Date: May 13, 2008
Series: Occupational Safety and Health
Part 242: Industrial Hygiene
Originating Office: Division of Safety and Health
14.1 What is the purpose of this chapter? This chapter describes the U.S. Fish and Wildlife Service (Service) requirements for protecting you from respiratory hazards you may encounter while performing your job tasks.
14.2 What is the Service policy for minimizing exposure to respiratory hazards?
A. We take steps to avoid exposing you to respiratory hazards in your work areas. Respiratory hazards (such as airborne contaminants or even insufficient oxygen) can irritate or damage your respiratory system, causing damage to your health, and may cause death.
B. Our primary goal is to prevent harmful levels of airborne contaminants in all Service work areas. Airborne contaminants may be gases, vapors, particulates, or fibers.
C. Our first choice is to use reasonable engineering controls, including product substitution, to eliminate hazardous airborne contaminants in your work area before you begin work there. Product substitution is when a material is replaced with a less hazardous product. We also consider the use of appropriate administrative controls to reduce harmful exposures.
D. If we determine that your work may expose you to respiratory hazards and you meet the requirements in this policy, we will give you an appropriate respiratory device. You may not work in the area without respiratory protection.
14.3 What is the scope of this chapter? This chapter applies to the people who work for the Service in areas where respirators are worn or in an environment where they may be exposed to respiratory hazards. The policy applies to:
A. Service employees (full-time, part-time, and seasonal),
C. Youth Conservation Corps members, and
D. Student interns.
14.4 What are the authorities for this chapter?
A. Occupational Safety and Health Act (OSHA) Federal Agency Safety Programs and Responsibilities (Public Law 91-596, Sec 19).
B. Occupational Safety and Health Standards, Respiratory Protection (29 CFR 1910.134).
C. Approval of Respiratory Protective Devices (42 CFR Part 84).
D. Basic Program Elements for Federal Employee Occupational Safety and Health Programs and Related Matters (29 CFR 1960).
E. Executive Order 12196, Occupational Safety and Health Programs for Federal Employees.
F. American National Standards Institute (ANSI) Standards for Respiratory Protection (ANSI Z88.2-1992).
G. 485 DM 17, Industrial Hygiene Program and the Occupational Medicine Program Handbook.
14.5 Who is responsible for the respiratory protection program?
A. The Director:
(1) Ensures that the Service maintains an effective and comprehensive occupational safety and health program, and
(2) Approves our respiratory protection policy.
B. The Assistant Director, Business Management and Operations ensures that:
(1) The Service has a respiratory protection policy, and
(2) The Headquarters Office has sufficient support and resources to implement the policy.
C. Regional Directors must provide sufficient support and resources to effectively implement the respiratory protection program in their areas of responsibility.
D. The Chief, Division of Safety and Health:
(1) Recommends revisions to this policy, as necessary.
(2) Interprets the respiratory protection program requirements and serves as a consultant to resolve Servicewide questions and issues.
E. The Regional Safety Managers:
(1) Interpret the respiratory protection program requirements and serve as advisors to resolve questions and issues in their areas of responsibility.
(2) Evaluate the respiratory protection program during Regional Field Station safety program evaluations.
(3) Help Project Leaders and supervisors ensure they select and provide appropriate respiratory protection for their employees.
(4) Evaluate and approve, in writing, requests from Project Leaders and supervisors to use supplied-air respirators or Self-Contained Breathing Apparatus in their work areas.
F. Project Leaders and supervisors:
(1) Minimize the need for respiratory protection by using engineering and administrative controls.
(2) Implement all aspects of a respiratory protection program for their employees.
(3) Ensure there is a written, site-specific respiratory protection plan for each work area where employees are required to wear respirators.
(4) Assign a Respiratory Protection Program Administrator to conduct and coordinate the respiratory protection plan at each facility requiring it, and ensure that the Administrator is sufficiently trained to accomplish that assignment.
(5) Make sure each employee who needs a respirator has been medically evaluated and properly trained. They must be fitted for the device at least once a year (see sections 14.9 through 14.11).
(6) Know the job tasks in their work areas that require respirators, and make sure all the employees doing those tasks use the appropriate respirators and accessories (i.e., cartridges) at all times.
