Lab Safety

Respiratory Protection Program

GVSU has established the following policy to ensure that employees and students are protected from adverse exposures to respiratory hazards.  The University is committed to maintaining engineering controls that provide an indoor atmosphere free of harmful chemical, physical and biological agents (see GVSU's Lab Ventilation Guidance).  This policy will apply in situations where those controls are not sufficient and other means of respiratory protection are required.

This program, training, recordkeeping will be administered by the Lab Safety Manager/Chemical Hygiene Officer.

A. SITUATIONS REQUIRING THE USE OF RESPIRATORS.

Respirators are required in any situation where the potential for exposure to a particular airborne contaminant exceeds occupational exposure limits or a hazard assessment determines one to be necessary. .

No employee may be exposed to any air contaminant above the levels established by Occupational Safety and Health Administration (OSHA).  Material Safety Data Sheets (MSDS) or other credible information sources shall be used to ensure compliance.  Faculty and Staff may not require that a student or employee use a respirator in situations other than those identified in this policy without prior approval of University health and safety staff, who will provide specific guidance.  However, voluntary use dust masks is not discouraged (see “dust mask” section below)

This policy covers only the use of face-mounted respirators.   Consult the health and safety staff for information on belt-mounted, self-contained, and remote-source respirators and their use.

The University recognizes the following situations when respirator use is required:

  • Air monitoring has identified that respiratory hazards are present.
  • A hazard assessment identifies that there is a reasonable expectation that an individual could be exposed to respiratory hazards.
  • Employees working in areas where contaminant levels may become unsafe without warning, such as emergency response.
  • The MSDS or chemical label requires the use of a respirator.
  • Areas where there is a significant risk that biological agents become aerosolized.
  • Spraying of pesticides in the Padnos Hall Greenhouse.

B. RESPIRATORY PROTECTION FOR EMPLOYEES.

Before any employee may begin a job that requires respirator use, the following items must be completed successfully (in the order listed below).

Step 1. Evaluation by a licensed physician 

A medical evaluation is required for each employee who is required to wear a respirator, regardless of the duration and frequency of respirator use.  The medical evaluation must be conducted by a licensed physician and completed before respirator fit testing and initial respirator use.   The medical evaluation is to be done during the employee's work day.

The medical evaluation can be accomplished in either of the following two ways:

Medical Questionnaire.  In some situations the physician may only need to review a medical questionnaire without needing to conduct a physical examination.  OSHA’s Respirator Medical Evaluation Questionnaire can be completed by the employee and then reviewed by a physician who determines the employee's fitness to wear a respirator.  The physician may request an office visit for a physical examination for any reason if he or she feels it is appropriate.   The following information must be submitted to the physician:

- The completed Respirator Medical Evaluation Questionnaire.
- A MSDS for the material to which the employee will be exposed.
- A copy of this policy.

Physical Medical Examination.  The employee visits a physician who will evaluate the employee's physical fitness to wear a respirator. The physician will conduct whatever tests he/she feels are appropriate, but at a minimum will provide information adequate to ensure that the wearer is physically fit to wear the respirator.  If the physician is properly equipped, the user seal and fit tests may be conducted at the same time.  Upon visiting a physician, the employee must bring the following information:

- A MSDS for the material to which the employee will be exposed
- A copy of this policy.
- The specified respirator if fit test is to be conducted.

The physician must provide a written opinion of the individual’s fitness to wear a respirator and whether or not there are any conditions employee or employer must follow.  One copy of the approval shall be placed in the employee's file, and one copy provided to the employee.

The evaluation is required only once, except under the following circumstances:

  • Physician recommends re-evaluation at a specific interval.
  • Changes in the workplace that may result in an increase on the physical burden of the employee or significantly increase exposure.
  • The employee reports suffering distress through wearing a respirator, signs or symptoms relating to respirator use, or a change in health condition that may affect respirator use.
  • The University determines it is necessary.

The evaluations must be conducted by Spectrum Occupational Health Services, 973 Ottawa Avenue NW, Grand Rapids, MI 49503.  Phone: 616-391-7752.  Prior arrangements need to be made by a supervisor, Human Resources, or health and safety staff.  Upon termination of employment, medical evaluations shall be permanently kept in the employee's personnel file.

Step 2. Training in Respirator Use

All employees required to wear respirators will be trained in the hazards present and proper selection, fit testing, use, and maintenance of respirators.  This will be done both before an employee begins the use of a respirator and annually thereafter.  All employees will be made aware of the hazards present from all chemicals as part of the University’s hazard communication or Lab Safety Program.

