The
Occupational Safety and Health Administration (OSHA) issued directive number CPL 02-00-158 "Inspection Procedures for the Respiratory Protection Standard". This new directive gives instructions to OSHA compliance safety officers and area directors on interpretations and enforcement policies for enforcing the
respirator standard 1910.134. This directive cancels and supersedes the previous directive CPL 02-00-120 dated September 25, 1998. Directives are used by OSHA to ensure the standards are enforced uniformly across the country. These directives are useful resources in that they inform the industry, and employers how OSHA intends on enforcing the respirator standard.
Changes to this revision include: updated definitions section to include definitions for assigned protection factors (APF) and maximum use concentrations (MUC); greater clarification on voluntary respirator use, and a better explanation of a compliant respirator program and provides additional acceptable methods to assess respiratory hazards; updates the directive with information related to the revised
Hazard Communication standard (1910.1200); and provides guidance on evaluating the need for respiratory protection for chemicals used in workplaces by referring to employer's Hazard Communication program wherein chemical manufacturers communicated the need for respiratory protection.
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According to this directive if employers require employees to wear respirators for the protection against TB they must be in compliance with the respirator standard 1910.134. Probably the most interesting portions of the directive are the modifications to voluntary use of respirators. According to the directive, it was the intent of the standard that the employer would not be required to incur any costs associated with voluntary use of filtering facepiece respirators (
dust masks) other than providing a copy of Appendix D of the standard to each user. OSHA is concerned that voluntary use may cause an employee's health being jeopardized by the wearing of a respirator, or the wearing of a dirty respirator that can cause dermatitis or ingestion of a
hazardous chemical, and the sharing of a respirator that leads to transmittal of disease.
Voluntary use of filtering facepiece respirators is one of the most misunderstood sections of the respirator standard. Some points from the directive:
NIOSH-approved filtering facepieces are strongly recommended but are not required; voluntary use does not require the employer to have a written program; and merely posting Appendix D is not considered adequate.
The directive is a useful resource to give employers an indication of how OSHA will enforce the respirator standard and it is a useful tool to help avoid citations or to fight violations.
