Respiratory Protection Policy

Initiated:   July 20, 2005
Approved:  November 21, 2005

Purpose:

To identify Northern Michigan University’s policy for the voluntary use of certain types of respiratory protection.

Applicability:

All University employees, full time, part time, temporary, casual labor and students who choose to use their own respirators.  Note:  This policy does not include the voluntary use of filtering facepieces (dust masks).

Policy:

It is the policy of Northern Michigan University to comply with the requirements of Act 154, Public Acts of 1974, as amended, Part 451, Respiratory Protection.

References:

Act 154, Public Acts of 1974 as amended, Part 451 and 29 CFR1910.134 as adopted by reference.  (Part 451, 1910.134(c)(2))

Distribution:

Employees covered under this policy, their supervisors, department heads and Human Resources.  

Initiating Department

Public Safety and Police Services, 227-2152

Introduction: Section 24 of Act No. 154 of the Public Acts of 1974, as amended (Part 451. Respiratory Protection) require a limited written plan when employees are permitted to use their own respirators. The University must determine that the use of a respirator will not in and of itself create a hazard.

  1. Employees choosing to use their own respirators must first have the task and the respirator evaluated by their immediate supervisor. 
  2. The supervisor is required to notify the Safety Director, so copies of this policy and the Respirator Medical Evaluation Questionnaire and evaluation by Health Center Physician are completed. 
  3. No employee may use a respirator unless approved in accordance with this policy.
  4. This policy does not apply to the use of filtering facepieces (dust masks). 
  5. Questions about the policy or procedures should be directed to the University Safety Director (Director, Public Safety and Police Services.)

Administrative Measures:

Mandatory information for employees using respirators (Part 451, 1910.134(k)(6) and Appendix D to Section 1910.134)

“Respirators are an effective method of protection against designated hazards when properly selected and worn.  Respirator use is encouraged even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers.  However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker.  Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards.  If you employer provides respirators for your voluntary use, of if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.

You should do the following:

  1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care and warnings regarding the respirators limitations.
  2. Choose respirators certified for use to protect against the contaminant of concern.  NIOSH, the National Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services, certifies respirators.  A label or statement of certification should appear on the respirator or respirator packaging.  It will tell you what the respirator is designed for and how much it will protect you. 
  3. Do not wear you respirator into atmospheres containing contaminants for which your respirator is not designed to protect against.  For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.
  4. Keep track of your respirator, so that you do not mistakenly use someone else’s respirator.  ()63 FR 1152, Jan. 8, 1998; FR 20098, Apri8l 23, 1998)”

Maintenance and Care Of Respirators:  (Part 451, 1910.134(h)(1) Appendix B-2)  Mandatory

For those employees choosing to use their own respirators, the following procedures are mandatory:

Employees shall ensure that respirators are cleaned and disinfected using the following procedures, or procedures recommended by the respirator manufacturer, provided that the procedures are equally effective:

  1. Remove filters, cartridges, or canisters.  Disassemble facepieces by removing speaking diaphragms, demand and pressure demand valve assemblies, hoses, or any components recommended by the manufacturer.  Discard or repair any defective parts.
  2. Wash components in warm (43 degree C [110 degree F] maximum) water with a mild detergent or a cleaner recommended by the manufacturer.  A stiff bristle (not wire) brush may be used to facilitate the removal of dirt.
  3. Rinse components thoroughly in clean, warm (43 degree C [110 F] maximum,) preferably running water.  Drain.
  4. When the cleaner used does not contain a disinfecting agent, respirator components should be immersed for two minutes in one of the following.
    1. Hypochlorite solution (50 ppm of chlorine) made by adding approximately one milliliter of laundry bleach to one liter of water at 43 degree C (110 degree F); or
    2. Aqueous solution of iodine (50 ppm iodine) made by adding approximately 0.8 milliliters of tincture of iodine (6-8 grams ammonium and/or potassium iodide/100 cc of 45% alcohol) to one liter of water at 43 degree C (110 F); or
    3. Other commercially available cleansers of equivalent disinfectant quality when used as directed, if their use is recommended or approved by the respirator manufacturer.
  5. Rinse components thoroughly in clean, warm (43 degree C [110 degree F] maximum), preferably running water.  Drain.  The importance of thorough rinsing cannot be overemphasized.  Detergent or disinfectants that dry on facepieces may result in dermatitis.  In addition, some disinfectants may cause deterioration of rubber or corrosion of metal parts if not completely removed.
  6. Components should be hand-dried with a clean lint-free cloth or air-dried.
  7. Reassemble face piece, replacing filters, cartridges, and canisters where necessary.
  8. Test the respirator to ensure that all components work properly. [63 FR 1152, Jan. 8, 1998]

