Federal law requires that engineering controls rather than respirators be used to solve air contamination problems. Nevertheless, respirators too often are used as a permanent solution. Some people hate the masks and figure that they're worse off than before. Some even begin to feel that they would rather breath the dirty air. That puts the safety rep or committee in the middle. But this doesn't have to be the end of the story. The more you know about respirators and their regulations, the more you can improve this type of situation.
Respirators are just about the most unpleasant and least effective type of personal protective equipment you can be asked to wear. They furnish protection against poisons in the air, but they are a last resort when the toxic substance can't be removed by substitution of a different material or by engineering controls (ventilation and/or enclosure). Workers should accept the use of respirators if:
- They are a short-term, temporary measure while a plan for engineering controls is carried out on a definite timetable.
- They are needed for rarely performed procedures for which other precautions have failed.
- They are correctly maintained for use in emergencies.
- They are a last resort for a problem that can't be solved otherwise.
They are a cheap substitute for solving an occupational health problem correctly, and they often don't work. However, federal and state OSHAs will usually accept and require them. As a union member, you should:
- Make sure that the respirator is functioning correctly, that protection is being provided.
- Insist that one qualified individual supervise the respirator program.
- Demand that all parts of the legal standards are complied with, which is a difficult task for the employer.
- Keep up the pressure to control the contaminant at the source through local ventilation. Technology does exist to remove the hazard.
If respiratory protection is needed, the employer is required to provide the equipment, see that it is worn and can be cited if workers are not using provided equipment. A worker who refuses to wear a respirator, or use it properly, risks harming his or her health. Providing respirators does not exempt the employer from citation for failure to provide feasible engineering controls.
The employer's real commitment to worker health is measured by whether there is a schedule for completing engineering controls and also whether supervisors as well as workers are asked to comply, whether requirements are enforced equally on all affected employees and whether the use of respirators complies with standards.
Legal requirements for a respirator program are found in the OSHA General Industry Standards Section 1910.134. The highlights of the rules are as follows:
Requirements for a minimal acceptable program.
"(1) Written standard operating procedures governing the selection and use of respirators shall be established."
- Make sure the employer goes through this step with the Union safety representative or committee and insist that these be posted and readable on the job site and given to each worker involved.
"(2) Respirators shall be selected on the basis of hazards to which the worker is exposed."
- Demand that the employer tell you the level of the air contaminants measured and their type. If dust levels are very high, for example, the disposable dust mask will not work. Get an exact copy of the industrial hygiene data.
- Respirators work either for particles (dusts, mists, fumes) or gases and vapors. There must be either a "Bureau of Mines" or "NIOSH" approval number (for example TC-21C-132) and a description of what it protects against right on the mask. Have the company produce the manufacturer's written description. A dust and mist respirator usually provides no protection against vapors.
- If someone asks the company for a respirator, make sure it's the correct type for the hazard.
"(3) The user shall be instructed and trained in the proper use of respirators and their limitations."
- The word "limitations" is important. The employer must tell the workers that respirators are not a permanent solution.
- The instruction should include how to do fit tests for an air purifying (cannister-type respirator). Plug up the filters in the respirator and breath in gently. If the mask doesn't hold the vacuum, it's no good.
- Everyone's face is different. There should be several varieties provided to insure fit.
- Demand that this instruction be carried out by a trained safety professional or jointly with the Union safety representative or committee, and that all supervisors receive this training as well.
"(4) Where practicable, the respirators should be assigned to individual workers for their exclusive use."
- This is a simple cleanliness measure to control the spread of dirt and disease.
"(5) Respirators shall be regularly cleaned and disinfected. Those issued for the exclusive use of one worker should be cleaned after each day's use, or more often if necessary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use."
- This task is the responsibility of the employer.
- The mask should be turned in at the end of the shift for cleaning and inspection and picked up at the start of the next.
"(6) Respirators shall be stored in a convenient, clean and sanitary location."
- The employer should provide and maintain such a location. For example, this is especially important for air-supplied hoods, which are usually left out on the shop floor.
"(7) Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Respirators for emergency use such as self-contained devices shall be thoroughly inspected at least once a month and after each use."
- Obviously, filters get plugged and absorbing cartridges run out and must be replaced.
- The safety representative or committee should check emergency equipment regularly.
- It is very important to check the seals in a standard mask and the tubing and valves in an air-supplied system.
- Rubber parts should be inspected for pliability and signs of deterioration.
"(8) Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained."
- This requirement is especially important. If an air-supplied hood is used, demand that the company sample the air inside during use. When the hood doesn't fit right, the worker may get an excessive exposure inside.
"(9) There shall be regular inspection and evaluation to determine the continued effectiveness of the program."
- Demand that the employer regularly go over all aspects of this program, including air contaminant measurements and progress on engineering controls with the safety representative or committee.
"(10) Persons should not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance, annually)."
- Someone who has lung problems may not be able to do the extra work of breathing both in and out through a respirator. This is very likely if he or she has been in a dusty area for years.
- Demand a lung function test, chest X-ray and general physical for each worker assigned a respirator. This may already be in your contract.
- Demand that the doctor come out to the workplace to observe the job and its exertion (for a full shift) so as to fully comply with this regulation.
Technology for controlling hazards through ventilation does exist so that you don't need to wear masks. The problem is getting the company to obey the law.
For more information about protecting workers from workplace hazards, contact the AFSCME Health and Safety Program at (202) 429-1000, or 1625 L Street, N.W., Washington, DC 20036.