October 14th, 2022 | Posted in Air Cleaners
That seems like a perfectly sensible question to ask. If there is an airborne health hazard, wouldn’t it be reasonable to use respirators to control employee exposures?
It is not, however, as simple as just calling up the safety supply house and ordering some respirators. There is a federal regulation, 29 CFR 1910.134, that governs the use of respirators for controlling health hazards in the workplace. This is the OSHA Respiratory Protection Standard and it imposes a number of requirements on the employer when requiring the use of respirators. These are described in detail in the “Small Entity Compliance Guide for the Respiratory Protection Standard”. The requirements are comprehensive and lengthy, but here we will cover a few aspects to get a perspective.
First, it must be noted that OSHA, and best practice, require taking steps to reduce the airborne hazard before falling back on respirators as the means of exposure control. These include:
When engineering controls are not feasible, or while engineering controls are being installed or maintained, or whenever there is an emergency, appropriate respirators must be used. How does one know what constitutes “appropriate respirators?” The process for that determination is incorporated in a respiratory protection program.
The Respiratory Protection Standard mandates that the employer develops and implements a written respiratory protection program with worksite-specific procedures and elements for required respirator use. It is important that the program must be administered by a suitably trained program administrator.
One of the requirements of the Respiratory Protection Program is to identify and quantify the airborne health hazards. Meeting that requirement necessitates personal breathing zone monitoring at a cost of about $1,500 to $2,500 per day. It can take several days to complete the quantification of the airborne hazards with concomitant costs.
Once the concentrations of the contaminants have been quantified, appropriate respirators must be selected. Air purifying respirators have two elements: the face piece and the purifying cartridge that goes on the respirator. The two common types of air purifying respirator face pieces are half mask and full face piece. The half-mask air purifying respirator (HFAPR) facepiece provides an Assigned Protection Factor (APF) of 10; meaning it cuts the concentrations inside the face piece by a factor of 10. HFAPRs generally cost from $20 to $40 each without cartridges (which are extra and must be selected for the contaminant of concern, as all cartridges are not alike). This selection process is performed by the suitably trained program administrator usually with the support of an Industrial Hygienist.
As an example, if the concentrations identified by personal breathing zone monitoring are 5 times the exposure limit for the contaminant of concern, a half mask will be adequate. If, however, the concentrations are equal to or more than 10 times the exposure limit one must go to a full-face piece with an APF of 50. If this is not sufficient protection then a Powered Air Purifying Respirator (PAPR) may be required. PAPRs are available with APFs of up to 1000, and cost in the range of $1,500 to $3,000 each.
Once appropriate respiratory protection has been selected, employees should not just put them on and go to work. The Respiratory Protection Standard also requires that:
Clearly, all of the above tasks justify the OSHA requirement that “The employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program to administer or oversee the respiratory protection program and conduct the required evaluations of program effectiveness.”
Before going through all the steps of hiring or training a program administrator, performing personal breathing zone monitoring, medically qualifying employees, developing a written program etc., it makes sense to follow OSHA’s requirement to investigate engineering controls such as ventilation, isolation or enclosure of the work process. Industrial air cleaning is a perfect fit for these circumstances. Too often conditioned air is simply exhausted through the roof or wall and the money spent conditioning the workplace air is wasted. Cleaning and re-circulating the air can save on HVAC costs and reduce or eliminate the need for respiratory protection and its associated costs, inconveniences and employee discomfort. Investigate air cleaning before just going to respiratory protection.