[This document was edited on 7/14/2004 to strike information that no longer reflects current OSHA policy. On 12/31/2003, 29 CFR 1910.139 was revoked and the 1997 proposed standard on Occupational Exposure to Tuberculosis (TB) was withdrawn in the Federal Register. The changes to this directive were approved by the Assistant Secretary John Henshaw on 7/13/2004. The added language is marked by an asterisk (*) at the beginning and the end of the paragraph.]
|DIRECTIVE NUMBER: CPL 2-0.120
||EFFECTIVE DATE: September 25, 1998|
|SUBJECT: Inspection Procedures for the Respiratory Protection Standard|
||This instruction establishes agency interpretations and enforcement policies, and provides instructions to ensure uniform enforcement of the Respiratory Protection Standard, 29 CFR 1910.134|
||This instruction applies OSHA-wide|
||OSHA Instruction, CPL 2.103, Field Inspection Reference Manual. OSHA Instruction CPL 2.111, Citation Policy for Paperwork and Written Program Violations 29 CFR 1910.134, Respiratory Protection Standard. NIOSH Respirator Certification Requirements 42 CFR 84 and 30 CFR 11.|
||See Paragraph V.|
||National, Regional and Area Offices|
||Directorate of Compliance Programs|
||Office of Health Compliance Assistance (202) 219-8036|
200 Constitution Avenue, NW, Room N-3467
Washington, DC 20210
By and Under the Authority of
TABLE OF CONTENTS
TABLE OF CONTENTS
Federal Program Change
Inspection Guidelines for the Standard on Respiratory Protection, 29 CFR 1910.134.
- Scope and Application
- Permissible Practice - 1910.134(a)(1) and (a)(2)
- Respiratory Protection Program-1910.134(c)(1)
- Selection of Respirators and Hazard Evaluation-1910.134(d)
- Medical Evaluation - 1910.134(e)
- Fit Testing-1910.134(f)
- Use of Respirators
- Maintenance and Care of Respirators - 1910.134 (h)(1)
- Breathing Air Quality and Use 1910.134 (i)
- Identification of Filters, Cartridges, and Canisters 1910.134 (j)
- Training and Information 1910.134 (k)
- Program Evaluation 1910.134(l)
- Recordkeeping - 1910.134(m)
- Dates 1910.134 (n)
Interface with Other Standards
Classification and Grouping of Violations.
Authorization to Review Limited Medical Information.
Training for OSHA Personnel.
Medical Examinations for OSHA Personnel
Protection of OSHA Personnel
CHANGE SCHEDULES GUIDE - A LISTING OF METHODS
Purpose. This instruction establishes agency interpretations and enforcement policies, and provides instructions to ensure uniform enforcement of the Respiratory Protection Standard, 29 CFR 1910.134.
Scope. This instruction applies OSHA-wide.
OSHA Instruction, CPL 2.103, Field Inspection Reference Manual, September 26, 1994.
OSHA Instruction CPL 2.100, Inspection Procedures for the Permit Required Confined Space Standard, May 5, 1995.
OSHA Instruction CPL 2.111, Citation Policy for Paperwork and Written Program Violations, November 27, 1995.
OSHA Instruction, CPL 2-2.30, Authorization of Review of Medical Opinions, November 14, 1980.
OSHA Instruction, CPL 2-2.32, Authorization of Review of Specific Medical Information, January 19, 1981.
OSHA Instruction, CPL 2-2.33, Rules of Agency Practice and Procedure Concerning OSHA Access to Employee Medical Records-Procedures Governing Enforcement Activities, February 8, 1982.
OSHA Instruction, CPL 2-2.46, Authorization and Procedures for Reviewing Medical Records, January 5, 1989.
OSHA Instruction CPL 2-2.59A, Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, April 24, 1998.
OSHA Instruction, PER 8-2.4, CSHO Pre-Employment Medical Examinations, March 31, 1989.
OSHA Instruction, PER 8-2.5, CSHO Medical Examinations, March 31, 1989.
29 CFR 1910.134, Respiratory Protection Standard.
NIOSH Respirator Certification Requirements 42 CFR 84 and 30 CFR 11.
1992 American National Standards Institute (ANSI) Z88.2 Respirator Standard.
Action. OSHA Regional Administrators and Area Directors shall use the guidelines in this instruction to ensure uniform enforcement of the Respiratory Protection Standard, 29 CFR 1910.134.
Federal Program Change. This instruction describes a Federal Program Change for which State adoption is not required. NOTE: In order to effectively enforce safety and health standards, guidance to compliance staff is necessary. Therefore, although adoption of this instruction is not required, States are expected to have standards, enforcement policies and procedures which are at least as effective as those of Federal OSHA.
Background. In 1971, OSHA adopted the ANSI standard Z88.2-1969, "Practices for Respiratory Protection," as well as ANSI Standard K13.1-1969, "Identification of Gas Mask Canisters" as its standard for respiratory protection. In April of 1971, OSHA promulgated 29 CFR 1926.103, the initial respiratory protection standard for the construction industry. On February 9, 1979, OSHA announced that 29 CFR 1910.134 would be formally recognized as also being applicable to the construction industry (44 FR 8577).
On November 15, 1994, OSHA issued a Notice of Proposed Rulemaking to revise 29 CFR 1910.134. Public hearings were held in 1995, and the Final Rule was published in the Federal Register on January 8, 1998. The new standard updates the previous standard and incorporates new technology and current scientific knowledge regarding respiratory protection. Application of the requirements of the new standard in affected workplaces will promote more effective use of respirators and provide greater compliance flexibility. Language in the new standard has been developed to make some requirements in the previous standard more understandable. On April 23, 1998, corrections to the regulatory text were published in the Federal Register.
The new respiratory protection standard also makes the respiratory protection provisions of other health standards consistent with each other and with the final rule. This will make these provisions easier to administer.
The prior Respirator Standard, 1910.134, remains in effect until October 5, 1998, the date when employers must be in compliance with the new standard.
On October 5, the prior 1910.134 will be retained, but re-designated as 1910.139. It will apply only to respiratory protection against M. tuberculosis (TB) until OSHA has promulgated the final standard for Occupational Exposure to Tuberculosis.
*On October 5, the prior 1910.134 was retained, but re-designated as 1910.139. It applied only to respiratory protection against M. tuberculosis (TB) until OSHA withdrew promulgation of a final standard for Occupational Exposure to Tuberculosis on December 31, 2003. At that time OSHA also revoked 1910.139. Effective January 1, 2004, employers, who have employees required to wear respirators for protection against TB, must also be in compliance with the new standard.*
Inspection Guidelines for the Standard on Respiratory Protection, 29 CFR 1910.134. These guidelines relate to specific provisions of 29 CFR 1910.134 and are provided to assist compliance officers with conducting inspections where the standard may apply. Any subparagraphs of the standard not discussed in this Directive, should be enforced according to their terms.
Scope and Application
This new standard applies to all respirator usage in General Industry, Shipyards, Marine Terminals, Longshoring and Construction workplaces. It does not apply to agricultural operations
or to occupational exposure to M. tuberculosis. Respiratory protection against tuberculosis will continue to be enforced under the old 1910.134, which has been redesignated 1910.139.
The standard covers respirator use where respirators are being worn to protect employees from exposure to air contaminants above an exposure limit or are otherwise necessary to protect employee health, where respirators are otherwise required to be worn by the employer, and where respirators are voluntarily worn by employees for comfort or other reasons.
Permissible Practice - 1910.134(a)(1) and (a)(2): Section 134 (a)(1) restates OSHA's longstanding policy that engineering and work practice controls should be the primary means used to reduce employee exposure to toxic chemicals, and that respirators should only be used if engineering or work practice controls are infeasible or while they are being implemented. This preference for engineering and work practice controls is stated in a number of OSHA's substance specific standards (for example, the asbestos standard) and in the standards (29 CFR 1910.1000 and, for construction work, 29 CFR 1926.55) establishing permissible exposure limits for a number of harmful air contaminants. Feasible engineering, administrative or work practice controls must be instituted even though they may not be sufficient to reduce exposure to or below the permissible exposure limit (PEL). They must be used in conjunction with respirators whenever exposures exceed permitted levels.
Inspection Guidelines. The compliance officer should determine what engineering controls are in place and what work practices have been instituted to effectively reduce exposure. If controls are in place, but sampling results indicate these controls have not reduced air contaminant levels to the extent necessary to protect the health of the employee, then the CSHO should determine if the appropriate respirators are being provided and properly used. Even if the employer has not instituted the required engineering controls, failure to provide respirators to protect employees health is citable under 1910.134.
Citation Guidelines: In cases where an overexposure to an OSHA Permissible Exposure Limit (PEL), (either an 8-hour time-weighted-average , Ceiling Value, Short Term Exposure Limit or Acceptable Maximum Peak) is exceeded, the following principles apply:
Violations for Exceeding an Exposure Limit. Where a PEL is exceeded for a substance listed in Table Z of 1910.1000 or Appendix A of 1926.55, the appropriate paragraph 1910.1000(a) thru (d), or 1926.55(a), should be cited. For substance-specific standards, the appropriate paragraph for exceeding the PEL should be cited.