Respirators shall be cleaned and disinfected as often as necessary to be maintained in a sanitary condition.

Respirator Storage  (Part 451, 1910, 134 (h)(2))

Respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the face piece and exhalation valve, or stored in accordance with any applicable manufacturer instructions.  Keep in mind facepieces will become distorted and straps will loose their elasticity if hung on peg for a long period of time.  Storing a respirator in a plastic sealable bag after use is not considered a good practice; unless the respirator is allowed to completely dry before storage. 

Respirator Inspection:  (Part 451, 1910 (h)(3))

Respirators shall be inspected before each used and during cleaning.  The inspection will include the following: respirator function, tightness of connection, and condition of the various parts including, but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canisters or filters an; and electrometric parts for pliability and signs of deterioration.

Respirators that fail inspection or are otherwise found to be defective will be removed from service and discarded.

Respirator Cartridge Change Schedule:  (Part 451, 1910.134(d)(3)(iii)

A change schedule is the part of the written respirator program which says how often cartridges should be replaced and what information was relied upon to make this judgment.  A cartridge's useful service life is how long it provides adequate protection from harmful chemicals in the air.  The service life of a cartridge depends upon many factors, including;

  1. Worker Exertion Level:  a worker breathing twice as fast as another will draw twice the amount of contaminant through the respirator cartridge.
  2. Respirator Cartridge Variability:  some cartridges contain more activated charcoal than others. 
  3. Temperature:  the hotter it is, the shorter the service life.  Relative Humidity:  water vapor will compete with the organic vapors for active sites on the adsorbent.
  4. Multiple Contaminants, environmental conditions, and the amount of contaminants in the air.

There are three valid ways to estimate a cartridge’s service life: experimental tests, Manufacturer’s recommendation and use of a math model.

At Northern Michigan University, employees who elect to use respirators will adhere to the following change schedule:

  1. A respirator may be used as long as it functions properly.
  2. Cartridges (filters) must be replaced whenever they are: damaged, cause noticeably increased breathing resistance (e.g., causing discomfort to the wearer.), if the wearer smells or taste any vapors. 
  3. Follow the Manufacturer’s recommendation for cartridge’s service life.

Before each use the outside of the filter material should be inspected.  If the filter material is physical damaged or soiled, the filter must be changed.  Always follow the respirator filter manufacturer’s service-time-limit.

Medical Evaluation Questionnaire:  (Part 451, 1910.134(e)(2), (e)(2)(i), (e)(2ii) and Appendix C to Sec. 1910.134)

Employees who choose to use their own respirators are required to complete a confidential Medical Evaluation Questionnaire annually, which the employee will submit the University Health Center for evaluation by a staff physician.

  1. The Medical Evaluation Questionnaire must be completed and evaluated prior to the employee using the respirator.
  2. The Medical Evaluation Questionnaire shall also be completed whenever the employee reports medical signs or symptoms that are related to his/her ability to use a respirator,
  3. whenever a n employees supervisor requests a reevaluation
  4. or a change occurs in workplace conditions that mayu result in a substantial increase in the physiological burden placed on the employee.
  5. The Medical Evaluation is Attachment 1 to this document.

