Ask the Expert: Implementing a Respiratory Protection Program

In our latest installment of Ask the Expert, brought to you by the team of industry experts at EHS Hero®, we look at a recent question from a subscriber asking how to implement a respiratory protection program. See what the experts had to say.
Q: What are the steps to implement a respiratory protection program? What are the OSHA regulations that require a written respiratory protection program, employee training, medical evaluations, and fit testing?
OSHA’s respiratory protection standard for general industry is found at 29 CFR 1910.134. The requirements for the construction industry are identical to those set forth in the general industry standard. The standard requires employers to provide a respirator to each employee when such equipment is necessary to protect the health of the employee. Employers are also responsible for the establishment and maintenance of a respiratory protection program, which must include the requirements outlined in 1910.134(c). The program must cover each employee required to use a respirator. 
Pursuant to 1910.134(c), the employer must develop and implement a written respiratory protection program with required worksite-specific procedures and elements for required respirator use. The program must be administered by a suitably trained program administrator and be updated as necessary to reflect changes in workplace conditions that affect respirator use. In addition, certain program elements may be required for voluntary use to prevent potential hazards associated with the use of the respirator. 
The written program must include the following provisions: 
  • Procedures for selecting respirators for use in the workplace; 
  • Medical evaluations of employees required to use respirators (Required by 1910.134(c)(1)(ii)); 
  • Fit-testing procedures for tight-fitting respirators (Required by 1910.134(c)(1)(iii)); 
  • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations; 
  • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators; 
  • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators; 
  • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations (Required by 1910.134(c)(1)(vii)); 
  • Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance (Required by 1910.134(c)(1)(viii)); and 
  • Procedures for regularly evaluating the effectiveness of the program. 
The requirements for employee training are detailed in 1910.134(k), the requirements for medical evaluations are detailed in 1910.134(e), and the requirements for fit testing are detailed in 1910.134(f).