(7) Make sure that appropriate respirators and accessories are available.
(8) Provide a clean storage area for respirators and their accessories.
(9) Establish industrial hygiene contracts for air monitoring in coordination with the Regional Safety Office and with the Service Industrial Hygienist, if necessary.
G. Respiratory Protection Program Administrators.
(1) How they are appointed: The Project Leader or supervisor selects the Administrator based on the Administrator’s training and knowledge of respiratory protection program requirements.
(a) The Administrator may or may not be the station’s collateral duty safety officer (CDSO).
(b) If the Administrator does not serve as the station’s CDSO, he/she must coordinate respiratory hazard evaluations and subsequent respiratory protection program element implementation with the location’s CDSO. In certain instances, it may be appropriate for a program (e.g., Office of Law Enforcement Wildlife Inspection Program) to supplement field station administrators with support from an off-site program administrator or an administrator serving multiple locations.
(c) If a location has an employee using a respirator, that individual must be covered by a respiratory protection program with a designated Administrator.
(a) Develop and update (as necessary) respiratory protection plans for all operations in work areas that require Service employees to use respirators (see section 14.3). You may obtain copies of program templates from your Regional safety managers.
(b) Select the appropriate respirators and filtering cartridges.
(c) Coordinate medical evaluations and respirator fit testing.
(d) Keep required written records for the respiratory protection program (see section 14.19).
(e) Provide annual training on the correct selection, limitations, use, and maintenance of respirators.
(f) Develop a change-out schedule for respirator cartridges.
(g) Coordinate air monitoring, exposure assessments, and any technical issues with the Regional Safety Office. Coordinate with the Service Industrial Hygienist, if necessary.
(h) Evaluate the effectiveness of the respiratory protection plan(s) at least annually, and prepare a written report on the evaluation.
H. Employees must:
(1) Complete all respiratory protection program training and comply with the requirements in this chapter.
(2) If we issue you a respirator:
(a) Wear, clean, maintain, and dispose of it as required;
(b) Protect it from damage;
(c) Store it properly in a clean location designated by your Project Leader or supervisor;
(d) Inspect it before use;
(e) Conduct a seal-check prior to use; and
(f) Report any problems with your respirator to your supervisor or Respiratory Protection Program Administrator immediately. Do not use the respirator until the problem has been resolved.
14.6 What job tasks may require use of a respirator? Following are examples of work that may require you to use a respirator:
A. Performing work that generates large amounts of dust.
B. Applying pesticides, herbicides, and rodenticides.
C. Cleaning areas where there is animal or rodent waste that could expose you to Hantavirus or other viral infection.
D. Conducting Avian Influenza surveillance activities (see the Service National Avian Influenza Response Plan).
E. Cutting, melting lead, or incidental disturbance of lead-based paint.
F. Painting, especially with epoxy or organic solvent coatings.
G. Using solvents, thinners, or degreasers.
H. Using formaldehyde (formalin) or isopropyl alcohol (in large quantities or poorly ventilated spaces).
I. Welding or burning.
J. Inspecting buildings that may be contaminated with asbestos. Service personnel may not remove asbestos-contaminated material.
K. Conducting natural and man-made disaster response and recovery operations.
L. Characterizing hazardous material sites following the policy in 242 FW 6, Hazardous Materials Operations.
M. Conducting inspection activities such as wildlife product inspections (see 241 FW 9).
14.7 How does a Project Leader or supervisor determine if a respirator is necessary?
A. Assessment. Your Project Leader or supervisor must assess each potentially hazardous job in your work area to determine if there may be a need for a respirator. The Service may have conducted a program-specific assessment based on known work activities to identify hazards and establish general respirator protection guidance. These assessments often identify responsibilities that the Project Leader or supervisor must fulfill. For example, Wildlife Inspectors and Special Agents have to use respirators in some circumstances when inspecting shipments or handling wildlife (see 241 FW 9).