Exposures to levels of air contaminants which exceed ACGIH Threshold Limit Values (TLVs) or NIOSH recommended exposure limits (RELs), but which have no OSHA PEL, and which are considered to be serious exposure hazards, should be considered for violations of Section 5(a)(1) of the Act. Guidelines on citing Section 5(a)(1) can be found in the Field Inspection Reference Manual (CPL 2.103 Chapter III).
Section 5(a)(1) shall not normally be used to impose a stricter requirement than that required by the standard. For example, if the standard provides for a permissible exposure limit (PEL) of 5 ppm, even if data establishes that a 3 ppm level is a recognized hazard, Section 5(a)(1) shall not be cited to require that the 3 ppm level be achieved unless the limits are based on different health effects. If the standard has only a time-weighted average permissible exposure level and the hazard involves exposure above a recognized ceiling level, the Area Director shall consult with the Regional Solicitor.
NOTE: An exception to this rule may apply if it can be documented that "an employer knows a particular safety or health standard is inadequate to protect his workers against the specific hazard it is intended to address." Such cases shall be subject to pre-citation review.
Section 5(a)(1) violations of the Act should be cited so as to cover all aspects of a serious hazard for which no standard exists. Related violations of the respirator or other standards should be grouped with any Section 5(a)(1) violations.
Engineering and Administrative Controls. An employer's failure to implement feasible engineering or work practice controls should be cited under an applicable provision of a substance-specific standard (for example, section 1910.1000(f) of the general industry asbestos standard) or, for those substances listed in 1910.1000 or 1926.55, under 1910.1000(e) or 1926.55(b). The requirement to implement feasible engineering and administrative controls is in several substance-specific standards (for example, section 1910.1001(f) of the asbestos standard). These violations should normally be grouped with the overexposure. Section 1910.134 (a)(1) should not be cited along with 1910.1000(e) or 1926.55(b). Section 1910.134(a)(1) should not be cited when an employer fails to use engineering or work practice controls to reduce exposures to chemicals for which OSHA has not established permissible exposure limits. In appropriate circumstances, an employer's failure to use feasible engineering or work practice controls when there is no OSHA PEL may be citable under 5(a)(1) of the Act.
The Requirement to Provide Respirators. Whether or not an employer has instituted required engineering or work practice controls, the employer's failure to provide respirators when employees are exposed to hazardous levels of air contaminants is citable under 1910.134. The requirement to provide respirators is found in several substance-specific standards (for example, 1910.1025(e) and (f) of the general industry lead standard). In cases involving those standards, where respirators have not been provided, the section of the substance-specific standard requiring respirators should be cited. If the substance is listed only in Table Z, the violation for not providing a respirator should be cited 1910.134(a)(2). These violations also would normally be grouped with the overexposure.
The employer must provide the right type of respirator for the substance and level of exposure involved. If the employer provided the wrong kind of respirator, a citation should be issued under paragraph (d) for not providing an appropriate respirator, unless a substance specific standard is applicable.
The Requirement to Ensure the Use of Respirators. Where respirators are needed to protect the health of the employees, employers must not only provide respirators but ensure that employees use them. In cases involving substance-specific standards, the section of the standard requiring respirator use should be cited when employers have not ensured respirator use. If the substance is only listed in Table Z (1910.1000) or Appendix A (1926.55), citations for not ensuring respirator use should be cited under 1910.1000(e) or 1926.55(b). For substances not listed in 1910.1000, 1926.55, or substance-specific standards, 1910.134(a)(1) should be cited when the employer fails to ensure respirator use.
The Requirement to Have a Program. Paragraph (a)(2) requires the employer to establish and maintain a respiratory protection program that includes the requirements in 1910.134(c) whenever respirators are required to protect the health of the employee. The program must be in writing and contain all of the elements specified in 1910.134(c). If the employer has no program at all (i.e., no elements of a respirator program in place), a citation for violation of .134 (a)(2) should be issued. If respirators are used or other respirator violations are found, and there is no written program, then those violations and .134(c)(1) should be cited. If an employer has a written program, but an element required by .134(c) is omitted, then the subsection of .134(c) that requires the missing element should be cited.
The specific actions that the employer must take are in 1910.134(d)-(m). If the employer's written program has all of the required elements, but the employer has not taken one of the actions required in .134(d)-(m), cite the applicable paragraph in .134(d)-(m). If no written program exists, but all other provisions of the standard have been met, a violation for lack of a written program would normally not be cited. CPL 2.111, Citation Policy for Paperwork and Written Programs, should be reviewed for guidance before citing the written program.
- Definitions-1910.134(b): The revised standard now contains definitions in
paragraph (b) that provide a clearer understanding of specific terminology used in
the standard and how these terms are applied to respirators and their use. Some
definitions in the proposal were not included in the final standard, and some new
definitions were added.
- "Adequate warning properties" was not included in the final standard
because the two major warning properties, odor and irritation, are
unreliable or otherwise inappropriate to be used as primary indicators of
- "Assigned Protection Factor" has not yet been included in the standard.
OSHA is conducting further rulemaking on this issue, and will eventually
add the APFs to the final standard. In the interim, OSHA will continue to
refer to NIOSH APFs except in cases where APFs have been published in
substance-specific standards or are addressed by OSHA in separate letters
of interpretation. Employers must rely on the best available information
when selecting the appropriate respirator.
- "Filtering facepiece" (dust mask) means a negative pressure particulate
respirator with a filter as an integral part of the facepiece or with the entire
facepiece composed of the filtering medium. Whenever a filtering
facepiece is used to meet the requirements of the standard, it must be
- A "HEPA filter"(High Efficiency Particulate Air) is a filter that is
99.97% efficient in removing monodispersed particles of 0.3 micrometers
in diameter. NIOSH no longer uses this term in its new respirator
certification standard (42 CFR 84). However, OSHA has retained this
definition because it is used in many of the existing substance-specific
standards. When HEPA filters are required by an OSHA standard, N100,
R100, and P100 filters can be used to replace them.
Note: NIOSH Respirator Certification Requirements, 30 CFR 11 (Part
11) were replaced by 42 CFR 84 (Part 84) on July 10, 1995. Only
certifications of non-powered, air-purifying, particulate-filter
respirators were affected by this change. The remaining portions of
Part 11 were incorporated into Part 84 without change. Part 84
permitted the manufacture and sale of non-powered-particulate
respirators certified under Part 11 until July 10, 1998.
Distributors who have purchased these respirators will be able to
sell them until their inventories are depleted. Employers may
continue to purchase available products and will be permitted to
use them until their inventories are depleted, or until the shelf or
service life for the product expires. However, Dust/Mist and
Dust/Mist/Fume Filters may only be used for particulates with
mass median aerodynamic diameters (MMAD) of least 2
micrometers, in accordance with paragraph (d)(3)(iv)(C). Welding
fumes and silica flour may be examples of dust particulates that
are less than 2 micrometers. If the MMAD cannot be determined,
a HEPA filter, or a filter certified by NIOSH under 42 CFR 84
(N95 or higher) must be selected.
Respiratory Protection Program-1910.134(c)(1): A written respiratory
protection program is required when necessary to protect the health of the
employee from workplace contaminants or when the employer requires the use of
respirators. A limited written program is also required when respirators (other
than filtering facepieces) are being voluntarily worn by employees. The program
must include workplace specific procedures and contain all applicable program
elements. Where respirators are required, respirators (and their associated
requirements such as fit-testing and maintenance), training and medical
evaluations must be provided at no cost to the employee. It is the intent of the
standard that the employer would not be required to incur any costs associated
with voluntary use of filtering facepieces other than providing a copy of Appendix
D to each user. If employers allow the voluntary use of respirators other than
filtering facepieces, the costs associated with ensuring the respirator itself does
not create a hazard, such as medical evaluations and maintenance must be
provided at no cost to the employee.
- Inspection Guidelines. During inspections of workplaces where
respirators are used, the CSHO is to evaluate the respiratory program and
determine if the employer's written program is adequate and complete for
that particular site.
The program must be tailored to cover the specific work operations and
practices in the workplace. The provisions listed in paragraph (c)(1)(i)
thru (ix) of the standard must be included in the written program unless it
is determined they are not applicable.
These provisions are to be considered when evaluating a written program:
- (i) procedures for selecting respirators
- (ii) medical evaluations for users,
- (iii) fit-testing procedures for tight-fitting respirators,
- (iv) procedures for proper use during routine and emergency
- (v) procedures for cleaning, storing, disinfecting, etc.,
- (vi) procedures to ensure adequate air quality and flow for
- (vii) training on respiratory hazards,
- (viii) training on proper use, donning and removing the respiratoretc.,
- (ix) procedures for regularly evaluating the effectiveness of the
Compliance with the program should be verified during the walkaround by
personal observation and employee interviews.