Step 3. Checking Fit Prior to Use

Employees must ensure the respirator provides a proper fit.  Fit testing can only be performed after the physician has given approval for the employee's respirator use.  Also, fit testing and respirator use in general cannot be done if there is substantial facial hair between the skin and the facepiece of the respirator.  Proper fit is to be checked as follows:

(a)   User Seal Check Procedure.  Each time an employee uses a respirator, proper fit must be checked (see OSHA User Seal Check Procedures).  This is done using either of the following two procedures.

Positive Pressure Facefit Check.  To check, place palm of hand over the exhalation valve cover and exhale gently.  Be careful not to disturb the position of the respirator.  If the facepiece bulges slightly, and no air leaks between the face and the facepiece are detected, a proper fit has been obtained.  If air leakage is detected, reposition the respirator on the face and/or readjust the tension of the elastic straps to eliminate the leakage.  Repeat the above steps until a tight seal is obtained.  If a proper fit cannot be achieved, the employee may not enter the area but should instead see his/her supervisor.

Negative Pressure Facefit Check.  To check, place the palms of hands or thumbs over both filters.  Be careful not to disturb the position of the respirator.  The employee should then inhale gently and hold his/her breath for five to ten seconds.  If the facepiece collapses slightly, a proper fit has been obtained.   If air leakage is detected, reposition the respirator on the face and/or readjust the tension of the elastic straps to eliminate the leakage.  Repeat the above steps until a tight seal is obtained.  If proper fit cannot be achieved, the employee cannot enter the area but should instead see his/her supervisor.

(b)     Qualitative Fit Test.  Often referred to as an "irritant smoke test."  These tests are only to be conducted by staff who have reviewed the OSHA accepted Qualitative Fit Test Protocol and after the employee has passed the medical exam and user seal check.  These tests are to be performed at least annually, and under the following circumstances:  a new respirator is purchased, the employee requests a test, a request by a supervisor, doctor, or the University, and any other condition that may lead to a poor seal of a respirator.

C.  RESPIRATOR STORAGE AND MAINTENANCE.

Respirators must be stored inside a cabinet. The cabinet will have shelves and a door to keep out dust, sunlight, extreme heat or cold, moisture, or chemicals.

Between uses, respirators must be stored in the respirator cabinet so facepieces and exhalation valves will rest in a normal position to prevent rubber or plastic from reforming into an abnormal shape.

The respirator body shall be replaced whenever found to be faulty (i.e. cracked or broken face seal or body). A valve or headband shall be replaced as soon as any performance loss is noticed.

Each employee is responsible for keeping his/her respirator clean and in good condition, and returning it to the respirator cabinet in a sealed bag, which is usually provided with a new respirator.  Avoid sealing wet respirators in airtight bags due to potential for mold growth.  Respirators must be cleaned and disinfected regularly using antiseptic wipes.  If employees must share a respirator, it must be disinfected after each use.

Number of Respirators.  One respirator (and only one) will be issued to each person required to wear a respirator.  The University will provide the respirator and cartridges at no cost to the employee.

Each respirator will be clearly marked (using permanent marker) with the person's name or initials on the headband to prevent the sharing or exchanging of respirators.

 Inspection of the Effectiveness of the Respirator Program.   All managers, supervisors, and safety managers are responsible for making regular checks of work area conditions and employee practices to make sure the respirator program is effective.  Inspections will ensure that proper respirators and cartridges are used, respirators are used at appropriate times, and that they are clean, clearly labeled and well maintained.

Temporary Changes in Conditions.  If air sampling reveals unusually high levels of any potentially harmful material, this respirator policy may be temporarily modified by the Compliance Department.

D. RESPIRATORS AND CARTRIDGES.

The following respirators have been approved by the University.

 

3M 6000 SERIES

Respirator Body – Small, Medium or Large

6100, 6200 or 6300

Full Facepiece Respirator (S-L)

6700-6900

P-100 HEPA Filter

2093 (magenta)

P-100 HEPA Organic Vapor / Acid Gas Filter

60923 (yellow/magenta)

With wear, the body will have to be periodically replaced to maintain the respirator's filtering capacity.

Filters.  Always consult the product material safety data sheet and the cartridge manufacturer to ensure proper cartridge selection prior to use.  NO FILTER WILL PROVIDE PROTECTION IN OXYGEN DEFICIENT ATMOSPHERES.  There are two main types of filters that will typically be used:

 P-100 HEPA Filter.  The first is a HEPA (High Efficiency Particulate) filter.  This filter removes airborne particulates and aerosol contaminants such as silica, sawdust, most biological contaminants, or liquid particles (non-oil) that do not emit harmful vapors.  A respirator fitted with this filter will provide protection from dusts, fumes, or mists by capturing course and fine particles on the filter.

