Respiratory Protection Plan

Scope

California State University, Dominguez Hills (CSUDH) is dedicated to protecting the health, safety and well being of students, employees, visitors, and the surrounding community. The Respiratory Protection Program is established to protect employees from hazardous airborne substances specifically particulate matter, toxic gases, fumes and vapors.

This is to be accomplished as far as feasible by eliminating the hazard, by using less toxic materials, or by using accepted engineering or administrative control measures (e.g., enclosure or confinement of the operation, general or local ventilation, or policies/procedures to reduce exposure). Respiratory protection should be used as the last resort in preventing harmful exposures to employees and not as a substitute for other feasible controls/measures.

Purpose

The Program applies to employees who work in potentially hazardous atmospheres, and outlines accepted practices for respiratory equipment use including information and guidance on the proper selection, use, and care of respirators and requirements governing their use. Environmental Health & Safety (EHS) administers and oversees implementation of the program.

The program complies with Cal/OSHA’s requirement for CSUDH to develop and implement a written respiratory program as defined in the following regulation:

California Code of Regulations (CCR), Title 8 Section 5144

https://www.dir.ca.gov/title8/5144.html

Roles and Responsibilities

a) The University

The University is committed to and has a duty to provide a safe and healthful work environment for employees potentially exposed to airborne contaminant hazards.

b) Environmental Health & Safety

EHS will ...

Appoint the Chemical Hygiene Officer to conduct this Program.
Evaluate respiratory hazards in the workplace.
Establish, implement, and maintain the Program, which is designed to eliminate or minimize exposure to airborne contaminants.
Perform exposure assessment and monitoring to determine appropriate respiratory protection requirements.
Develop training materials and conduct annual training for all employees who are required to wear a respirator.
Coordinate annual medical evaluation and fit testing for all employees who are required to wear a respirator
Maintain training, fit testing, and “pass/fail” medical evaluation records.
Enroll employees in the Program and provide authorization to wear a respirator.
Evaluate and approve voluntary use of respirators.
Remove employees from the Program and revoke authorization to wear a respirator if employee fails to meet the Program requirements.
Review and evaluate the Program for effectiveness annually and update the Program as needed.

c) Department Management

The Department of the applicant employee will…

Identify and evaluate employee exposure hazards.
Ensure that all respirator users have received medical approval, training and fit testing, as required, prior to the use of respiratory protective equipment.
Enforce work practices and methods designed to protect employees, such as selection, use, fitting, maintenance, cleaning and storage of protective devices.
Implement practices that protect the health and safety of employees, visitors, and students at campus facilities under their control.
Purchase and issue respiratory protection equipment including respirators, cartridges, and cleaning supplies upon recommendation and authorization by EHS.

d) Supervisors (Employee Reports-to Manager)

Supervisors are responsible for the following:

Identify employees who will perform tasks that require respiratory protection and contact EHS to enroll the employees into the Program. Employees are not permitted to wear a respirator until authorized by EHS.
Request assistance from EHS to evaluate changes in work area conditions or degree of exposure or stress that may affect respirator effectiveness.
Enforce the proper use of respiratory protection equipment where it is required and the requirement for authorized use.
Ensure that a respirator is used only be the employee that it was assigned to.
Inform EHS when an employee stops participating in the Program.

e) Employees

Employees will…

Utilize the issued respiratory protection equipment in accordance with instructions and training provided by EHS.
Inform the Supervisor immediately of any personal health problems that could be caused or aggravated by using respiratory protection equipment.
Inform the Supervisor of any change in work area conditions or degree of exposure or stress that may affect respirator effectiveness.
Inspect and care for their respiratory protection equipment.
Report any observed or suspected malfunctioning of their respirator to EHS.
Use only those brands, sizes, and types of respiratory protection equipment for which they have been specifically fit tested for and trained to use.
For half-face air purifying respirators, use the appropriate type of cartridge for the airborne exposure hazard, and follow the manufacturer’s cartridge change-out schedule.
Ensure an effective face to face-piece seal during respirator use.
Inform their Supervisor or EHS if they no longer wish to participate in the Program. Only voluntary users may opt out of the Program.

Definitions

Air-purifying respirator (APR) - A respirator that works by removing gas, vapor, or particulate, or combinations of gas, vapor, and/or particulate from the air through the use of filters, cartridges, or canisters that have been tested and approved for use in specific types of contaminated atmospheres by NIOSH. The respirator does not supply oxygen and therefore cannot be used to enter an atmosphere that is oxygen deficient.

Note: Cartridges, canisters, and filters are approved for use against specific hazards where the concentration is known or can be reasonably estimated. Some combination organic vapor/particulate cartridges and canisters are approved for use against CS and CN tear gas.

Approved - Respirators and cartridges that have been tested and listed as satisfactory by the National Institute for Occupational Safety and Health (NIOSH).

Assigned Protection Factor (APF) – The workplace level of respiratory protection that a respirator or class of respirators is expected to provide to employees when the employer implements a continuing, effective respiratory protection program.

Canister or Cartridge – A container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container.