- Citation Guidelines. If respirators are required to be worn in the
workplace or respirators other than dust masks are worn by voluntary
users, a written program is required. An overexposure is not required to
cite this paragraph. If the CSHO determines that specific provisions are
lacking or deficient in the written program, the CSHO should cite section
(c)(1) with the specific element(s) that are missing. Discrepancies
between the written program and implemented work practices at the
worksite should be cited by the appropriate paragraph in the standard that
requires the work practice. If overexposures are found and no program at
all exists, paragraph (a)(2) should be cited.
- (c)(2) Voluntary Use: Normally, respirators that are voluntarily used by
employees will be filtering facepieces (dust masks). NIOSH-approved
respirators are strongly recommended, but they are not required for
voluntary use. This voluntary use of dust masks alone does not require the
employer to have a written program. For filtering facepiece respirator use,
the employer needs only ensure that dust masks are not dirty or
contaminated, that their use does not interfere with the employee's ability
to work safely, and that a copy of Appendix D is provided to each
voluntary wearer. Merely posting Appendix D is not considered adequate.
Use of elastomeric or supplied-air respirators, even when voluntary on the
part of the employee, will require the employer to include all elements in a
written program that will ensure use of these respirators does not create a
- Inspection Guidelines Even though employees may be voluntarily using
respirators, adverse health conditions can be caused by the wearing of a
respirator itself. Examples include, but are not limited to;
- (1) an employee's health being jeopardized by the wearing of a
respirator (e.g., employee has a cardiac and/or pulmonary disorder
that could be aggravated by respirator use),
- (2) the wearing of a dirty respirator that can cause dermatitis or
ingestion of a hazardous chemical;
- (3) the sharing of a respirator that leads to transmittal of disease.
- Citation Guidelines Maintenance (h) and medical evaluation (e) violations
should be considered for all situations where employees have elected to
use a respirator, other than a dust mask, for personal comfort. If
overexposures are found, then all other applicable subparagraphs should
- (c)(3) Program Administrator: A "respiratory protection program
administrator" is required to oversee and evaluate the respirator program.
This individual must be suitably trained and have the appropriate
accountability and responsibility to manage the full respiratory protection
Companies with multiple worksites may have a program administrator at
each worksite, as long as this person is qualified and retains the
accountability and responsibility for the day-to-day operation of the
specific program for that site. Alternatively, a company may opt to have
one program administrator for several sites and/or one program for several
similar sites as long as the program contains the necessary elements and
addresses the hazards at those sites.
- Inspection Guidelines. The extent of training or experience required for
the program administrator will vary based on the complexity of the
respiratory hazards in the workplace. Where significant program
deficiencies are discovered, compliance officers should discuss questions
about the program with the program administrator to determine how
familiar she or he is with respirators, the hazards in the workplace,
respirator use in the facility, the respirator standard and the company's
Selection of Respirators and Hazard Evaluation-1910.134(d): The employer
is required to select and provide an appropriate respirator (NIOSH certified) based
on the respiratory hazard(s) present in the workplace. The employer must identify
hazardous airborne contaminants that employees may inhale and make a
reasonable estimate of employee exposures in determining the appropriate
respirator for employees to use. Oxygen deficient atmospheres and those
atmospheres that are not or cannot be estimated must be treated as IDLH
environments. Where a contaminant is regulated by a substance-specific standard
that requires monitoring, failure to monitor in accordance with the standard's
terms would be cited under that standard. For other contaminants, although the
most reliable and accurate method to determine exposure is to conduct personal
air monitoring, it is not explicitly required by the respirator standard. Instead,
other means can be used to estimate workplace exposures. Acceptable means
- Use of objective data - this is the use of data obtained from industry
studies, trade associations, or from tests conducted by chemical
manufacturers which demonstrate that air contaminants cannot be released
in the workplace in airborne concentrations that are IDLH. The objective
data shall represent the highest contaminant exposures likely to occur
under reasonably foreseeable conditions of processing, use, or handling.
The employer must document the use of objective data as part of their
- Application of mathematical approaches - the preamble to the final rule
(p. 1199) states that employers can use data on the physical and chemical
properties of air contaminants, combined with information on room
dimensions, air exchange rates, contaminant release rates, and other
pertinent data including exposure patterns and work practices to estimate
the maximum exposure that could be anticipated in the workplace.
- As a continuing practice, employers are required to identify hazards as a
result of changes in the workplace such as a change in equipment, process,
products, or control measures that could result in new exposures.
Appropriate respirators should be provided as necessary.
- Inspection Guidelines. The CSHO should closely scrutinize the
employer's estimate of employee exposure and determine if the hazard
assessment is based on appropriate data and reliable information. OSHA
personnel have considerable experience evaluating air monitoring data for
representativeness of the sample and reliability and accuracy of data.
Where objective data are used in the workplace to determine employee
exposure, the data must have been obtained under conditions which
closely resemble the process, types of materials, control methods, work
practices, and environmental conditions.
In regards to mathematical predictive equations, their use should be
limited to situations where workplace factors, such as contaminant release
and ventilation system performance, are fairly constant over the work shift
and predictable. The results should incorporate reasonable safety factors
and be interpreted conservatively. CSHO's must exercise a great deal of
professional judgement in concluding if the mathematical approach
provides appropriate guidance. (e.g., The methylene chloride standard
forbids the use of APR's for protection against methylene chloride and
would supercede any model which predicts a changeout time for this
The CSHO should examine the employer's Hazard Communication
Program for further information on existing respiratory hazards in the
The Hazard Communication Standard requires employers to inventory the
hazardous chemicals in their workplace and to maintain copies of material
safety data sheets (MSDS) for each hazardous chemical. In a similar
manner under the respirator standard, the employer must examine the
workplace and determine if the quantity, circumstances, and use of the
hazardous chemicals require further evaluation for respiratory hazards.
MSDSs contain information such as physical and chemical characteristics
and hazards, primary route(s) of entry, and generally applicable control
measures. Some MSDSs include some recommendations on appropriate
For those chemicals that do present a potential respiratory hazard,
employers can contact the chemical manufacturer for additional
information on predicted exposure levels and methods to further control
The CSHO should be aware of the potential for an emergency situation
and the type of respirators selected. The employer must provide the
appropriate emergency escape respirator in the immediate work area for
employee use and address emergency use respirators in the written
The CSHO should also investigate, through routine employee interviews,
what actions the employer has taken to re-evaluate employee exposure
when employees have made health complaints to determine if appropriate
action has been taken to address a respiratory hazard.
Respirators required to be used in the workplace must be NIOSH-approved and appropriate for the hazard. Part 84 respirators with an "N"
designation should not be used in work settings where oil aerosols are
generated, while those with an "R" designation should be used for only
one shift when oil is present. Respirators with a "P" designation may be
used for more than one work shift, even when oil is present. Employers
must follow respirator manufacturer's recommendations.
- Citation Guidelines. If the employer has not made any effort to assess the
respiratory hazards, and there is potential for an overexposure, the CSHO
should cite section (d)(1)(iii). The extent to which the employer explored
ways to reasonably estimate exposures must be evaluated at each worksite.
Inappropriate respirators [(d)(1)(i)] should be cited when the CSHO
documents an overexposure is possible, and a suitable respirator is not
being used for protection against that exposure . Unapproved [(d)(1)(ii)]
respirators can be cited even where an overexposure has not been
- (d)(3)(iii)(B) Air-purifying Respirators for Protection Against Gases and
Vapors on Atmospheres That Are Not IDLH - If a cartridge/canister air
purifying respirator for the protection against gases and vapors does not
have an ESLI, then the employer must implement a cartridge/canister
change schedule based on objective information that will ensure the
cartridges/canisters are changed before the end of their service life. The
purpose of a change schedule is to establish the time period for replacing
respirator cartridges and canisters; this is critical to preventing
contaminants from respirator breakthrough, and thereby over-exposing
workers. Data and information relied upon to establish the schedule must
be included in the respirator program. The requirements for several of
OSHA's chemical specific standards already address this issue and have
been retained. These include:
||end-of-service life or end of
shift (whichever occurs first)
||end-of-service life or
beginning of shift (whichever
||Butadiene 1910.1051 (h)(2)(ii)
||every 1, 2 or 4 hours
dependent on concentration
according to Table 1 and at
beginning of each shift|
||Formaldehyde 1910.1048 (g)(2)(ii) -
|| for cartridges every three
hours or end of shift
(whichever is sooner); for
canisters, every 2 or 4 hours
according to the schedule in
||Vinyl chloride 1910.1017(g)(3)(ii)
|| end-of-service life or end of
shift in which they are first
used (whichever occurs first)|
||Methylene chloride -
|canisters may only be used for emergency escape and must be replaced after use.|
Change schedules for all other gases and vapors must be established and
implemented by the employer. OSHA has stated in the preamble to the
final rule that the employer is not required to research and analyze
experimental breakthrough data, but may obtain information from sources
who have expertise and knowledge that can help the employer to develop
reasonable change schedules. The new standard prohibits the use of
warning properties as the sole basis for determining change schedules.