HEPA filters have served their useful life and must be replaced when visibly dirty, when breathing resistance becomes excessive, or when the user experiences taste, smell or irritation related to the particles being filtered.

 P-100 HEPA Organic Vapor/Acid Gas Filter.  This type of filter cartridge protects against certain organic vapors, acid gas and particulates found in a variety of applications including petrochemical, laboratories, pharmaceutical and chemical manufacturing. When properly fitted, helps provide respiratory protection from certain organic vapors, chlorine, hydrogen chloride, sulfur dioxide, or hydrogen sulfide or hydrogen fluoride and particulates at concentrations up to 10 times the Permissible Exposure Limit.  Not to be used for formaldehyde, ammonia, mercury vapor or methylamine.

Follow the manufacturer's recommendations for use and replacement recommendations.  In general, if the user experiences taste, smell or irritation related to the chemical being used the filter should be replaced. 

F.  DUST MASKS.

 Required Use of Dust Masks.  In no case does a dust mask provide adequate protection against inhalation of airborne contaminants above occupational exposure levels.  Typical respiratory hazards at the University do not require the use of dust masks; however any employee can request to wear a dust mask for his/her own comfort.  The University will keep a supply of NIOSH-approved dust masks and provide them at no expense to the employee.

If an employee is required to wear a dust mask, the requirements stated in this policy for employee respiratory protection must be followed. That includes medical evaluation and training, but not fit testing requirements.

Voluntary Use of Dust Masks.  If a supervisor chooses to allow employees to wear dust masks voluntarily, they must do the following:

G. INDOOR AIR MONITORING.

The University will conduct representative sampling when there is reason to believe that an employee may be exposed to airborne contaminants above OSHA’s Permissible Exposure Limits (PEL) or action levels during a typical work day.  All sampling and monitoring shall be coordinated through the University’s health and safety staff.  Individuals who are sampled will receive written results of their sampling within two weeks of receipt of the report from the laboratory.

1.    Monitoring will be conducted at the following intervals:

  • Initial Monitoring.  When an area begins or significantly alters the use of a chemical suspected to exceed the OSHA PEL or Action Level, a sample from all job classifications with potential exposure above the Action Level will be taken.  Additionally, any significant changes in production, process, handling procedures, etc. that might increase the level of contaminants in the atmosphere makes retesting necessary.
  • Routine Monitoring.  At appropriate intervals, routine monitoring may be performed to ensure the levels are within the acceptable limits.  All job classifications that are required to wear a respirator and some that could have potential exposure will be sampled.  If results above the Action Level are detected, sampling will be done every six months until operational changes bring levels within acceptable limits.
  • Complaint Monitoring.  If there are reports of signs or symptoms that may indicate overexposure, such as respiratory or skin conditions associated with exposure to airborne contaminants, the affected individuals must notify their supervisor immediately.  Health and safety personnel will determine whether monitoring will be necessary.

2.    Working Areas.  The University will maintain the general working area with exposures well below the PEL.  If any areas exceed that level, the appropriate respiratory protection must be worn until corrective engineering controls are implemented.  These would usually include operational changes, improved ventilation, or facility improvements.

If a particular area is expected to be above the PEL, all entrances must be posted with an appropriate warning sign. 

3.    Exposure Levels.

Consult the MSDS for exposure levels of airborne contaminants.

(a)      Action Level.  An eight hour time weighted average concentration below which no further action is needed. 

(b)      PEL.  The maximum eight hour time weighted average concentration that an employee can be exposed to without wearing a respirator.  Monitoring results between the Action Level and PEL will be resampled within six months of the sampling event.  If monitoring results show exposure above the PEL, full-time respirator use will be required for that job until satisfactory results are received.  This requirement will be waived only if there is compelling evidence that the test was not representative of the employee's exposure. 

(c)       STEL.  The maximum concentration of airborne contaminants that an employee can be exposed to in a 15 minute period.  Job classifications where employee exposure may exceed the STEL require respirator use while performing these jobs.

(d)      Maximum Concentration.  The level above which special types of respirators must be used.  Areas exceeding the Maximum Concentration must improve their engineering controls to reduce these levels.

4.    Recordkeeping.  The University must maintain any records concerning employee exposure, monitoring, and training at their facility.  Corporate will keep the following records for the necessary retention time:

Records

Retention Time

Exposure monitoring results

30 years

Training

30 years (file with exposure results)

Medical Surveillance

Duration of employment plus 30 years.

Respirator Fit Test

Until replaced by a more recent record.

{Policy revised 6/1/2010}

Page last modified March 18, 2014