B. Evaluation. If the Project Leader/supervisor finds a potential respiratory hazard and cannot eliminate it using engineering or administrative controls, including product substitution (i.e., replacement of a product or equipment that is less hazardous), he/she must evaluate the hazard. The evaluation tells your Project Leader/supervisor and your duty station’s Respiratory Protection Program Administrator what airborne contaminants are present and if the levels exceed safe exposure limits established by OSHA and the American Conference of Industrial Hygienists (ACGIH). Conformance with OSHA levels is required and ACGIH levels are preferred/recommended. The Respiratory Protection Program Administrator must develop a respiratory protection plan based on this information (see section 14.5G(2)). This evaluation may include:
(1) Reviewing Material Safety Data Sheets,
(2) Air monitoring, and
(3) Consulting with an Industrial Hygienist or the Regional Safety Office for further guidance.
14.8 What are the Service’s requirements for issuing respirators?
A. Before selecting, purchasing, and requiring employee use of respirators, Project Leaders and their Respiratory Protection Program Administrator must discuss their needs with the Regional Safety Office, respirator manufacturer(s), or other safety equipment suppliers to ensure that they are buying an appropriate respirator.
B. Before issuing respirators or requiring an employee who uses a respirator to do a new task that requires a respirator, Project Leaders and supervisors must consult their Respiratory Protection Program Administrator. The Program Administrator may consult with their Regional Safety Office to determine if previously provided selection and use criteria apply to the new task, or if it is a new assessment and a selection/use process is needed.
C. Project Leaders and supervisors will not issue respirators until you:
(1) Fill out FWS Form 3-2363, Request for Respirator Clearance,
(2) Pass a medical evaluation documenting that you are medically qualified for respirator use (see section 14.9),
(3) Take required respirator training (see section 14.10), and
(4) Successfully pass respirator fit testing for the style of respirator you will wear (see section 14.11).
A. Pre-placement or baseline clearance examination. Before we give you a respirator and assign you to work in an area requiring respiratory protection, we arrange and pay for a medical physician or other licensed health care professional (medical professional) to evaluate whether you can do your job safely while wearing a respirator without injuring your health.
(1) You give a copy of OSHA’s Appendix C, Medical Questionnaire, to the medical professional when you have your evaluation, and
(2) The medical professional documents the evaluation and gives a clearance record, FWS Form 3-2364, stating the employee’s ability to wear or not wear a respirator to the employee’s supervisor. The exam may be for respiratory clearance requirements or conducted as part of a more comprehensive examination for other duties (e.g., law enforcement, underwater diving, firefighting, environmental contaminants, etc.) The evaluation is a baseline for future evaluations.
(3) We will provide a follow-up medical evaluation if any of the questions in 1 through 8 in section 2 of OSHA’s Part A of Appendix C are positive, or if the medical professional finds the person unable to wear a respirator because of a medical condition.
B. Additional medical evaluations. We arrange and pay for additional medical evaluations when (see 29 CFR 1910.134(e)):
(1) You report any signs or symptoms that are related to your ability to use a respirator;
(2) A medical professional, Project Leader, supervisor, or Respiratory Protection Program Administrator tells us that you need to be reevaluated;
(3) Information from the respiratory protection program (i.e., the program evaluation, observations during fit testing, etc.) shows that you need a reevaluation; or
(4) A change occurs in workplace conditions (e.g., physical work effort, addition of protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on you.
C. Termination of employment physical evaluation.
(1) We arrange and pay for a medical professional to give you a medical evaluation when you separate from the Service. Evaluation must occur prior to your separation date.
(2) We may use the termination evaluation to evaluate any post-employment medical problems you claim are a result of an exposure to a respiratory hazard within your occupational setting.
A. You will learn:
(1) The nature and degree of respiratory hazard(s) you will be exposed to in your work area.
(2) The proper selection and use of your respirator, as well as its limitations.
(3) How to properly wear the respirator, how to fit test it, how to conduct a user seal (face-to-seal) check, and how to determine when it is no longer giving you the required protection. You practice putting it on, conducting a user seal check, and taking it off.
(4) How to clean, maintain, store, and replace your respirator.
B. Your Project Leader/supervisor must ensure there is a written record of your training. See FWS Form 3-2292 for a certificate of respirator training. The training certificate must include the following information for each respirator user:
(1) The type and model of respirator trained and fit tested for,
(2) The date of the training and the name of the trainer, and
(3) The signature of the respirator user certifying he/she received the training.