CBRN - Chemical biological, radiological, and nuclear defense.

Contaminant - A harmful, irritating, or nuisance agent foreign to the normal atmosphere.

Employee Exposure – Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection.

Exhalation Valve - A device which allows exhaled air to leave a respirator and prevents infiltration of outside air.

Face-piece – The portion of a respirator that covers the wearer’s nose and mouth in a half face-piece and nose, mouth, and eyes in a full face-piece. It seals to the face and includes the headbands, exhalation valve(s), and connections for an air-purifying device.

Filter – A medium used in respirators to remove solid or liquid particles from the air stream entering the respiratory enclosure.

Filtering Face-Piece – A negative pressure particulate respirator with a filter as an integral part of the face-piece or with the entire face-piece composed of the filtering medium (e.g. a dust mask).

Fit Test – The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fit test QNFT.)

High-Efficiency Particulate Air (HEPA) Filter – A filter that is at least 99.97% efficient in removing monodisperse particles of 0.3 micrometers in diameter.

Immediately Dangerous to Life or Health (IDLH) – An atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual’s ability to escape from a dangerous atmosphere.

Inhalation Valve – A device that allows air to enter the face-piece and prevents exhaled air from leaving the face-piece.

National Institute for Occupational Safety and Health (NIOSH) – A Federal agency that tests, approves, and certifies respirators and cartridges.

Oxygen Deficient Atmospheres – Air that contains less than 19.5% oxygen by volume.

Particulate – Airborne solid or liquid dusts, fogs, fumes, mists, smokes, or sprays.

Permissible Exposure Limit (PEL) – Contaminant exposure concentrations listed by the California Occupational Health and Safety Administration (Cal/OSHA) that a healthy individual normally can tolerate for 8 hours a day, five days a week, without harmful effects. Particulate concentrations are listed as milligrams per cubic meter of air (mg/m3), and gaseous concentration are listed as parts per million by volume (ppm).

Physician or other Licensed Health Care Professional (PLHCP) – An individual whose legally permitted scope or practice (i.e., license, registration, or certification) allows him or her to independently provide, or be delegated the responsibility to provide some or all of the healthcare services required under the respiratory protection program.

Powered Air-Purifying Respirator (PAPR) – An air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Qualitative Fit Test (QLFT) – A pass/fail fit test to assess the adequacy of respirator fit that relies on the individual’s response to the test agent.

Quantitative Fit Test (QNFT) – An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator.

Respirator – A device that protects the wearer from inhalation of harmful contaminants.

Service Life – The period of time that a respirator, filter or sorbent, or other respiratory equipment, provides adequate protection to the wearer.

Tight-Fitting Face-Piece – A respiratory inlet covering that forms a complete seal with the face.

Respirator Selection

EHS has evaluated the respiratory hazards of various job classifications throughout CSUDH and has prepared a respirator selection matrix (Appendix A). Please refer to the matrix to select the appropriate type of respirator or consult with EHS. Respirators and cartridges will be issued by departments at no cost to employees.

The following types of respirators are used by employees on campus, excluding police officers:

N95 Respirators - N95 filtering face-piece respirators are available to authorized users, such as staff at the Student Health Center (SHC) and those who voluntarily choose to use them. The staff at the SHC must be fit tested for use in compliance with CCR Title 8, Section 5199, regarding aerosol transmissible diseases. Voluntary users are not fit tested.
Air-purifying Half Face-piece Respirators – These include 3M and North brands which are provided by the department. They do not provide protection in oxygen deficient atmospheres. Half face respirators use various types of filter cartridges to protect against various hazards. HEPA filter cartridges protect against particulates such as asbestos, lead, and low levels of toxic and radioactive particulates. Other filters protecting against specific contaminants such as acid gases or organic vapors. Combination filters protect against all or a few of these specific contaminants. All users of half-face respirators must be fit tested.

Medical Evaluation for University Police Officers

University Police offers are considered medically qualified to use respiratory protective equipment after completing the POST Medical History Statement (POST 2-252) or its equivalent and successfully passing a physical examination that occurs as a condition of employment. The pre-employment physical must meet or exceed the standards described in the POST Medical Screening Manual for California Law Enforcement. Employees who were hired prior to the implementation of the POST Medical History Statement (POST 2-252) shall complete the Cal/OSHA medical questionnaire and department medical personnel shall review it.

Medical evaluations are required for any officer when any of the following occurs:

An officer reports medical signs or symptoms that are related to the ability to use a respirator.
A physician or other licensed health care professional, a Supervisor, or the Program Administrator informs the Chief of Police that an officer needs to be reevaluated.
Observations made during fit testing and program evaluation indicate a need for re-evaluation.
A change occurs in workplace conditions that may result in a substantial increase in the physiological burden placed on an officer.

Employee Education and Training

Prior to wearing a respirator, employees enrolled in the Program shall complete initial Respiratory Protection Program Training. Employees enrolled in the Program shall be retrained annually. Additional training shall be provided when there is a change in the type of respiratory protection used, or when inadequacies in the employee's knowledge or use of the respirator indicate that he/she has not retained the requisite understanding or skill.

