(OSHA) Respiratory Protection Standard and Environmental Compliance

Compliance Checklist for Respirator Programs

The Occupational Safety and Health Administration (OSHA) has a respiratory protection standard that is designed to limit employee exposure to airborne contaminates. The respiratory protection standard, 29 CFR 1910.134, was established to limit and control occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays or vapors. The primary objective is to prevent atmospheric contamination by accepting engineering controls, including but not limited to enclosure of the operation, ventilation and substitution of less toxic materials. When effective engineering controls are not feasible or while they are being instituted, appropriate respirators shall be used. It is the employers’ responsibility to provide respiratory protection that is applicable and suitable for the purpose intended to all affected employees. The employer is also responsible for the establishment and maintenance of a respiratory protection program which shall meet all the requirements of the 1910.134 standard.

Does your facility have the potential to expose employees to contaminated air? Do you have respiratory protection requirements in place for employees? Answer the questions below to see how your facility measures up to the respiratory protection standard.

Answer Yes or No to determine your compliance with OSHA’s respiratory protection standard, 1910.134. If you provide respirators to employees and you answer No to any of the following items in the checklist, you are not in compliance with the OSHA standard and are subject to financial penalties. (If your personnel voluntarily wear a respirator, portions of the 1910.134 standard still apply to your facility.)

1. Does your facility have a written respiratory protection program?

2. Does your facility provide the respiratory protection, training and medical evaluation at no cost to the employee?

3. Are the respirators that you use selected based on an evaluation of respiratory hazards in your workplace?

4. If you have an Immediately Dangerous to Life or Health (IDLH) atmosphere, do your respirators provide appropriate protection?

5. Have your personnel been medically approved to wear a respirator?

6. Have your personnel been fit tested?

7. Does your facility have procedures that are implemented to prevent facepiece seal leakage?

8. Do you evaluate work areas to detect changes in working conditions or degrees of employee exposure to stress that may affect respirator effectiveness?

9. Does your facility have written procedures for interior structural firefighting?

10. Does your facility provide the means for cleaning and disinfecting respirators to employees?

11. Does your facility provide the means for respirator storage and inspections?

12. Do you provide annual respiratory training to all affected employees?

13. Are all of your respirator cartridges certified and labeled by NIOSH?

14. Does your respiratory training program test your employees’ knowledge of proper respirator fit, use and maintenance?

15. Do you conduct periodic workplace evaluations to determine if your written respiratory protection program is being properly implemented?

16. Has your facility established and retained written information regarding medical evaluations and fit testing?

There are many aspects and requirements associated with OSHA’s respiratory protection standard. If you feel your facility may not meet the 1910.134 standard, CTI can help.


Published by Stephen Kovatch

Senior Client Manager  Stephen J. Kovatch focuses on assisting clients in establishing corporate regulatory compliance programs in the areas of air, water, and waste management. Mr. Kovatch also provides direction to industrial facility owners who are active in the transaction of contaminated property by defining objectives, coordinating soil and water sampling protocols, risk assessment, and remedial / cleanup activities. He frequently represents clients in property sales negotiations and regulatory agency and insurance proceedings.

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