A. While you wear a respirator, a fit test ensures that you:
(1) Are comfortable,
(2) Have a satisfactory face-to-mask seal,
(3) Are able to breathe normally,
(4) Can move your head and retain the proper fit, and
(5) Can talk so that someone understands you. (For a list of all the fit test criteria, see OSHA requirements at 29 CFR 1910.134, Appendix A, Fit Testing.)
B. You must:
(1) Pass either a qualitative or quantitative fit test before you are provided a respirator or are exposed to a respiratory hazard,
(2) Receive proper fit testing at least once a year while your job requires you to wear a respirator, and
(3) Perform a positive/negative pressure user seal check before each respirator use.
C. You must not perform fit tests and user seal checks if there is any hair growth between the skin and the face piece sealing surface, such as stubble beard growth, beard, mustache, or sideburns that cross the respirator sealing surface.
D. Your Project Leader/supervisor must ensure there is a written record of your fit testing. The fit testing record must include (see FWS Form 3-2365 for a sample fit test record):
(1) The type of respirator,
(2) Brand name and model,
(3) Method of test and test results,
(4) Test date, and
(5) The name of the tester.
14.12 What are the different types of respirators? There are three types of respirators: air-purifying, supplied-air, and self-contained breathing apparatuses. Your Project Leader/supervisor must get written approval from their Regional program offices, in concurrence with the Regional safety office, on any field station requests to use a supplied air respirator or a self-contained breathing apparatus.
A. Air-purifying Respirator. When exposed to atmospheres requiring air-purifying respirators, those respirators and components must be approved by the National Institute for Occupational Safety and Health (NIOSH). This type of respirator removes contaminants from the air you breathe through negative pressure or by purifying powered air with specialized filters and cartridges. They do not supply air. You can only use them when the oxygen level in the air is greater than 19.5% and less than 23.5%. You must not use an air-purifying respirator in atmospheres that are considered to be immediately dangerous to life or health, which are conditions that pose a threat to your life or may cause irreversible adverse health affects now or in the future. Air purifying respirators are available as disposable, cartridge, canister, powered air, and emergency escape types. The air-purifying respirator has specialized filters and cartridges:
(1) Filters protect against particulates by trapping the contaminant within the fibers of the filter.
(2) Cartridges or canisters protect against respiratory hazards caused by specific gases and vapors. Cartridges are available for protection against such substances as ammonia gas, mercury vapor, acid gases, and organic vapors. Cartridges are designed only to protect against specific contaminants and will not protect you against anything else. To maintain maximum protection while in use:
(a) The respirator should be equipped with a cartridge end-of-service-life indicator.
(b) If there is no end-of-service life indicator, then your field station’s Respiratory Protection Program Administrator must develop a cartridge change-out schedule that is based on environmental conditions, work exertion level, contaminant exposure levels, etc. See OSHA’s Respirator eTool for guidance.
(3) Disposable air-purifying respirators are the most commonly used type of respirators at Service facilities. The disposable respirator provides low-cost protection against dusts, fumes, and mists containing no gases, vapors, or non-absorbed contaminants and requires no cleaning or spare parts. We often use disposable respirators for short term, minimal potential exposure work activities. Such respirators typically come in half-face or full-face designs.
(4) Emergency escape respirators are rarely needed or provided in our work, but may be encountered as adjunctive personal protective equipment in certain settings, such as in water treatment or sewer pump stations.
B. Supplied-air respirator. This type of respirator provides breathing air independent of the environment. We use these respirators when the contaminant has insufficient odor, taste, or irritating warning properties, or when the contaminant is of such high concentration or toxicity that an air-purifying respirator is inadequate. Supplied-air respirators are also called air-line respirators.
C. Self-Contained Breathing Apparatus (SCBA). This type of respirator gives you complete independence from a fixed source of air and offers the best protection, under certain circumstances. It is also the most complex respirator to use. You need extensive training and practice to use and maintain this apparatus.
