our medical testing wizard here.
Give us a call at 1-844-622-8633, or complete the form below to schedule an on-site visit or to get your free quote.