However respirator users should be trained to understand that abnormal
odor or irritation is evidence that respirator cartridges need to be replaced.
Where an effective change schedule is implemented, air-purifying gas and
vapor respirators may be used for hazardous chemicals, including those
with few or no warning properties.
- Inspection Guidelines - OSHA understands that new or existing objective
data could be presented in a variety of formats and from a number of
different sources. CSHOs should approach the evaluation of this
requirement with professional judgement and flexibility. There are a
number of factors that influence the service life of a cartridge. Some of
the more significant factors include: the contaminant's chemical
properties, temperature, humidity, contaminant concentration, work rate
(breathing rate) of the respirator user, variability of respirator cartridges
between manufacturers, and the presence of multiple contaminants. To
ensure fair and reasonable enforcement of this provision, the following
guidelines are presented to assist the CSHO in determining compliance
with this provision.
- Availability of Objective Data: Ascertain if there are sources of
objective data for the particular make and model of the respirator
cartridge/canister and if this data is sufficient to implement change
schedules. Typical sources would include: respirator
manufacturers, industry organizations, trade associations,
professional societies, chemical manufacturers (MSDS), academic
institutions, and ad hoc committees. The CSHO should determine
if the employer has access to adequate information to comply with
this provision. For a list of some options that employers may use
in developing their change schedules, refer to Appendix A.
- Use of Inappropriate Respirator Cartridge/canister: Determine if
the air purifying respirator is appropriate for the contaminant
present in the workplace. In some cases, the breakthrough time
may be so rapid (minutes) that air purifying respirators are not
feasible and supplied air respirators should be used. CSHOs
should consult respirator manufacturers and other reference
material for this information.
- Change Schedules For Mixtures: Establishing cartridge service life
for mixtures of contaminants is a complex task and one that
requires considerable professional judgement to create a reasonable
change schedule. Cartridge service life for mixtures is best
determined using experimental methods. Change schedules are
very difficult to develop for mixtures using predictive
The change schedule for a mixture should be based on reasonable
assumptions that include a margin of safety for the worker wearing
the respirator. Where the individual compounds in the mixture
have similar breakthrough times (i.e. within one order of
magnitude), service life of the cartridge should be established
assuming the mixture stream behaves as a pure system of the most
rapidly migrating component or compound with the shortest
breakthrough time (i.e., sum up the concentration of the
components). Where the individual compounds in the mixture
vary by 2 orders of magnitude or greater, the service life may be
based on the contaminant with the shortest breakthrough time.
OSHA believes that an approach such as this reflects good health
and safety practice where neither objective or experimental data is
available for the mixture.
OSHA believes that change schedule information will become
more available to the respirator user community and will evolve in
quality. The CSHO should review the written respiratory
protection program to ensure that it describes the information and
data relied upon and the basis for the canister and cartridge change
schedule and the basis for reliance on the data as required by the
standard. Again, CSHOs should exercise judgement in evaluating
mathematical models, rules of thumb, experimental data, use of
analogous chemical structures, and other reasoned approaches.
- Chemical Contaminant Migration: CSHO's should be aware that
some contaminants have a tendency to migrate through
cartridge/canister sorbent material during periods of storage or
non-use. This is characteristic of the contaminant-carbon bed
interaction for organic chemicals with boiling points below 65
Centigrade and would predictably shorten breakthrough times. In
cases where respirators are used for multiple days this could
present an additional exposure to the respirator user. Where
contaminant migration is possible, respirator cartridges/canisters
should be changed after every workshift where exposure occurs
unless the employer has specific objective data to the contrary
(desorption studies) showing the performance of the cartridge in
the conditions and schedule of use/non-use found in the workplace.
- Citation Guidelines. If the employer has or could have had the knowledge
available to implement change schedules and had done little or nothing to
determine accurate change schedules, (d)(3)(iii)(B) should be cited. For
citation purposes, the CSHO should document the purpose of respirator
use, make and model of respirator(s), identification and concentration of
contaminant (s), duration of use, exposure to a mixture of contaminants
and any other relevant user and workplace factors.
Medical Evaluation - 1910.134(e): Employers must provide a medical evaluation
to determine each employee's fitness to wear a respirator. The evaluation must be
provided before the initial fit-testing and before the respirator is used for the first
time. Medical evaluations consist of the administration of a medical
questionnaire, which is found in the mandatory Appendix C of the standard, or
provision of a physical examination that elicits the same information as the
questionnaire for the employee. An employer, who opts to provide physical
examinations to his or her employees, need not also administer the medical
questionnaire. These evaluations are required for all respirator users except for
employees who voluntarily use dusts masks and for those whose only respirator
would be the use of escape-only respirators. SCBA's are not considered escape-only respirators. Employees who refuse to be medically evaluated cannot be
assigned to work in areas where they are required to wear a respirator.
Where employers use a transient workforce, (e.g., temporary or construction
workers), the employer may accept the written medical recommendation of the
employee's ability to use a respirator as determined by their previous employer's
PLCHP only if the work conditions and type and weight of the respirator remains
the same and appropriate for use at their new work site. In this situation, the
employer must obtain from the previous employer a copy of the PLCHPs written
Section (e)(2)(ii) requires the employer to obtain the information required in the
questionnaire or provide the initial examination prior to performing fit testing of
employees and prior to requiring the employee to wear the respirator in the
workplace. When using the questionnaire, the employer may not change the
wording of questions in Part A , if the form is being used as the sole means to
evaluate employees. The Physician or other Licensed Health Care Professional
(PLHCP) may add questions to the questionnaire that could assist in determining
whether the employee can perform the work while wearing respiratory protection.
In order to maintain strict confidentiality of the information obtained in the
questionnaire, the employer's role is limited to distributing the blank
questionnaire to the employee for him or her to fill out, or providing it to the
PLHCP, who will administer the questionnaire to the employee. If the employer
provides the questionnaire to the employee, an addressed and postage-paid
envelope should also be provided for the employee to mail it to the PLHCP. The
questionnaire and findings may also be maintained by the employer's medical
office, if the health office is administratively separate from the employer's central
If the employer does not have or chooses not to use an in-house medical staff,
arrangements must be made for a physician or other licensed healthcare
professional (PLHCP) to perform the medical evaluations. The PLHCP may be
a physician, a registered nurse, a nurse practitioner, a physician assistant, or other
licensed health care professional acting within the scope of his or her state license,
registration, or certification. The PLCHP must be legally permitted by his or her
professional license to conduct the type of medical evaluation required by the
respirator standard. Scope of practice for non-physician PLCHPs will vary from
state to state. All PLCHPs who participate in any aspect of the medical evaluation
must be practicing within the scope of their license. For assistance in determining
which state licensing board or agency to contact to determine a PLCHP's legally
permitted scope of practice, the CSHO can contact the Directorate of Technical
Support in OSHA's National Office.
The employer must ensure that the questionnaire is administered in such a manner
that employees can understand the content and the confidentiality of the record is
maintained. Where the employee cannot understand English, the employer must
have the questionnaire translated into the employee's language either through a
translator or a translated written copy. The questionnaire has been translated into
Spanish and is available on OSHA's homepage (www.osha.gov) in the Respirator
Q & A Document. In cases where the employee cannot read, the employee can
request someone other than the employer to orally read them the questionnaire or
the PLHCP may obtain through an interview or examination the same information
requested on the medical questionnaire.
- Inspection Guidelines. The CSHO should determine if the requirements of
paragraph (e) are being met by interviewing a number of employees and
asking if they have been provided with a confidential evaluation of their
ability to wear a respirator, either by the administration of the medical
questionnaire or by physical examination. Compliance officers should
determine what mechanism the employer is using to ensure that the
employer does not see the answers to the questionnaire in order to
maintain confidentiality. The CSHO can verify that these medical
evaluations have in fact been conducted by asking the employer to see the
written recommendation of the employee's ability to use a respirator. The
employee should have also received a copy. The recommendation must
contain only the information required by subparagraph (e)(6).
The CSHO should determine what supplemental information was given to
the PLHCP by the employer. This can be done through interviewing the
PLHCP or reviewing documentation from the employer. If the employer
is relying on a medical evaluation for the employee from a previous
employer (which is allowed only when the employer uses a transient
workforce), the CSHO should determine that the work conditions and
respirator remained the same.
If the CSHO suspects the employee(s) did not receive a medical evaluation
or have not answered the questionnaire honestly (e.g., been "coached" by
the employer on how to respond to the mandatory questions from
Appendix C), then the CSHO should ask to interview the PLHCP. If this
interview still results in questions, the CSHO may wish to obtain a
Medical Access Order and review the actual medical questionnaire and/or
the physical examination records where necessitated by this paragraph of
The CSHO should also ensure that any required physical examinations
have in fact been conducted, as per (e)(3) and (e)(7). A positive answer to
any question in Part A, Section 2, Questions 1-8 (also questions 10-15 for
SCBA and full-face respirator users) requires a follow-up by the PLCHP.