14.13 How does the Service select respirators? The Respirator Selection and Use Chart (Exhibit 1) is a list of what types of respirators we recommend for specific job tasks. Whether a respirator is issued or not is a function of the actual contaminant or chemical being used and its concentration levels, how it is being used, the environment in which it is used (outdoors versus a confined space), engineering controls, and the length of employee exposure. If your Project Leader/supervisor determines that you need a respirator in your work area, he/she and the Respiratory Protection Program Administrator must:
A. Select only respirators and components that NIOSH has approved.
B. Select filters and cartridges based on the nature of the respiratory hazard.
C. Consider the following items before selecting the best respirator for the hazards involved and the work you will be doing:
(1) Effectiveness of the device against the specific airborne contaminant,
(2) Estimated maximum concentration of the substance in your work area,
(3) General environment (open area or confined space, etc.),
(4) Known limitations of the respirator,
(5) Your comfort and the fit of the device, and
(6) Other contaminants in the environment or potential for oxygen deficiency. An oxygen deficient atmosphere is an atmosphere containing less than 19.5% oxygen.
D. Contact the Regional Safety Office before exposing you to a situation that is immediately dangerous to life or health or to an oxygen deficient atmosphere. Approach situations involving non-routine activities, highly toxic chemicals, or confined spaces with caution (also see 242 FW 11, Confined Spaces).
14.14 May an employee wear a respirator even if OSHA, the Service, or an Industrial Hygiene survey does not require it?
A. Yes. We may provide a respirator for you to use voluntarily to give you an extra level of comfort or protection.
B. We may also allow you to provide your own respirator, if we are sure that the respirator itself does not present a hazard to you or the job you are doing, is in good working condition, and meets the same NIOSH approval requirements.
C. Your Project Leader/supervisor must ensure that you meet all Service and OSHA requirements before allowing you to voluntarily use a respirator in your work area. (See OSHA’s requirements in “Information for Employees Using Respirators When Not Required under the Standard,” at 29 CFR 1910.134, Appendix D, Voluntary Use.)
D. If you wear a tight fitting respirator (i.e., ½ face or full face air purifying) on a voluntary basis, your Project Leader/supervisor must ensure that you are medically able to use that respirator and that the respirator is cleaned, stored, and maintained properly.
E. To wear a dust mask (i.e., filtering face piece), you only need to read OSHA’s Appendix D, Voluntary Use. Such masks do not meet the design or performance parameters of a respirator and may only be used to reduce potential exposure to non-harmful particulates within the atmosphere. Your Project Leader/supervisor does not need to determine if you are medically able to wear the dust mask. Devices that NIOSH has assigned a protection factor (for example a disposable N-95 unit) are not dust masks, and must be treated as respirators.
14.15 May employees use surgical masks to protect themselves from airborne contaminants? No. Surgical masks are for medical use only. They do not provide protection against airborne contaminants, and you may not use them in place of an air-purifying respirator. This prohibition does not apply to NIOSH-approved respirators that have a similar design to surgical masks, such as “fan fold” disposable particulate respirators.
14.16 What are the requirements for maintaining, cleaning, inspecting, and storing Service respirators? You are responsible for cleaning and maintaining your respirator, unless your Project Leader/supervisor specifically assigns that responsibility to someone else. The Respiratory Protection Program Administrator makes sure that general use respirators are properly cleaned, maintained, inspected, and stored. Disposable particulate respirators must be discarded as required by your respiratory protection program plan.
A. Maintaining Respirators. Your Project Leader/supervisor and Respiratory Protection Program Administrator must:
(1) Train you in the proper maintenance procedures for your specific respirator,
(2) Ensure that the replacement parts you need to keep your respirator in perfect working condition are available, and
(3) Ensure that disposable respirators are not used past their intended use period.
B. Cleaning Respirators.
(1) Your Project Leader/supervisor and Respiratory Protection Program Administrator must:
(a) Only issue clean, sanitary respirators,
(b) Train you on the proper cleaning procedures for your specific respirator or disposal criteria for disposable respirators, and
(c) Ensure that you or the person responsible for cleaning respirators at your work area cleans and disinfects the respirator after every use.
(2) You are responsible for making sure that your respirator is clean.