Employees are allowed to answer the questionnaire during normal working hours, or at a time and place convenient to them.  The questionnaire is confidential and your employer or supervisor may not look at or review your answers.

Questions:

Employees, supervisors or departments heads having questions about the policy or requiring assistance should contact the Safety Director (Director, Public Safety & Police Services.)


ATTACHMENT 1

Northern Michigan University Respirator Medical Evaluation Questionnaire (Mandatory)

Part A. Section 1. (Mandatory)
The following information must be provided by every employee who has been selected to use any type of respirator (please print).

  1.  Today’s date: _____________________________
  2.  Your name: _______________________________
  3.  Your age (to nearest year): ___________________
  4.  Sex (circle one): Male/Female
  5.  Your height: ______ ft. ______ in.
  6.  Your weight: ______ lbs.
  7.  Your job title: ______________________________
  8.  A phone number where you can reached by the health care professional who reviews this questionnaire (include Area Code): _____________________
  9.  The best time to phone you at this number: ________________________
  10.  Has your employer told you how to contact the health professional who will review this questionnaire (circle one): Yes/No
  11.  Check the type of respirator you will use (you can check more than one category):
    1. ____ N, R, or P disposable respirator (filter-mask, non-cartridge type only).
    2. ____ Other type (for example, half- or full-face piece type, powered-air purifying, supplied-air, self-contained breathing apparatus).
  12. Have you worn a respirator (circle one): Yes/No
    If “yes,” what type(s):

Part A. Section 2. (Mandatory)
Questions 1 through 9 must be answered by every employee who has been selected to use any type of respirator (please circle “yes” or “no”).

  1.  Do you currently smoke tobacco, or have you smoked tobacco in the last month: Yes/No
  2. Have you ever had any of the following conditions?
    1. Seizures (fits): Yes/No
    2. Diabetes (sugar disease): Yes/No
    3. Allergic reactions that interfere with your breathing: Yes/No
    4. Claustrophobia (fear of closed-in places): Yes/No
    5. Trouble smelling odors: Yes/No
  3. Have you ever had any of the following pulmonary or lung problems?
    1. Asbestosis: Yes/No
    2. Asthma: Yes/No
    3. Chronic bronchitis: Yes/No
    4. Emphysema: Yes/No
    5. Pneumonia: Yes/No
    6. Tuberculosis: Yes/No
    7. Silicosis: Yes/No
    8. Pneumothorax (collapsed lung): Yes/No
    9. Lung Cancer: Yes/No
    10. Broken ribs: Yes/No
    11. Any chest injuries or surgeries: Yes/No
    12. Any other lung problem that you have been told about: Yes/No
  4. Do you currently have any of the following symptoms of pulmonary or lung illness?
    1. Shortness or breath? Yes/No
    2. Shortness of breath when walking fast on level ground or walking up a slight hill or incline: Yes/No
    3. Shortness of breath when walking with other people at an ordinary pace on level ground: Yes/No
    4. Have to stop for breath when walking at your own pace on level ground: Yes/No
    5. Shortness of breath when washing or dressing yourself: Yes/No
    6. Shortness of breath that interferes with your job: Yes/No
    7. Coughing that produces phlegm (thick sputum): Yes/No
    8. Coughing that wakes you early in the morning: Yes/No
    9. Coughing that occurs mostly when you are lying down: Yes/No
    10. Coughing up blood in the last month: Yes/No
    11. Wheezing: Yes/No
    12. Wheezing that interferes with your job: Yes/No
    13. Chest pain when you breathe deeply: Yes/No
    14. Any other symptoms that you think may be related to lung problems: Yes/No
  5. Have you ever had any of the following cardiovascular or heart problems?
    1. Heart attack: Yes/No
    2. Stroke: Yes/No
    3. Angina: Yes/No
    4. Heart failure: Yes/No
    5. Swelling in your legs or feet (not caused by walking): Yes/No
    6. Heart arrhythmia (heart beating irregularly): Yes/No
    7. High blood pressure: Yes/No
    8. Any other heart problems that you have been told about: Yes/No
  6. Have you ever had any of the following cardiovascular or heart symptoms?
    1. Frequent pain or tightness in your chest: Yes/No
    2. Pain or tightness in your chest during physical activity: Yes/No
    3. Pain or tightness in your chest that interferes with your job: Yes/No
    4. In the past two years, have you noticed your heart skipping or missing a beat: Yes/No
    5. Heartburn or indigestion that is not related to eating: Yes/No
    6. Any other symptoms that you think may be related to heart or circulation problems: Yes/No
  7. Do you currently take medication for any of the following problems?
    1. Breathing or lung problems: Yes/No
    2. Heart trouble: Yes/No
    3. Blood pressure: Yes/No
    4. Seizures (fits): Yes/No
  8. If you have used a respirator, have you ever had any of the following problems? (If you have never used a respirator, check the following space and go to questions 9 ____ )
    1. Eye irritation: Yes/No
    2. Skin allergies or rashes: Yes/No
    3. Anxiety: Yes/No
    4. General weakness or fatigue: Yes/No
    5. Any other problem that interferes with your use of a respirator: Yes/No
  9. Would you like to talk to the health care professional who will review this questionnaire about your answers to this questionnaire: Yes/No

    Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-face piece respirator or a self-contained breathing apparatus (SCBA).  For employees who have been selected to use other types of respirators, answering these questions is voluntary.

  10. Have you ever lost vision in either eye (temporarily or permanently): Yes/No
  11. Do you currently have any of the following vision problems?
    1. Wear contact lenses: Yes/No
    2. Wear glasses: Yes/No
    3. Color blind: Yes/No
    4. An other eye or vision problems: Yes/No
  12. Have you ever had an injury to your ears, including a broken ear drum: Yes/No
  13. Do you currently have any of the following hearing problems: Yes/No
    1. Difficulty hearing: Yes/No
    2. Wear a hearing aid: Yes/No
    3. Any other hearing or ear problem: Yes/No
  14. Have you ever had a back injury: Yes/No
  15. Do you currently have any of the following musculoskeletal problems?
    1. Weakness in any of your arms, hands, legs or feet: Yes/No
    2. Back pain: Yes/No
    3. Difficulty fully moving your head up or down: Yes/No
    4. Pain or stiffness when you lean forward or backward at the waist: Yes/No
    5. Difficulty fully moving your head up or down: Yes/No
    6. Difficulty fully moving your head side to side: Yes/No
    7. Difficulty bending at the knees: Yes/No
    8. Difficulty squatting to the ground: Yes/No
    9. Climbing a flight of stairs or a ladder carrying more than 25 lbs: Yes/No
    10. Any other muscle or skeletal problem that interferes with using a respirator: Yes/No

Part B.
Any of the following questions, and the questions not listed, may be added to the questionnaire at the discretion of the health care professional who will review the questionnaire.

