Clemson University's Respiratory Protection Program

Section Number	Current Revision	Current Revision Date
1	2	January 1996
2	2	January 1996
3	2	January 1996
4	1	January 1996
5	1	January 1996
6	2	January 1996
7	2	January 1996
8	2	January 1996
9	1	January 1996
10	1	January 1996

Section 0 - General

Section 1.0 - Program Statement

1.1 - Respiratory Protection Program
1.2 - Purpose
1.3 - Objectives

Section 2.0 - Regulatory Requirements

2.1 - Regulations/Requirements

Section 3.0 - Responsibilities/Resources Employed

3.1 - Industrial Hygienist
3.2 - Occupational Health Nurse
3.3 - Principal Investigator/Supervisor
3.4 - Respirator Wearers
3.5 - Other

Section 4.0 - Respirator Selection/Use

4.1 - Industrial Hygienist
4.2 - Fit Factors
4.3 - Exclusive Student/Employee Respirator Usage

Section 5.0 - Training Requirements

5.1 - Employee/Student Training

Section 6.0 - Respirator Fit Testing

6.1 - Industrial Hygienist
6.2 - Conditions of Fit Testing

Section 7.0 - Respirator Inspection/Repair/Storage

7.1 - Inspection Frequency
7.2 - Repair of Respirators
7.3 - Storage of Respirators

Section 8.0 - Exposure/Health Assessment

8.1 - Assessment of Area Requiring Respiratory Protection
8.2 - Medical Approval

Section 9.0 - Program Evaluation

9.1 - External Audits
9.2 - Internal Audits

Section 10 - Respiratory Protection Records

10.1 - Data and Records
10.2 - Records Retention

Section 1. Program Statement

1.1 Respiratory Protection Program for Clemson University

Clemson University will maintain a healthy work environment in an on going effort to protect each employee and student from potentially harmful agents. It is the goal of Clemson University to insure that employees and students will at no time suffer any adverse health effects related to their work environment.

In the on going control of occupational diseases and deaths caused by inhaling air that is deficient in oxygen and/or contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective of Clemson University is to first prevent atmospheric contamination and deficiencies. Whenever feasible, control of atmospheric contamination and deficiencies shall be accomplished by implementing accepted engineering and/or administrative controls, including: enclosure, isolation, local exhaust systems, general exhaust systems and material substitutions.

It is the philosophy of Clemson University to utilize respiratory protection only when effective engineering and/or administrative controls are not feasible, or while they are being implemented. A sound and effective respiratory protection program is an essential aspect in assuring that personnel using such equipment are adequately protected.

1.2 Purpose:

The purpose of the Respiratory Protection Program (RPP) at Clemson University is to establish and maintain a program that will assure compliance with all applicable federal, state regulations concerning the selection, use and maintenance of respirators.

1.3 Objectives:

The objectives of the RPP include:

To ensure that respiratory protective equipment is utilized only when effective administrative and/or engineering controls are not feasible; or while they are being implemented.
To ensure that the correct type of respiratory protective equipment is selected for each application.
To ensure that respiratory protective equipment is clean and in good working order.
To ensure that respiratory protective equipment properly fits the user.
To ensure that users of respiratory protective equipment are adequately trained in the care, limitations, and proper application of the device.
To ensure that regulatory documentation is established and maintained in a logical and accessible manner.

Section 2. Regulatory Requirements

2.1 Regulations/Requirements

Requirements/references pertaining respirator use, maintenance, selection, and associated training are found in the following publications:

Occupational Safety and Health Standards for General Industry (29 CFR 1910.94).
Occupational Safety and Health Standards for General Industry (29 CFR 1910.120).
Occupational Safety and Health Standards for General Industry (29 CFR 1910.134).
Occupational Safety and Health Standards for General Industry (29 CFR 1910.156).
Occupational Safety and Health Standards for General Industry (29 CFR 1910.1001).
Mine Safety and Health Administration (30 CFR part 11).
Public Health Service (42 CFR part 84).
The United States Pharmacopoeia for medical or breathing oxygen.
The Compressed Gas Association Specification G-7.1-1966.

"American National Standard for Respiratory Protection" (ANSI Z88.2-1992), published by the American National Standards Institute, Inc.

"Respiratory Protection-Respirator Use-Physical Qualifications for Personnel", published by the American National Standards Institute, Inc.

Section 3. Responsibilities / Resources Employed

3.1 Industrial Hygienist:

The Industrial Hygienist is responsible for the development, implementation, and administration of the RPP. These responsibilities include:

Reviewing and updating the respiratory protection written program.
Conducting exposure and health hazard evaluations of the Clemson University work environment.
Approving respiratory protection equipment for Clemson University employees.
Providing instruction to personnel on the proper use, maintenance and storage of respirators.
Providing a fit testing program for respirator wearers.
Maintaining fit testing and training records.
Evaluating the overall effectiveness of the respirator program.

