A compliant respiratory protection program requires a written program, exposure-based selection, medical evaluation, fit testing, training and a defensible cartridge change schedule. Even voluntary use carries obligations.
Respirator selection must follow from a known exposure and an assigned protection factor sufficient to bring it below the limit. Choosing a respirator because it is what the supplier carries is not a selection process.
Employees must be medically evaluated before fit testing and use, by a physician or other licensed health care professional. Breathing through a respirator is a cardiopulmonary load, and this step is not optional.
Tight-fitting respirators require fit testing before initial use and at least annually, with the same make, model and size the employee will wear. Testing on a different model than issued invalidates it.
Any facial hair that interferes with the sealing surface defeats a tight-fitting respirator entirely. Programs that permit it are not protecting anyone, and the exposure continues while everyone believes it is controlled.
Change-out must be based on a defensible estimate of service life, not on the employee noticing breakthrough. Relying on odor as a warning property is only valid for a limited set of substances.
When employees voluntarily use respirators, the employer still has obligations including providing specified information, and for anything beyond a filtering facepiece, medical evaluation and program elements apply.
Selection follows from the hazard assessment: what the exposure is, what protection factor is required to bring it below the limit, and whether a tight-fitting respirator is even appropriate for the employees who will wear it.
Then the mechanics — medical evaluation coordination, fit testing with the issued make and model, training with demonstrated understanding, a cartridge change schedule with documented basis, storage and maintenance procedures, and the annual program evaluation the standard requires.
For voluntary use of filtering facepieces, employers must provide specified information to users, and certain program elements are reduced. For voluntary use of any other respirator type, medical evaluation and additional program elements apply. Get the distinction right rather than assuming voluntary means exempt.
Before initial use, whenever a different respirator facepiece is used, when physical changes could affect fit, and at least annually thereafter.
Only where engineering controls are not feasible or while they are being implemented. Respirators as a permanent substitute for feasible engineering controls is a citation, and it is the least reliable point in the hierarchy.
Facial hair crossing the sealing surface makes a tight-fitting respirator ineffective. The options are shaving, a loose-fitting powered air-purifying respirator, or removing the exposure. There is no fourth option.
From a service life estimate based on the contaminant, concentration, humidity, temperature and work rate — commonly using published models or manufacturer tools — and documented. Relying on employees smelling breakthrough is valid only for substances with adequate warning properties.
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