The PLCHP may evaluate positive responses through consultation with the
employee to determine if the positive response is not relevant to the
employee's ability to wear a respirator or if further physical examination is
necessary (e.g., brief smoking history in the past, as compared to current
heavy smoker status).
If questions arise regarding the issue of qualifications of the PLHCP, the
CSHO should inquire with the state licensing board or the applicable
registration or certification agencies in that state to ensure that the PLCHP
is acting within the scope of his or her practice.
- Citation Guidelines: If medical evaluations are not provided, a violation
of (e)(1) exists. If the PLHCP designated by the employer is not operating
within the scope of their license or their license has expired or is invalid,
the employer should be cited under paragraph (e)(2)(i) for choosing an
- If the employer's medical evaluation does not obtain the mandatory
information required in Part A, Sections 1 and 2 of Appendix C,
then a violation of (e)(2)(ii) exists.
- If the PLHCP is not provided with the appropriate supplemental
information, a violation of (e)(5) exists.
Fit Testing-1910.134(f): Fit testing is required for all employees using negative
or positive pressure tight-fitting respirators, where such respirators are required by
OSHA or where the employer requires the use of such a respirator. A fit test is
not required for voluntary users or for escape-only respirators.
The fit test must be performed before the respirator is used in the workplace. It
must be repeated at least annually and whenever a different respirator facepiece is
used or a change in the employee's physical condition could affect respirator fit. If
the respirator subsequently becomes unacceptable (i.e., causes irritation or pain to
the employee) to the employee, the employee must be given the opportunity to
select a different respirator facepiece and be retested.
Qualitative Fit-Testing (QLFT) may be used to fit test negative pressure air-purifying respirators, if they will only be used in atmospheres less than ten times
the PEL, since existing evidence only validates the QLFT protocols listed in
Appendix A to identify respirators that achieve a fit factor of 100. For greater
concentrations, Quantitative Fit-Testing (QNFT) must be used. When
quantitative fit-testing is used, all full-facepiece respirators must meet or exceed a
fit factor of 500, while quarter - and half-mask respirators must meet or exceed
100. For all positive pressure, atmosphere-supplying respirators, either qualitative
or quantitative fit testing may be used. While atmosphere-supplying respirators
are fit-tested in the negative pressure mode, these respirators are most often used
as positive pressure respirators in the workplace. Positive pressure atmosphere-supplying respirators that pass the QLFT or QNFT fit test may be used at the
higher protection factors assigned these respirators. See Table 1 for a summary.
- Inspection Guidelines. The CSHO should determine which protocol was
used for fit testing and if all employees who are wearing tight-fitting
respirators have been fit-tested in the last twelve months for the respirator
they are wearing. Fit testing procedures should be discussed with the
program administrator. If fit testing is being performed, the CSHO should
observe the company's procedures and evaluate their adherence to the
- Where employees move from job to job within the year (e.g.,
temporary or construction workers), their fit test need not be
repeated, if the employer obtains a copy of the original fit test
record and the same respirator make, model and size is available
and appropriate for use at their new work site.
- Citation Guidelines. Fit test records should be reviewed. If no fit test
record is found it must be determined if they were not maintained
[(m)(2)(ii)] or the test was not performed [(f)(2)] and cited accordingly.
For not following prescribed protocol, cite (f)(5). Using QLFT for
negative pressure APR's used in atmospheres greater than 10 times the
PEL would be cited as (f)(6).
- If fit testing was done by a previous employer within the required
time, but no fit test record was obtained by the current employer, a
citation for (m)(2) should be issued.
- If the CSHO determines the fit testing was not appropriate for the
present respirator usage, citations for the appropriate requirements
of paragraph (f) should be issued.
Acceptable Fit-Testing Methods
|Half-Face, Negative Pressure, APR (<100 fit factor)
|Full-Face, Negative Pressure, APR (<100 fit factor)
used in atmospheres up to 10 times the PEL
|Full-Face, Negative Pressure, APR (>100 fit factor)
|Supplied-Air Respirators (SAR), or SCBA used in
Negative Pressure (Demand Mode) (>100 fit factor)
|Supplied-Air Respirators (SAR), or SCBA used in
Positive Pressure (Pressure Demand Mode)
|SCBA - Structural Fire Fighting, Positive Pressure
|SCBA/SAR - IDLH, Positive Pressure
|Loose-fitting Respirators (e.g., hoods, helmets)
Use of Respirators - 1910.134(g): Employers must establish and implement
procedures for the proper use of respirators. These procedures include prohibiting
conditions that may result in facepiece leakage, preventing employees from
removing respirators in hazardous environments, ensuring continued respirator
operation throughout the shift, and establishing procedures for the use of
respirators in IDLH atmospheres.
- Facepiece Seal Protection (g)(1):
- Inspection Guidelines - The CSHO should be alert for the presence
of facial hair (more than one day's growth) that comes between the
sealing surface of the respirator and the face as well as other
conditions that could result in facepiece seal leakage or interfere
with valve function of tight-fitting respirators, such as the presence
of facial scars, the wearing of jewelry, or the use of headgear that
projects under the facepiece seal. Corrective glasses or goggles or
other personal protective equipment (such as faceshields,
protective clothing, and helmets) must not interfere with the seal of
the facepiece to the face of the user. If employees wear other
safety equipment with their respirators, the employee must pass an
appropriate fit test while wearing the equipment to determine if it
interferes with the seal.
Employees should be observed to determine if the seal check
procedures are being performed each time the respirator is donned.
The procedure used must be one listed in Appendix B-1 or
recommended by the manufacturer if the employer demonstrates it
is as effective as those listed in Appendix B-1. Alternative seal
checks must be based on scientific studies. [The face fit is
considered satisfactory if a slight positive pressure can be built up
inside the facepiece when the exhalation valve or surface is
covered, the user exhales gently, and there is no evidence of
outward leakage at the seal. The negative check requires covering
the inlet opening or surface, inhaling gently, and having the
facepiece remain in a slightly collapsed condition with no inward
leakage of air detected.]
- Citation Guidelines - CSHO should cite (g)(1)(i)(A) when
employees' facial hair comes between the sealing surface of the
facepiece and the face or interferes with valve function;
(g)(1)(i)(B) when any other condition except for those listed in
(g)(1)(ii) interferes with the face-to-facepiece seal; (g)(1)(ii) when
the employee is wearing equipment (e.g., glasses, goggles, helmets,
etc.) that affects the face-to-facepiece seal, but was not worn
during fit testing; (g)(1)(iii) if user seal checking is not being
performed or the employer has not demonstrated that the
procedures used are those listed in or as effective as those in
Appendix B-1. This paragraph should not be cited in voluntary use
situations, if overexposures are not found.
- Continuing Respirator Effectiveness (g)(2):
- Inspection Guidelines - The employer is required, by paragraph
(c)(1)(ix), to address in its written program the type of regular
surveillance of the workplace necessary to evaluate the
effectiveness of the respirator program. The surveillance
procedures may include continuous or periodic monitoring, on-site
observations, and notation of problems. The intensity of the
surveillance should be tailored to the hazards present in the
workplace. Highly hazardous substances that pose acute
respiratory hazards merit a higher degree of surveillance.
Section (g)(2)(ii) requires that employers ensure that employees
leave the respirator-use area to correct certain problems associated
with respirator use, including the detection of contaminant
breakthrough, and to replace the respirator or its filters or
cartridges. Employees should be interviewed [e.g., What do you
do if you notice a leak? ] to determine whether there are any
policies or actions which would prohibit or impede them from
leaving the area should they have significant problems with their
respirators or which impede the replacing of filters or cartridges.
Paragraph (g)(2)(iii) is designed to prevent employees from
reentering a workplace after leaving because of a significant
respirator failure without first assuring the proper functioning of
- Citation Guidelines - The CSHO should cite (c)(1)(ix) if the
written procedures are inadequate to identify problems or changes;
(g)(2)(i) if the routine surveillance of the work conditions is not
performed; the appropriate section of (g)(2)(ii)(A), (B) or (C), if
prohibitions to leaving an area are identified or if employees fail to
leave the area when the standard requires them to do so; (g)(2)(iii)
if employees are allowed back into an area before the employer has
replaced or repaired the respirator.
