Recent advances in environmental technology as well as the changing nature of environmental regulations have greatly expanded the areas of responsibility of corporate environmental, health, and safety officers. New environmental monitoring requirements, the increasing use of risk assessment in hazardous materials regulations, new methods for hazardous waste clean-up these and other recent developments have focused industry and government attention on how to manage cost-effectively the use, transport, and disposal of toxic agents.
Environmental managers are increasingly required to implement detailed – and documented – environmental management programs among their operating units to monitor compliance with specific groups of environmental regulations and requirements. Environmental risk managers must be trained in the key elements of environmental management and auditing oversight programs. One such component, often overlooked in the past, is emergency response planning.
A number of environmental regulations (including the Superfund Amendment Reauthorization Act) and federal agencies (including EPA and OSHA) have very specific ongoing training requirements for workers who handle, transport, or manage hazardous materials. In addition, they often require that a contingency plan be developed in case of an uncontrolled release of toxic chemical agents at a particular location (Smith, 18). This plan must be supplemented by documented internal reporting procedures and competence. OSHA regulation 1910. 34 states that when it is not possible through engineering controls to control human exposure to toxic chemical agents in the workplace or during emergency response actions, appropriate respiratory protection must be used.
A good respiratory protection program can also reduce worker accidents and illness, regulatory compliance costs, on-site compliance oversight by regulatory authorities, and production operations costs and downtime. Under OSHA regulation 1910. 134, employers are responsible for the following: Providing respirators when such equipment is necessary to protect an employee’s health. – Providing respirators that are applicable and suitable for the purpose intended. – Establishing and maintaining a respiratory protection program. Corporate management and employees must make diligent and dedicated efforts to ensure corporate respiratory protection programs meet their stated goals (Smith, 21). Staff and management responsible for respirator assignment must receive appropriate training. Assignment of improper respirators to employees has resulted in employee injury and death.
Staff must therefore have the appropriate technical and professional background to administer a respiratory protection program and make sound respirator selections based on proper evaluation of workplace hazards. It is important that one member of management have final responsibility – and the necessary management support – for company respiratory protection programs, with appropriate staff specialized in all needed areas of respirator maintenance and use (Bevis, 47). One key responsibility of corporate health and safety management is purchasing respirators.
The program administrator should have a strong voice in this decision, if not complete control over it. Respirators cannot be selected on the basis of price alone. The large variety of styles and options in respiratory equipment allows almost any worker in any situation to be properly protected. A number of workplace situations and applications require specialized respiratory protection equipment. These applications include firefighting, confined space entry, and immediately dangerous to life and health (IDLH) environments (Vaughan, 2004: 9).
Other factors important in purchase decisions for respirator equipment include sizing of masks, job duration, and type of chemical protective clothing to be worn. Written procedures for respirator selection and use are very important to avoid misuse and to educate users. They are required by OSHA 29 CFR 1910. 134 as part of a “minimal acceptable program” (Vaughan, 2004: 11). Their purpose is to ensure proper respiratory protection for a specific group of workers against a specific hazard or hazards. The written standard operating procedures should contain all the information needed to maintain an effective, site-specific respirator program.
They should be written so that those directly involved in the respirator program – users, administrators, maintenance personnel, trainers, and supervisors – will be able to understand and use them on the job (Vaughan, 2003:31). Generally, the plan should contain the following elements: – Selection criteria for approved respirators for protection against specific hazards. – Detailed instructions for training users in the proper fitting and use of respirators they will wear. – Detailed maintenance procedures for such things as cleaning and disinfection, drying, inspection, repair or replacement, and storage. Administrative procedures for purchasing, inventory control, issuance of respirators, surveillance of hazards, and monitoring of respirator use. – Instructions for emergency respirator use, for example, in fires and immediately dangerous to life and health atmospheres. – Guidelines for medical surveillance of workers. – Procedures for evaluating the respiratory protection program’s effectiveness. Basically, all information needed to establish and maintain a safe and effective respiratory protection program should be recorded in the plan.
It is much better to be overly detailed than not to be detailed enough in the written plan. It is particularly important to include emergency respirator procedures for use in fires, hazardous chemical spills, or low-oxygen situations (Vaughan, 2003:33). No one should be assigned a task requiring the use of a respirator unless he or she has been found physically able to do the work while wearing the respirator. This not only makes good sense from a safety standpoint but is a requirement of OSHA 1910. 134. Certain chemicals and occupations have specific standards and requirements for medical examinations.
It is up to a physician to determine what level of health and physical condition is required and if the potential user can meet those conditions. Exams are conducted prior to respirator use and periodically thereafter to determine if there have been any changes in health or physical condition. The exam should also address any history of respiratory disease; work history that may include possible exposure to substances causing respiratory disease; and other medical information such as symptoms of claustrophobia, physical deformities or abnormalities affecting respirator use, use of medication, and tolerance of heat stress.
While good physical health is important to the safety of the respirator user, it is likewise important to be able to use the respirator safely. Safe, proper use comes about through careful training of supervisors and workers in the selection, use, and maintenance of respiratory protective devices. OSHA requires that training of both workers and supervisors include an opportunity to handle the respirator, proper fit of the respirator, testing of the facepiece-to-face seal, and adequate time of use in normal air to become familiar with the device.
Further training includes fitting instructions, discussion of why respirators are needed, discussion of the nature of the hazards and their effects, explanation of why a particular type of respirator has been selected, and discussion of how to recognize and handle emergencies. Training should emphasize the need and reasons for wearing a respirator. It should also help motivate the user to accept the facts that protection is needed and that respirators must be used and maintained properly in order for the device to provide adequate protection.
Fit testing is another OSHA requirement for users of negative-pressure respirators. Fit testing may involve both qualitative and quantitative testing. Qualitative testing relies on the user’s subjective response to determine mask leakage and, therefore, improper fit (Sheppard, 52-53). A quantitative test relies on actual contaminant measurement inside the facepiece. Qualitative tests are fast, are easily performed in the field, and do not require expensive equipment. They do rely on the wearer’s subjective response; because sensitivities vary among individuals, this may not be entirely reliable.
S. L. Smith. (2000). Is your respirator program effectively managed? Occupational Hazards. Cleveland: March, Vol. 61, Iss. 3; Darell A Bevis. (2000). Complying with OSHA’s respiratory protection standard. Occupational Hazards. Cleveland: March, Vol. 62, Iss. 3 Kenneth Vaughan. (2004). Measuring Your Respiratory Program. Occupational Health ; Safety. Waco: May, Vol. 73, Iss. 5 Kenneth Vaughan. (2003). The right reason for respirator training. Occupational Hazards. Cleveland: August, Vol. 65 Rob Sheppard. (1999). Figuring out fit-testing. Occupational Health ; Safety. Waco: November, Vol. 67, Iss. 11