  1. In your present job, are you working at high altitudes (over 5,000 feet) or in a place that has lower than normal amounts of oxygen: Yes/No
  2. At work or at home, have you ever been expose to hazardous solvents, hazardous airborne chemicals (e.g. gases, fumes, or dust), or have you come into skin contact with hazardous chemicals: Yes/No
    If “yes”, name the chemicals if you know them:
  3. Have you ever worked with any of the materials, or under any of the conditions, listed below:
    1. Asbestos: Yes/No
    2. Silica (e.g. in sandblasting): Yes/No
    3. Tungsten/cobalt (e.g. grinding or welding this material): Yes/No
    4. Beryllium: Yes/No
    5. Aluminum: Yes/No
    6. Coal (for example, mining): Yes/No
    7. Iron: Yes/No
    8. Tin: Yes/No
    9. Dusty environments: Yes/No
    10. Any other hazardous exposures: Yes/No
      If “yes”, describe these exposures:
  4. List any second jobs or side businesses you have:
  5. List you previous occupations:
  6. List your current and previous hobbies:
  7. Have you been in the military services? Yes/No
    If “yes” were you exposed to biological or chemical agents (either in training or combat): Yes/No
  8. Have you ever worked on a HAZMAT team? Yes/No
  9. Other than medications fro breathing and lung problems, heart trouble, blood pressure, and seizures mentioned earlier in this questionnaire, are you taking any other medication for any reason (including over-the-counter medications): Yes/No
    If “yes,” name the medication if you know them:
  10. Will you be using any of the following items with you respirator(s)?
    1. HEPA Filters: Yes/No
    2. Canisters (for example, gas masks): Yes/No
    3. Cartridges: Yes/No
  11. How often are you expected to used the respirator(s) (circle “yes” or “no” for all answer that apply to you)?
    1. Escape only (no rescue): Yes/No
    2. Emergency rescue only: Yes/No
    3. Less than 5 hours per week: Yes/No
    4. Less then 2 hours per day: Yes/No
    5. 2 to 4 hours per day: Yes/No
    6. Over 4 hours per day: Yes/No
  12. During the period you are using the respirator(s), is your work effort:
    1. Light (less than 200 kcal per hour): Yes/No
      If “yes,” how long does this period last during the average shift: _____ hrs _____ min.
      Examples of light work effort are sitting while writing, typing, drafting, or performing light assembly work; or standing while operating a drill press (1-3 lbs.) or controlling machines.
    2. Moderate (200 to 350 kcal per hour): Yes/No
      If “yes,” how long does this period last during the average shift: _____ hrs _____ min.
      Examples of moderate work effort are sitting while nailing of filing; driving a truck of bus in urban traffic; standing while drilling, nailing, performing assembly work, or transferring a moderate load (about 35 lbs.) at trunk level; walking on a level surface about 2 mph or down a 5-degree grades about 3 mph; or pushing a wheelbarrow with a heavy load (about 100 lbs.) on a level surface.
    3. Heavy (above 350 kcal per hour): Yes/No
      If “yes,” how long doe this period last during the average shift: _____ hrs _____ min.
      Examples of heavy work are lifting a heavy load (about 50 lbs) from the floor to yours waist or shoulder; working on a loading dock; shoveling; standing while bricklaying or chipping castings; walking up an 8-degree grade about 2 mph; climbing stairs with a heavy load (about 50 lbs.).
  13. Will you be wearing protective clothing and/or equipment (other than the respirator) when you are using your respirator: Yes/No
    If “yes,” describe this protective clothing and/or equipment:
  14. Will you be working under hot conditions (temperature exceeding 77 deg. F): Yes/No
  15. Will you be working under humid conditions: Yes/No
  16. Describe the work you will be doing while using your respirator(s):
  17. Describe any special or hazardous conditions you might encounter when using your respirator(s) (for example, confined spaces, life-threatening gases):

  18. Provide the following information, if you know it, for each toxic substance that you will be exposed to when you using your respirator(s):
    Name of the first toxic substance:
    Estimated maximum exposure level per shift:
    Duration of exposure per shift:
    Name of the second toxic substance:
    Estimated maximum exposure level per shift:
    Duration of exposure per shift:
    Name of the third toxic substance:
    Estimated maximum exposure level per shift:
    Duration of exposure per shift:
    The name of any other toxic substance that you will be exposed to while using you respirator:

  19. Describe any special responsibilities you will have while using you respirator(s) that may affect the safety and well-being of other (for example, rescue, security):

[63 FR 1152, Jan. 8, 1998; 63 FR 20098, April 23, 1998]