- Procedures for IDLH Atmospheres (g)(3):
- Inspection Guidelines - The employer must be prepared for
emergency rescue or respirator failure whenever employee(s) are
working inside of an IDLH atmosphere. At least one person must
be on standby outside the IDLH atmosphere and maintain
communication with the person inside at all times. The standby
person(s) must be trained and equipped to provide an effective
emergency rescue. Except in emergency situations, environments
containing IDLH atmospheres are frequently well enough
characterized and controlled that a single standby person can
monitor the status of multiple entrants. The need for multiple
standbys should be evaluated in context with the ability of the
standby personnel to meet all their standby duties, including their
ability to monitor the worker(s) in the area and their ability to
initiate effective rescue procedures. Planning is critical for
effective response to emergency situations through the
development of specific emergency procedures. These procedures
should address how the employer will be notified when standby
person(s) outside of the IDLH atmosphere enter the IDLH
atmosphere to provide emergency rescue and what actions will be
taken or assistance provided by the employer. Emergency
procedures must be developed and included in the employer's
written respirator program.
For work performed outside of visual contact, voice, radio or signal
line are permitted. CSHOs should specifically review protocols for
communication, rescue, and notification for employees entering
IDLH atmospheres. Communication protocols must be established
that allow the standby person to monitor entrant status and enable
the standby(s) to alert entrants of the need to evacuate the area. It
is not sufficient to rely on the employees in the IDLH area to call
for help when needed.
Paragraph (g)(3) does not apply to IDLH atmospheres in a permit-required confined space (PRCS) or to environments in which there
is an uncontrolled release of a hazardous substance. IDLH
atmospheres in a PRCS are specifically addressed in the PRCS
standard, 1910.146, and its accompanying directive, CPL 2.100.
Environments in which there is an emergency release of a
hazardous substance are addressed in paragraph (q) of OSHA's
HAZWOPER standard, 1910.120 or 1926.65, and its
accompanying directive, CPL 2-2.59A. In facilities where an
uncontrolled release of a hazardous substance could create an
emergency IDLH atmosphere, employers must follow the
requirements of HAZWOPER paragraph (q). These situations
must be addressed in the employer's emergency response plan and
the response procedures must be consistent with that standard.
- Citation Guidelines - If an IDLH area meets the definition of a
confined space, then the requirements of 1910.146 would apply
and the appropriate section of 1910.146 should be cited where
deficiencies are noted. If the IDLH is a result of an uncontrolled
release of a hazardous substance, then the appropriate section of
the HAZWOPER standard, 1910.120 should be cited. Otherwise,
violations should be cited under the applicable subparagraph of
(g)(3). If adequate communication is not maintained between the
entrants and the standby personnel located outside the IDLH area,
(g)(3)(ii) should be cited.
- Procedures for Interior Structural Firefighting, 1910.134(g)(4): This
section applies to private sector workers engaged in firefighting, including
those working in industrial fire brigades and private incorporated fire
companies, and to Federal employees under Section 19 of the Act. These
or equivalent provisions apply to State and local government firefighters
only in the 25 States that operate OSHA-approved State plans which are
required to adopt an identical or "at least as effective" standard and extend
its coverage to public employees. (Coverage of volunteer firefighters in
these States varies by State and depends on State law.) The following
guidance will have applicability primarily in the State Plan States and in
responding to general inquiries.
The provision is limited to workers performing an interior attack on an
interior structural fire. In Subpart L ( 1910.155), OSHA has defined
"interior structural fire fighting" to mean: "the physical activity of fire
suppression, rescue or both, inside of buildings or enclosed structures
which are beyond the incipient stage." This is firefighting to control or
extinguish a fire in an advanced stage of burning, producing large amounts
of smoke, heat and toxic products of combustion. Firefighter exposure
during this activity is extremely hazardous. The atmosphere is considered
IDLH and the use of Self Contained Breathing Apparatus is required. By
contrast, incipient stage fire fighting involves the control or
extinguishment of a fire in the initial or beginning stage, using portable
fire extinguishers or small hose lines without the need for personal
protective equipment. It is the incident commander's responsibility, based
on training and experience, to judge whether a fire is an interior structural
fire, and how it will be attacked.
OSHA has discussed this provision in a number of documents.
- Summarized below are some key points from those documents.
- There must always be at least two firefighters stationed outside
during interior structural firefighting, and they must be trained,
equipped and prepared to enter if necessary to rescue the
firefighters inside. However, the incident commander has the
responsibility and flexibility to determine when more than two
outside firefighters are necessary given the circumstances of the
fire. The two-in/two-out rule does not require an arithmetic
progression for every firefighter inside, i.e. the rule should not be
interpreted as 4-in-4-out, 8-in-8-out, etc.
- It is important that the CSHO recognize that life-saving activities
in interior structural fire fighting are not precluded by the standard.
There is an explicit exemption in the standard that if life is in
jeopardy, firefighters have the discretion to perform the rescue, and
the "two-in/two-out" requirement is waived. There is no violation
of the standard under such life-saving rescue circumstances.
- The two-in/two-out provision is not intended as a staffing
requirement. It does not require fire departments to hire additional
firefighters; it does not require four-person fire companies; it does
not require four persons on a fire truck. Most fire departments
have more than four firefighters and can assemble the numbers
required on the scene by waiting for others to arrive. During this
time the fire may be attacked only from the outside, sizing-up
operations may occur, and emergency rescue necessary to save
lives may take place as discussed above. The "two-in/two-out"
rule is a worker safety practice requirement, not a staffing
- The standard allows one of the standby firefighters to have other
duties such as serving as the incident commander, safety officer, or
operator of fire apparatus. However, one of the outside firefighters
must actively monitor the status of the inside firefighters and may
not be assigned additional duties. The second outside firefighter
may be involved in a wide variety of activities. Both of the outside
personnel must be able to provide support and assistance to the two
interior firefighters; any assignment of additional duties for one of
the outside firefighters must be weighed against the potential for
interference with this requirement. Proper assignment of
firefighting activities at an interior structural fire must be
determined on a case-by-case basis and is dependent on the
existing firefighting situation. Compliance will always depend on
consideration of all the worksite variables and conditions, and the
judgement of the incident commander is critical in meeting this
- The two firefighters (buddies) entering an IDLH atmosphere to
perform interior structural firefighting must maintain visual or
voice communication at all times. Electronic methods of
communication such as the use of radios shall not be substituted
for direct visual contact between the team members in the danger
area. However, reliable electronic communication devices are not
prohibited and certainly have value in augmenting communication
and may be used to communicate between inside team members
and outside standby personnel.
- For further explanation refer to the preamble of the Respiratory
Protection standard (vol. 63, No. 5, 1245-1248) and the Respirator
Question and Answer document (August 3, 1998). Both
documents can be found at OSHA's Homepage - www.osha.gov.
Inspection Guidelines - Section (g)(4) includes the requirements of
(g)(3). The first and critical step in evaluating an employers
response using the two-in/two-out rule is to determine if there was
interior structural fire fighting activity. This determination will
require consideration of the factors existing at the time of the
firefighting action and the basis for the Incident Commander's
finding. CSHO should seek expert opinion from other authorities
such as a state or local fire Marshall or other fire protection
professionals and should thoroughly interview affected personnel
to document the violation.
Citation Guidelines - If the CSHO's investigation reveals that the
two-in/two-out rule was not followed during the interior attack of
an interior structural fire and there was no reasonable expectation
that someone was in jeopardy inside the building, the CSHO
should cite (g)(4)(i) or (g)(4)(ii) as a serious violation. If adequate
communication is not maintained between the team inside and the
standby personnel located outside the IDLH, (g)(3)(ii) should be
Maintenance and Care of Respirators - 1910.134 (h)(1): Respirators must be
cleaned and disinfected as often as necessary to keep them in a sanitary condition.
They must be properly stored to prevent damage and contamination, inspected
regularly and repaired as necessary.
- Inspection Guidelines. To ensure that respirators are clean and in good
working order, the employer can have respirators cleaned and repaired in a
centralized operation where respirators are passed out to employees OR
the employer may require the respirator user to perform all cleaning and
respirator maintenance functions. The CSHO should verify that the
procedures in the mandatory Appendix B-2 or an equivalent method
specified by the manufacturer are being followed and are performed by
employees who are adequately trained in the proper respirator care
procedures. Respirators issued to more than one employee must be
cleaned and disinfected before being worn by another user. The use of
individually-wrapped cleaning towelettes may be used as an interim
method in the cleaning schedule for individually assigned respirators, but
they must not be the only method in place. During fit-testing, towelettes
may also be used between employees being tested, however these
respirators must be thoroughly cleaned at the end of each day, using the
procedures in Appendix B-2.
The employer must ensure that respirators are inspected before each use
and during cleaning. The CSHO should observe the condition of the
respirators being used in the workplace. One or more respirators should
be checked before employees enter, or as they leave the respirator area. A
minimally acceptable inspection procedure for ALL respirators includes a
check of respirator function, tightness of connections and the condition of
the various parts, including but not limited to, the face piece, head straps,
valves, connecting tube, and cartridges, canisters, or filters, and a check of
the respirator's elastomer parts for pliability and signs of deterioration.