C. Inspecting Respirators.
(1) You must inspect your respirator:
(a) Prior to each use and during cleaning,
(b) At least once a month for respirators used for emergency purposes, and
(c) After each use for respirators having a prolonged intermittent use period.
(2) When inspecting your respirator, you look for:
(a) Respirator function and tightness of connections.
(c) Pliability and signs of deterioration of elastomeric parts.
(3) The Respiratory Protection Program Administrator must ensure that all respirators are inspected as we require. Refer to your respiratory protection plan for the specific inspection requirements at your work area.
D. Storing Respirators.
(1) You must store your respirator in a clean place where it is protected from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals. To achieve this standard, you:
(a) May store your respirator in commercially available respirator storage bags or in “Zip-Loc” type bags only after a respirator is clean, disinfected, and thoroughly dried. It must be stored so that the face piece and exhalation valve are not deformed,
(b) Must refer to your respiratory protection plan for the storage location and specific requirements in your work area.
(2) You must store:
(a) New, unused cartridges in the sealed bags they come in to protect them from outside contaminants; and
(b) Cartridges that you are using in “Zip Loc” type bags to protect them from being spent from exposure to outside contaminants in the ambient air. You may leave installed cartridges, which are still serviceable, on the respirator and store the entire unit in a large sealed bag (see section 14.16D(1)).
14.17 What should employees do if a respirator fails inspection or is not working or fitting properly?
A. Do not use a broken, ill-fitting, or defective respirator.
B. Contact your Respiratory Protection Program Administrator immediately for assistance. The Administrator must discard, repair, or adjust the respirator to achieve satisfactory performance. A like type, model, or size of respirator may be provided as a replacement. In some cases a different type, model, or size may be required to satisfy fit testing requirements.
14.18 How does the Service help ensure that a duty station’s Respiratory Protection Program is effective? The Respiratory Protection Program Administrator must evaluate the duty station’s program annually. The evaluation must include review of:
A. The number of respirator users and their job classifications;
B. Types of respirators, cartridges, and filters used and the job tasks being performed while using them;
C. Job Hazard Assessments involving use of respirators;
D. Maintenance and care of the respirators; and
E. Records and documentation, including medical evaluations (dates and clearance statements), fit tests, training, etc.
14.19 What records does the Service keep for the Respiratory Protection Program? Your work area’s Respiratory Protection Program Administrator must maintain records about your medical clearance evaluations, training, fit testing, job hazard assessments, respiratory protection program plans, and any other appropriate items. This information helps us make sure the program is effective and provides a record for OSHA compliance inspections. Your Project Leader/supervisor must ensure that the Respiratory Protection Program Administrator keeps the following records. At your request, the Administrator must allow you to review these records. You may only view your own medical records.
A. Fit-testing records for each respirator user. Maintain these records until the next fit-test is conducted.
B. A written report of the Respiratory Protection Program Administrator’s annual program evaluations and inspections (see section 14.18).
C. A written report of hazard evaluations, air sampling results, industrial hygiene surveys, and respirator selection records. Keep these reports for a minimum of 30 years.
D. Records of medical evaluations for the respiratory protection program (see section 14.9). The collection and maintenance of records containing personal information (i.e., medical evaluations and physician statements clearing you to wear a respirator, etc.) must be consistent with the provisions of 5 U.S.C. 552a (The Privacy Act of 1974). Employees tasked with storing and maintaining such records must read and be familiar with OPM/GOVT-10. These records:
(1) Are sensitive and protected by The Privacy Act (see 204 FW 1 – 8 for more information on the Privacy Act),
(2) Must only be available to staff on a need-to-know basis.
(3) If electronic, must be password protected and only used in accordance with the routine uses identified in “OPM/GOVT-10, Employee Medical File System Records.”
(4) If hard copy, protected in a locked file and locked room that is available only to staff who have a need to know this information in accordance with OPM/GOVT-10.
E. A written record of all respiratory protection training you receive (see section 14.10). Keep these records at least until the respirator user’s next training session.
F. A written record of all respirator fit testing (see section 14.11). Keep these records at least until the respirator user’s next fit test.
For information on the content of this chapter, contact the Division of Safety and Health. For information about this Web site, contact Krista Holloway in the Division of Policy and Directives Management.