3.2 Occupational Health Nurse:

The Occupational Health Nurse will be responsible for:

Developing and implementing a medical surveillance program for all personnel utilizing respiratory protection.
Performing initial evaluations and physical examinations of the individuals using respiratory protection to determine if the individual is medically able to wear respiratory protective equipment.
Conducting periodic evaluations (and physicals as necessary) of respirator users.

3.3 Principal Investigators/Supervisors:

Principal investigators or supervisors have the primary responsibility for implementation of the respiratory protection program in their area of jurisdiction. The principal investigator/supervisor will be responsible for:

Supervising staff to ensure that the respirator protection program guidelines are followed.
Identifying and notifying Environmental Health and Safety of tasks/procedures which may require exposure/health assessments to determine if individuals need to utilize respiratory protection.
Identifying personnel under their supervision required to utilize respirators to the Industrial Hygienist.

3.4 Respirator Wearers:

Respirator wearers will be responsible for:

Using respirators in accordance with instructions and guidelines received during training courses.
Storing, cleaning, maintaining, and protecting respirators from damage.
Reporting any problems or malfunction with respiratory protective equipment to the department of Environmental Health and Safety.
Informing the Occupational Health Nurse or contracted medical personnel of health changes that would effect the safe use of respirators.

3.5 Other

Health, safety, medical, industrial hygiene consultants shall be utilized to support the Respiratory Protection Program as needed and if funding allows. Consultants may be utilized to provide independent data collection, assist in training programs and to assist in compliance audits.

Section 4. Respirator Selection/Use

4.1 Industrial Hygienist

The Industrial Hygienist is responsible for selecting respirators used for protection against exposure/health hazards. Selection of respirators will be based on applicable regulation/guidelines and the following factors:

Approval of the respirator by the Mine Safety and Health Administration (MSHA) and the National Institute of Occupational Safety and Health (NIOSH).
The substance present in the work environment for which respiratory protection is needed.
The physical state of the contaminant (gas, vapor, dust, mist, etc.).
The Permissible Exposure Limit (PEL) and toxicity of the substance.
The concentrations of the air contaminants likely to be encountered.
The fit factor listed for the respirator type.
The possibility of skin absorption or eye irritation.
The possibility of oxygen deficiency.
The nature of the individuals task/procedure.

4.2 Fit Factors

At no time will a respirator with a lower fit factor than required be selected for utilization. The maximum concentration that is allowable for a particular respirator is determined by the:

Fit Factor x PEL = Maximum Exposure Concentration Allowable

Prior to requiring respirator use an exposure/health hazard evaluation will usually be performed according the "Occupational Exposure Assessment Strategy Manual" for Clemson University. This manual is maintained by the Industrial Hygienist and outlines the procedures that must be followed to complete an exposure assessment at Clemson University. Reports and documentation concerning an exposure assessment will be generated and maintained in strict adherence to this manual.

4.3 Exclusive Student/Employee Respirator Usage:

All individuals who wear respiratory protective devices will be supplied with equipment for their exclusive use. An exception to this practice may be permitted for equipment utilized for emergency or rescue purposes (Self Contained Breathing Apparatus (SCBA) and Powered Air Purifying Respirators (PAPR)). Exclusive use respirators will be marked with the employees name or some other identification to prevent cross contamination.

Section 5. Training Requirements

5.1 Employee/Student Training

The Environmental Health and Safety Department is responsible for training individuals who wear respiratory protection to control exposure to hazardous agents. An exception to this practice may be permitted for equipment utilized for emergency or rescue purposes (SCBA). Courses related to emergency use equipment may be conducted by outside consultants or by qualified in-house personnel. Any individual who wears a respirator shall receive initial and periodic training in the proper use, care, and limitations of the selected respirator. This training shall include the following:

The nature of the respiratory hazard - what specific chemical substances are present, what areas, operations, or conditions involve potentially hazardous exposures and what effects may result if respirators are not used.
An explanation of why engineering controls are not immediately possible and a discussion of what efforts are being made to eliminate, and/or control the potentially hazardous agent.
An explanation of why the specific type of respirator has been selected and the associated fit factors.
A discussion and demonstration on how to properly use the respirator.
Instruction on the proper techniques/importance of cleaning, disinfecting, inspecting, maintaining, and storing the selected respirator.
A discussion of the capabilities, limitations and correct applications of the selected respirator.

Section 6. Respirator Fit Testing

6.1 Industrial Hygienist

Any individual who wears a respirator shall be assured of having a proper fitting respirator. Proper fitting shall be assured through quantitative and qualitative fit testing performed by the Industrial Hygienist or a qualified individual in the Environmental Health and Safety Department. An approval to wear a respirator will not be issued by the Environmental Health and Safety Department until a satisfactory qualitative or quantitative fit test has been performed. Fit testing will be performed at least annually for individuals utilizing respiratory protection and more frequently for specific job tasks (ex. asbestos every 6 months)

6.2 Conditions of Fit Testing

The following conditions must be met before respiratory fit testing can be undertaken:

Individuals must be medically certified to wear a respirator by the Occupational Health Nurse or by certified and approved outside medical personnel.
Respirators that require a face-respirator seal shall not be worn when conditions prevent an effective seal. Conditions that may affect the respirator-face seal include: eye/safety glasses, missing dentures, and facial hair.