SCBA's also require an inspection of the air and oxygen cylinders to
assure that the cylinder pressure is maintained at 90% of the
manufacturer's recommended pressure level and that the regulator and low
pressure warning devices function properly. To assure that both the
regulator and low pressure warning devices function properly the warning
device must be activated and heard by the person performing the
inspection. The CSHO should interview the individual who is inspecting
SCBA's to determine if these regulator and low pressure warning devices
are being activated according to the respirator manufacturer's instructions.
The CSHO should also observe how respirators are stored in the
workplace. Respirators must be properly stored to protect them against
physical damage, contamination, excessive moisture, extreme
temperatures, sunlight, and damaging chemicals. Emergency use
respirators must be stored in compartments OR in covers, both of which
must be clearly marked as containing the emergency respirators.
- Respirators That Are Available for Emergency Use: An inspection must be
conducted monthly for all emergency use respirators. The employer must
certify in writing that an inspection was performed. The certification must
include the name (or signature) of the person who made the inspection, the
findings of the inspection, any remedial action, and a serial number or
other means of identifying the inspected respirator. The respirator must
also be checked before and after each use.
- Emergency escape-only respirators carried by employees must be
inspected before being taken into the workplace for potential use.
- Section (h)(4) Repairs: Defective respirators must be removed from
service. A respirator is defective if one or more of its components is
missing, damaged, or visibly deteriorated. The employer must develop
some means to ensure defective respirators are not used in the workplace.
The employer can comply by placing an "out of service" tag on the
respirator to help ensure that the defective respirator is not inadvertently
used or by removing the respirator from the work area. An "appropriately
trained" person must be responsible for performing repairs or adjustments
- Inspection Guidelines. The CSHO must interview the employee(s) at the
worksite who repair respirators, and determine what training they have
received. An appropriately trained person is an individual who has
received training from the manufacturer or otherwise has demonstrated
that he or she has the skills to return the respirator to its original state of
effectiveness. The training is performance-oriented, so it is acceptable for
the employee to have acquired the skills through practice rather than by
attending a formal training course. Repairs to reducing and admission
valves, regulators, and alarms must be done by a technician trained by the
- Only the respirator manufacturer's NIOSH-approved parts that are
designed for the particular respirator being repaired can be used to
repair a respirator.
- CSHOs should cite for defective respirators not effectively being
removed from service.
Breathing Air Quality and Use 1910.134 (i): Compressed breathing air must
meet at least the requirements for Grade D breathing air. The ANSI/CGA G.7-1 -
1989 specifies the contents of Grade D breathing air as: oxygen (volume/volume)
of 19.5 to 23.5 %; hydrocarbon (condensed) of 5 mg/m³ of air or less; carbon
monoxide of 10 ppm or less; carbon dioxide of 1,000 ppm or less; and the lack of
a noticeable odor.
- Inspection Guidelines. If compressors are used to supply breathing air, the
CSHO should note the location of the compressor intake and ensure it is
located in an area uncontaminated by either combustion exhaust gases
produced by vehicles or the compressor itself (if applicable), or by other
exhaust gases ventilated from plant processes. A tag containing the
signature of the person authorized by the employer to change the in-line
sorbent beds and filters and the date of the latest change must be
maintained at the compressor.
For air compressors that are not oil lubricated, a CO alarm is not required.
However, the employer is required to ensure that carbon monoxide levels
in the breathing air do not exceed 10 ppm. Some practical methods for
ensuring that the carbon monoxide level does not exceed 10 ppm include;
placing the air intake for the compressor in an area that the employer
knows is free from contaminants; frequent or continuous monitoring of the
breathing air supply; the use of carbon monoxide filters; or the use of a
high temperature alarm or shut off devices.
If the employer is using an oil-lubricated air compressor, it must have
either a carbon monoxide alarm, high temperature alarm, or both. If only a
high temperature alarm is used, then the breathing air must be tested for
the presence of carbon monoxide at intervals sufficient to ensure that
carbon monoxide levels do not exceed 10 ppm. The alarm must be able to
alert the users or another employee who knows to alert any respirator
If cylinders are used they must be marked with a NIOSH approval label.
Cylinders of purchased breathing air must have a certificate of analysis
from the supplier that the breathing air meets the required Grade D air and
If compressed or liquid oxygen is used, it must meet the specifications for
breathing oxygen outlined by the United States Pharmacopoeia (USP).
Compressed oxygen must not be used for any respirators that previously
used compressed air.
All breathing air couplings must be incompatible with those of non-respirable air or other gases used at the site to prevent inadvertent
servicing of air line respirators with non-respirable gases or oxygen.
Identification of Filters, Cartridges, and Canisters 1910.134 (j): The
employer must ensure that all canisters and filters are properly labeled and color
coded with the NIOSH approval label and that the label is not removed, obscured,
or defaced while in service. This requirement enables the employee using the
respirator to check and confirm that the respirator has the appropriate filters
before the respirator is used and also allows fellow employees, supervisors, and
the respirator program administrator to readily determine that the employee is
using the appropriate filters.
- Inspection Guidelines. The CSHO should verify that properly labeled
filters and canisters are being used, and that the labels remain legible.
- Citation Guidelines. Date and time labels applied to the filters/cartridges
should not be considered violations, but the employer must obscure as
little as possible of the label to allow ready identification.
Training and Information 1910.134 (k): The employer is required to provide
effective training to employees who wear respirators. Training must be provided
prior to an employee's use of a respirator in the workplace and must be
comprehensive and understandable. Training must recur annually, and more often
if retraining appears necessary to ensure safe use. The employer must ensure that
each employee can demonstrate a knowledge of all items in (k)(1)(i) thru (vii).
Pre-testing may be used as a training aid to determine extent of retraining
- Inspection Guidelines. The effectiveness of the training program can be
evaluated by determining how well employees understand how to use their
respirators. If respirators are improperly worn, missing parts, dirty,
improperly stored, or the wrong cartridges are being used, the compliance
officer should interview the employee for knowledge of the respirator
Employees should be interviewed to determine if they have received the
required training and the extent of that training. If the CSHO detects a
trend in employee responses that indicate training is not being conducted,
or is conducted in a cursory manner, a closer review of the training
program is necessary.
Employees who voluntarily wear respirators must, at least, be given the
information in Appendix D.
- Citation Guidelines. Lack of training should be cited. Citations for
insufficient training should usually be based on several interviews that
reveal a lack of understanding of the respirator program. Lack of
knowledge about the hazards for which the respirator is being used, could
also indicate a deficiency in the employer's Hazard Communication
Program Evaluation 1910.134(l): The employer must conduct evaluations of the
workplace to ensure the written respiratory protection program is properly
implemented. The employer must observe and consult employees to determine if
they have any problems with the program and ensure that the respirators are used
- Inspection Guidelines. The CSHO should evaluate how well the written
respiratory program is being implemented in the workplace. Observed
deficiencies in the program and evaluation procedures should be discussed
with the program administrator to determine what previous efforts she or
he may have made to evaluate how well their program was working.
Deficiencies should also be discussed with employees to determine how
long any deficiency has existed and what requests or complaints about the
respirator program if any they have made to the program administrator. If
the program administrator keeps a written assessment, implemented
changes may be considered as efforts toward improvement. Recent
changes in the workplace such as new processes should have been
evaluated for necessary respiratory program changes.
- Citation Guidelines. Multiple deficiencies found during the inspection,
especially long term deficiencies, could indicate inadequate program
Recordkeeping - 1910.134(m): For every employee required to wear a respirator,
the employer must establish and retain medical evaluations and fit-testing records.
Medical evaluation records must also be retained for employees who wear
elastomeric facepiece respirators. An employee's medical evaluation records
must be made available to the employee and to OSHA in accordance with
1910.1020. The employer must also make an employee's fit-testing records
available to that employee and to OSHA. The standard does not intend for the
employer to make an employee's medical or fit-testing records available to any
other individual unless that individual is the employee's "designated
representative" as defined in 1910.1020(c)(3).
- Inspection Guidelines. Even though the employer must ensure the
medical evaluations are maintained, the actual medical evaluations will
normally be maintained with the PLHCP, not the employer. Alternatively,
the company nurse or doctor may maintain these files, but only medical
confidentiality is maintained. The employer must retain a record of the
medical evaluation which includes the PLHCP's written recommendation.
If an employee states she or he has not had a medical evaluation, the
CSHO should check if a medical evaluation record is on file.
Fit test records must be kept until the next fit test is administered. Each fit
test record must contain the employee identification, type of fit test, date
last tested, the results of the test, and the make, model and size of the
respirator tested. The CSHO should review these records to verify that fit-testing is being done annually and confirm that the fit-tested respirators are
the same models and sizes as those observed in the workplace.
The CSHO should also check on the availability of the written program.
- Citation Guidelines. If a medical evaluation record cannot be found, it
must be determined whether the record was not maintained or the
evaluation was not performed. If not maintained, (m)(1) would normally
be cited. If no record can be found and the employee confirms an
evaluation was not performed, then (e)(1) would be cited.
