The OSHA regulation 29 CFR 1910.134, Respiratory Protection, mandates requirements for implementing respiratory protection programs. As best practice, there are steps that should be taken prior to implementation to make the program come full circle.
When considering implementing a respiratory protection program, the first step should be to conduct a job safety analysis on the process or equipment of concern. Respirators should only be used as the last line of protection, after engineering and administrative controls have been exhausted, and a job safety analysis would evaluate other potential solutions. Sampling is also recommended to determine potential levels of exposure, which will aid in the determination of implementing a required or voluntary program. The level of sampling needed would be dependent upon the situation, but passive monitoring badges or active sampling may be appropriate. The combination of a job safety analysis and sampling provides the full picture of the hazards associated with the process. The next step is to determine if the respiratory protection program is required or voluntary. Of course, an employee can request to voluntarily wear a respirator at any time. A company can also decide to require respirators for specific tasks or in specific areas even if the sampling shows that exposure levels are not exceeded. There are many factors to consider when determining if the program will be voluntary or required.
Once the determination on voluntary or required is made, program implementation is based on the requirements for the respective determination. Respirator selection, fit testing, medical clearance, policy development, and training are a few of the major aspects associated with implementing a compliant respiratory protection program, which includes numerous documentation requirements.