Respiratory Protection Policy

Policy Statement

Important Notice: no one is to purchase or use respiratory protection for potentially hazardous airborne contaminates without the oversight and approval of EHS. if you have concerns over the need for respiratory protection, read this document and contact EHS for assistance. Thank you!

Prepared in compliance with 29 CFR 1910.134

Scope of Policy

This policy is applicable to all areas of Dartmouth College where respiratory protection may be required. The Dartmouth College Respiratory Protection Policy (DCRPP) has been written in compliance with 29 CFR 1910.134. A complete copy of the OSHA standard can be found at the following address: (https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=standards).

Respirators will only be issued by Environmental Safety and Health Department upon completion of a hazard assessment, medical clearance and fit testing is completed.

Exposure Reduction Strategy

Whenever feasible, consideration should be given to eliminating the use of the hazardous material or substituting a less hazardous material. When elimination or substitution is not possible, the use of engineering controls, such as local exhaust ventilation should be utilized. Work practice controls such as moving the task into a better-ventilated area or applying the material in a different manner is a third alternative to reduce exposure to airborne  contaminants. The objectives of these methods are to remove the person from interaction with the chemical and/or the task. If this can be achieved, the need for a respirator is eliminated.

Medical Considerations

Prior to a Dartmouth College employee being issued a respirator, a licensed health care provider (LHCP) must medically clear that employee for respirator use.

Dartmouth College will provide the examining physician with the following information:

• Type of respiratory equipment to be used
• Type of work the individual will do while wearing the respirator
• Visual and audio requirements of the job
• Length of time the individual will wear the respirator
• Substances the individual will be exposed to.

The medical clearance procedure also requires the employee to complete the medical questionnaire in "Appendix A".

Along with the above mentioned job information, EHS will submit the questionnaire to the LHCP (Dick's House) for review. Following the medical review, The LCHP will do one of the following:

• Return the cover sheet (first page of Appendix A) to EHS as "medically able to wear a respirator"
• Return the cover sheet (first page of Appendix A) to EHS " not medically able to wear a respirator"
• Contact the employee for further medical evaluation. This may require an on site medical exam. The extent of the on site exam will depend upon an employee's individual health conditions.

Employee's who may wear respirators as part of their job are required to be medically cleared on an annual basis.

Selection of Respirators

Initial Assessment

Hazard Identification and Evaluation.¹ This typically involves a walk-through evaluation of the work environment or evaluation of the tasks/concerns posed by a given activity. The evaluation includes assessing the type of hazard (obvious or potential), the duration and frequency of use, and potential for acute or chronic exposures requiring the use of a respirator to control or limit potential exposures to within recognized, accepted occupational exposure limits.² Industrial Hygiene monitoring will be performed when necessary in the hazard ID and evaluation.

Hazard analyses have indicated that the following shops will be pre-screened for respirator use since their job duties MAY require them to use a respirator.

• Building Repair Shop
• Science Facilities Shop
• Heat/Power Plant
• Refrigeration technicians
• Welding Shop
• Ground Crew
• Animal Lab Technicians
• Environmental Safety & Health

Annual fit testing will be required for Painters, Masons, Heat/Power Plant and Animal Lab Technicians.

Since most jobs in the shops listed above may not use a respirator for a period of time (several years), fit testing will be conducted at the time a respirator is to be used.

Should respiratory protection be required—a preliminary determination by type is made. For example, air purifying (chemical or HEPA), etc.

Respirator Issuance

Control over the selection and purchase of respiratory protection rests with EHS. No one is to purchase or use any type of respiratory protection (exceptions for nuisance dust masks only) without the expressed permission of EHS.

Supplied Air Respirators

The only employees who may potentially be exposed to an IDLH atmosphere are EHS staff members. EHS staff members are trained to monitor and wear self contained breathing apparatus (SCBA)³ when necessary.

Members of the EHS staff are the only employees who may have a need to wear supplied air⁴ or SCBA's. (Quantitative fit testing is conducted every two years using a Portacount™ or similar instrument using a third party vendor.)

Air Purifying Respirators

Air purifying respirators include negative pressure half or full face (cartridge respirators), Disposable N-95 particulate respirators, and powered air purifying respirators (PAPR).

As required, employees will be fitted with equipment that is specific to their needs. A determination will be made based upon the exposure, the environment where it will be used, the duration of exposure employee comfort and fit factor requirements.

Respirator cartridges are designed to filter against specific hazards. Selection of the proper cartridge is essential for proper protection against air contaminants. EHS is responsible to insure that employees received the proper filtering cartridge.

Whenever feasible filter cartridges with an end of service life indicator will be used.

Filter cartridges that have been used will be replaced on an annual basis or more often as use requires. Respirator cartridges with an end of service life will be replaced just prior to reaching the end of their service life.

Voluntary Use of Respirators

Individuals may use a respirator on a voluntary basis under the following conditions:

• The employee must be medically cleared (Appendix A) to wear a respirator
• The respirator must be appropriate for the hazard.
• EHS will issue the respirator to the employee for voluntary use.
• The employee must read and sign "Appendix E" of this policy. (Appendix D of 29 CFR1910.134). This form must be given to EHS prior to respirator issuance.
• Fit testing is not required, however, EHS will fit test if requested by the employee.

Training

At a minimum this training will include:

• The proper fit, use and limitations of the respirator they have been given (what it can and cannot do). In particular, what to do in the event of a potentially dangerous atmosphere that may overwhelm the respirator or be oxygen deficient.
• Appropriate instruction on the inspection, care, maintenance, cleaning and storage of the respirator they have been issued.
• Annual retraining is required. The curriculum is updated on an on-going basis to reflect additions in content, training materials and product improvements.
• Appendix B or C will be used as a training guide.

Responsibilities

Once issued, the employee (and their supervisor) is responsible for ensuring that the respirator is worn when required and used in accordance with manufacturer and EHS requirements.

Program Audit

On an on-going basis the program is evaluated for compliance and effectiveness. A formal review of the program is conducted periodically by EHS.
 

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References

¹. At Dartmouth, few tasks require the routine use of a respirator for personal protection. Please refer to the Collegeʼs Hazard Communication and Chemical Hygiene Plans for additional information on chemical related safety and the use of respirators.

². OSHA PELs, ACGIH TLV-TWAs, NIOSH RELs, etc. For purposes of OSHA compliance, the PELs are the enforceable standards.

³. This equipment is routinely inspected by the Hanover Fire Dept. in accordance with NFPA standards

⁴. A specific Standard Operating Procedure (SOP) for this equipment is followed by the users at the Heating Plant.