Lack of a fit test record or lack of information on a fit test record would be
cited under (m)(2). If an employee is wearing a respirator different from
that found in his fit test records then (f)(2) should be cited. Improper fit
testing procedures would similarly be cited under the appropriate
subparagraph in (f).
Dates 1910.134 (n): The final standard became effective April 8, 1998. By
September 8, 1998, the employer must have evaluated the workplace to determine
if respirator use is required. Compliance with all provisions is required no later
than October 5, 1998.
Appendices: All appendices are mandatory.
- Appendix A details fit testing protocols [see paragraph (f)(5)].
- Appendix B-1 details User Seal Check Procedures [see paragraph
- Appendix B-2 details Respirator Cleaning Procedures [see paragraph
- Appendix C is the OSHA Respirator Medical Evaluation Questionnaire
[see paragraph (e)(2)].
- Appendix D is Information for Employees Using Respirators When Not
Required Under the Standard. This appendix must be provided to all
employees who voluntarily use respirators. [see paragraph (c)(2), (k)(6)]
Interface with Other Standards.
- PEL Overexposures. Overexposures to Permissible Exposure Limits will usually
be linked to compliance with the respirator standard. Most of these PEL's are
listed in Tables Z1- Z3 in 1910.1000 and Appendix A in 1926.55.
- Standards Regulating Toxic Substance Exposure. A number of industry-specific
standards and substance-specific standards regulating exposure to toxic substances
have been affected by the new respirator revisions. Many paragraphs from these
standards that addressed respirator use, selection, and fit testing were deleted and
now refer to the provisions in 1910.134. Violations will now be cited under the
appropriate paragraphs of 1910.134.
- Medical Records Access. The Access to Employee Exposure and Medical
Records Standard (29 CFR 1910.1020 ) requires that employees have access to all
medical and exposure records generated under this standard.
Classification and Grouping of Violations. The procedures in chapter III of the Field
Inspection Reference Manual (FIRM) should be followed. The FIRM describes the
circumstances, such as proposing Willful or Criminal violations, where the CSHO or AD
may need to consult the Region or the Solicitor's office. The Citation Policy for
Paperwork and Written Program Requirement Violations, CPL 2.111 , should be
reviewed for guidance when citing the written program.
Authorization to Review Limited Medical Information. Appropriately qualified
compliance personnel are authorized to review medical records and medical opinions
pertinent to compliance with the Respiratory Protection Standard. There are four
directives that address the limitations and procedures which are to be followed. They are
OSHA Instruction(s) CPL 2-2.30 (Authorization to Review Medical Opinions); CPL
2-2.32 (Access to Biological Monitoring Results); CPL 2-2.33 (Written Access Orders);
and CPL 2-2.46 (Authorization to Review Specific Medical Records). In general, each of
these instructions defines "qualified compliance personnel" as a field-qualified Industrial
Hygienist who is at the journeyman level or a professional with specific training or
experience in medical disciplines. When inspections are conducted by teams, the Team
leader should ensure that a team member is so qualified.
Training for OSHA Personnel.
- CSHO Experience. For all inspections on a site where respirators are used and the
exposures are expected to be above the 8-hour TWA or the STEL, only
experienced and properly trained CSHOs shall perform the on-site evaluations.
CSHOs are expected to be knowledgeable of the:
- Potential hazards which may be encountered at the site,
- Contents of the Respiratory Protection standard,
- Appropriate PPE to be worn. Each CSHO who will be expected to use
PPE must be trained in the proper care, use, and limitations of the PPE.
Instructions for the use of respiratory protection by CSHO's are contained
in OSHA Instruction CPL 2-2.54. The CSHO should closely review and
examine all the data available on site concerning the exposures or potential
exposures in this particular location. If the employer cannot supply
adequate data to support the selection of the types of respirators that are in
use, the CSHO must not enter the areas where respirators are in use. If the
hazard determination performed by the employer has been completed in
accordance with the standard, the CSHO must don the appropriate
respirator required in that work-site prior to the walkaround in areas where
respirators are required.
- Emergency Procedures. For all inspections on a site where OSHA personnel are
investigating an emergency that involves hazardous substances, the CSHO must
be knowledgeable of:
- Appropriate training required by 29 CFR 1910.120, or any applicable
annual refresher training;
- The ARA for Technical Support must be consulted for assistance in
determining the appropriateness of SCBA use by CSHOs.
Medical Examinations for OSHA Personnel.
- Regional Administrators and Area Directors are responsible for implementing the
CSHO Medical Examination program in accordance with OSHA Instruction,
PER 8-2.5. This medical evaluation is more stringent than what is required by the
revised Respiratory Protection Standard.
- Many of the hazards that CSHO's may encounter are already regulated by the
medical surveillance requirements in other OSHA standards. CSHOs who are
required to wear any respiratory protection and Level A or B PPE must be
medically cleared via the CSHO Physical Examination procedures.
Protection of OSHA Personnel. The paramount concern addressed in this section is the
protection of the CSHO. Compliance Officers are reminded about Agency policy that
requires that appropriate personal protective equipment be used when exposed to a
hazard. When and if a CSHO is not adequately protected by the use of appropriate PPE,
the CSHO should stay out of the contaminated area to avoid being overexposed to any
- Personal Protective Equipment (PPE).
- Regional Administrators and Area Directors must ensure that appropriate
PPE is available for the CSHO.
- Respirators must be selected in accordance with 1910.134.
- Eye and face protection must meet the requirements of 29 CFR
CHANGE SCHEDULES GUIDE - A LISTING OF METHODS
A brief description of some currently available approaches or methods for respirator cartridge
change schedules is presented below. The CSHO should assess the "Good Faith" efforts of the
employer on a case by case basis and contact appropriate regional OR National office staff for
guidance, as necessary. This is not intended to be an exhaustive list, but a summary of some
reasonable methods that an employer may take in creating a change schedule. No matter which
method is used, the employer must maintain any data used in making their decision as part of
Manufacturers Objective Data: Respirator cartridge model-specific objective data that is
available from the manufacturer or through a distributor may be used to establish change
schedules. Objective data may be presented in tabular or graphical format or simply provided
verbally over a manufacturer's telephone help line. Some manufacturers have developed
elaborate computer programs available on the Internet that provide the necessary objective data
to the user.
Experimental Methods: Experimental breakthrough-time data from a laboratory based on
worst case testing of simulated workplace conditions. This method can provide fairly accurate
service life data compared to other available methods.
Mathematical Predictive Modeling: One tool that has demonstrated value is the use of
mathematical modeling based on predictive equations. These models are typically complex and
require considerable expertise to apply. They also require some proprietary information from the
respirator manufacturer. OSHA fully supports the further development and validation of these
models. The agency believes that respirator manufacturers may be in the best position to apply
them to their products.
Analogous Chemical Structures: Employer would rely on service life values from other
chemicals having analogous chemical structure to the contaminant under evaluation for
breakthrough. Or in some cases a chemical with known migration may reasonably be anticipated
to act as a surrogate for a similar chemical that would have less rapid migration (e.g., an
employer could assume that a heavier, less volatile compound than another in the same chemical
series that had been tested for breakthrough would breakthrough no faster than the latter
compound, such as benzene versus toluene.) The use of this method requires a substantial
amount of judgement and assumption of similar chemical properties. The use of analogous
chemical structures should be infallible as long as objective data or information for lower
molecular weight compounds is used to predict the breakthrough times for higher molecular
weight analogues containing only additional methyl or phenyl groups. Data from higher
molecular weight groups should not be used to predict the behavior of analogous substances with
lower molecular weight. This approach relies heavily on experimental data and expert analysis.
This method may be less accurate than others and should be used only when better information is
Workplace Simulations: Unvalidated methods exist or are under development where the
respirator cartridge is tested in the workplace in "real time" and under actual conditions of use.
Simple designs have been informally described to the agency. Workplace air during
representative conditions is drawn over the cartridge at a rate approximating normal breathing at
a higher work rate. An air sampling/analytic device would be placed on the other side of the
filter to measure the time of breakthrough. Employers could incorporate this type of testing into
their air monitoring program using sampling strategies established in their workplace. In
theory, these approaches should be an accurate method for determining change schedules and
could accommodate fluctuating conditions of humidity, concentration, etc., to allow less
conservative schedules that utilize a larger fraction of the true service life.
Rules of Thumb: Generalized rules or guidance can be generated from experimental work.
Presented below is a rule of thumb for estimating organic vapor service life found in Chapter 36
of the American Industrial Hygiene Association publication
"The Occupational Environment Evaluation and Control".
*If a chemical's boiling point is >70 C and the concentration is less than 200 ppm you
can expect a service life of 8 hours at a normal work rate.
Note: This first rule of thumb needs further review.
* Service life is inversely proportional to work rate.
* Reducing concentration by a factor of ten will increase service life by a factor of five.
* Humidity above 85% will reduce service life by 50%.
These generalizations should only be used in concert with one of the other methods of predicting
service life for specific contaminants.