If any of these conditions are not met, respirator fit testing can not be performed. An approval to wear a respirator will not be issued by the Environmental Health and Safety Department until the conditions of fit testing are met.

Section 7. Respirator Inspection / Repair / Storage

7.1 Inspection Frequency

All respirators shall be inspected routinely before and after each use and during cleaning procedures to ensure that it is in proper working condition. Respirators designed for emergency use shall be inspected at least monthly. Principal investigators/supervisors are responsible for monthly inspections of emergency use respirators. Inspections of emergency use respirators shall be recorded on the form titled "Emergency Use Respirator Inspection". This form will be issued monthly by the Industrial Hygienist and serves as a permanent record of regulatory compliance. An exception to this practice may be allowed for departments who perform inspections on a more frequent basis and who establish and maintain a method of documenting these inspections. Departments who establish and maintain a personalized method of inspection/documentation will be audited by the Industrial Hygienist annually.

7.2 Repair of Respirators

No repairs shall be made to air purifying respirators. If air purifying respirators are damaged or missing parts they should be discarded and a new respirator will be issued.

Repairs to SCBA or PAPR should only be performed by a trained individual and according to applicable manufacturer directions.

7.3 Storage of Respirators

All respirators shall be stored according to the following guidelines:

Respirators must be protected from dust, sunlight, heat, extreme cold, excessive moisture, and damaging chemicals. Most air purifying respirators can be stored in a clean plastic bag until they are used.
Emergency use respirators shall be stored in a cabinet or case located in a non-contaminated but readily accessible area.

Section 8. Exposure/Health Assessment

8.1 Assessment of Areas Requiring Respiratory Protection

The Industrial Hygienist will perform initial and periodic exposure monitoring in all areas requiring the use of respiratory protection. The frequency of periodic monitoring will be based upon applicable state and federal regulations and the judgment of the Industrial Hygienist. Exposure/health assessments will follow procedures found in the "Occupational Exposure Assessment Strategy" and the "Industrial Hygiene Program" manuals. Both of these manuals are maintained by the Industrial Hygienist and are found in the Environmental Health and Safety Department.

8.2 Medical Approval

When using air-purifying respirators, breathing can become difficult because the flow of air is impeded by a filter or cartridge device. A determination will be made by the Occupational Health Nurse or an approved/certified outside medical consultant if the employee is medically able to use a respiratory protective device. The initial determination will consist of a questionnaire evaluation followed by a health exam (if needed). This assessment must be performed prior to fit testing and assigning a respirator to an employee. The evaluation (and follow-up exam) will be repeated periodically for all respirator wearers. Supervisors/principal investigators will be advised of employees/students with medical limitations regarding the use of respirators.

Section 9. Program Evaluation

9.1 External Audits

Periodic evaluations will be made by the Industrial Hygienist to assure continued effectiveness of the program. Such evaluation will determine whether or not all requirements of the program are being adhered to properly. Periodic feedback will be solicited from respirator users and their supervisor and/or primary investigator.

Frequent random inspections will be conducted by the Industrial Hygienist to assure that: the proper respiratory protective equipment is being used, the equipment is being used correctly, users are certified to wear respirators, users are getting a good face-seal fit and that the equipment is being cleaned and stored properly. These inspections will be documented in the manual titled "Documentation of Industrial Hygiene Tasks Investigations" maintained by the Industrial Hygienist. A copy of the investigation will be distributed to the all involved parties.

9.2 Internal Audits

Every January, beginning 1997, the Industrial Hygienist will audit the respiratory protection program. This audit will include a complete review the RPP manual and any necessary changes will be made promptly. The internal audit will include a review of all investigations and reports issued during the preceding year related to the RPP. Any inconsistencies or inaccuracies concerning these investigations and reports will be noted.

The Industrial Hygienist will notify the Director of Environmental Health and Safety in writing of the internal audit findings, corrective action plans (if applicable), and possible steps to improve the overall program.

Section 10. Respiratory Protection Program Records

10.1 Data and Records

OSHA regulations require that records pertaining to fit testing and respiratory training be retained in a format that allows easy and logical access. All original Industrial Hygiene data pertaining to fit testing and respirator training will be kept on file in the Environmental Health and Safety file room, which is kept locked during non-working hours. All documentation will be arranged by department.

Duplicate computer files of fit testing and training records are maintained for efficient report writing and organizing. Computer word processing files of reports are also maintained.

10.2 Records Retention

Regulatory compliance data such as personal fit testing and respirator training will be retained indefinitely.