Training will be provided at no cost to employees by EHS and/or through web-based training on the following content:

Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator.
What the limitations and capabilities of the respirator are.
How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions.
How to inspect, put on and remove, use, and check the seals of the respirator.
What the procedures are for maintenance and storage of the respirator.
How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.
How to decontaminate (or safely dispose of) a respirator that has been contaminated with chemicals or hazardous biological materials.
The general requirements of Title 8 CCR 5144.

No CSUDH employee will be required to work in IDLH atmospheres, and therefore the training for most employees will focus on work in and around low-hazard atmospheres and nuisance dusts. University Police officer respiratory protection training will also include information on how to use respirators for general-duty and CBRN incident response.

Respirator Fit Testing

The Program requires qualitative or quantitative respirator fit tests as determined by EHS to ensure a tight-fitting seal. The Program also prohibits respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function. Facial hair is allowed as long as it does not protrude through the respirator seal or extend far enough to interfere with the device’s valve function. Fit testing shall not be performed, nor shall a respirator be worn, if facial hair interferes with the seal.

Fit testing can detect and help correct poorly fitting or performing respirators based upon contaminant leakage into the respirator. During fit tests, adjust the straps properly as comfortably as possible to simulate working conditions. Cal/OSHA fit testing procedures are described in Appendix A of Title 8 CCR 5144 and summarized below.

Before an employee is required to use any respirator, the employee must be fit tested with the same make, model, style, and size of respirator to be used. Employees shall be provided with a sufficient number of respirator models and sizes so that he/she may select an acceptable face piece.
Fit tests shall be provided at the time of initial assignment and at least annually thereafter. Additional fit tests shall be provided whenever an employee reports a physical condition that could affect respirator fit. These conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight.
Employees fitted for full-face APRs who wear corrective glasses or other personal protective equipment must be sure that such equipment is worn in a manner that does not interfere with the face piece seal. The glasses or personal protective equipment that must be worn with the respirator shall be taken to the fit-test assessment and worn during the test.
Employees who are issued a full-face APR will use a quantitative (numerical measurement of leakage) method fit test.

Fit testing for University Police officers is performed by the Department Armorer using a TSI Portacount Pro. Fit testing for all other employees is performed by EHS or a provider designated by EHS.

Fit test records are maintained by the University Police Department for officers and by EHS for all other employees. Fit testing is provided to employees at no cost.

The types of fit testing are described below:

Qualitative Fit Test - Options for fit testing include irritant smoke (stannic chloride), Bitrex solution, or banana oil applied to the face to face-piece seal. Irritant smoke is applied approximately six inches from the seal as the respirator wearer counts loudly from 100 to 1 or repeats the OSHA “Rainbow Passage” while moving the head from side-to-side and up-and- down. The test simulates movements and conversation the wearer will perform during the course of their work. Infiltration of the smoke will cause the wearer to cough involuntarily and result in an unsuccessful test. If no smoke infiltrates the seal, the test is successful. The Bitrex solution or banana oil is used with the employee inside of a test enclosure. The test is successful if the wearer cannot taste the solution caused by infiltration of the mask. A sensitivity test confirms that the wearer can detect the solution.
Quantitative Fit Test - A machine is used to measure the actual amount of leakage into the facepiece and does not rely upon the wearer’s sense of taste, smell, or irritation in order to detect leakage. The respirator is worn by the wearer and connected to the machine with tubes or hosing. Three methods are accepted by Cal/OSHA: general aerosol, ambient aerosol, and controlled negative pressure.

Quantitative tests provide a numerical fit factor for each respirator. These fit factors relate to a specific respirator, but Cal/OSHA has assigned protection factors (PFs) to different classes of respirators as guidance on proper selection. Like the fit factor, the PF equals the ambient concentration of a contaminant divided by the concentration within the respirator (PF = ambient concentration/inside concentration). Half face-piece respirators generally provide a PF of 10 and full face-piece respirators provide a PF of 50. Example: Work with a half face-piece respirator in an atmosphere with 10 ppm contaminant concentration equates to an actual exposure of 1 ppm.

In addition to either qualitative or quantitative fit testing, APR wearers shall perform a positive and negative air pressure check each time the respirator is donned prior to entering a hazardous atmosphere.

Positive/Negative Air Pressure Check - Prior to each use, the respirator wearer will complete a negative pressure test. Don the respirator and place the hands over the inlet of the filter cartridges to restrict air from passing through; inhale gently so the face-piece slightly collapses; and hold their breath for approximately 10 seconds. If the face-piece remains slightly collapsed and no inward leakage occurs, the test is successful. Next, complete a positive pressure test by covering the exhalation valve and exhaling gently into the face-piece. If no outward air leakage occurs the test is successful.

Voluntary Use

Upon request by an employee, EHS may authorize employees to voluntarily wear a respirator, if EHS determines that such respirator use will not in itself create a hazard.

Voluntary users of N95 respirators are exempt from medical evaluation and fit testing but must complete the initial Respiratory Protection Program training prior to wearing a respirator.

Voluntary users of half-face respirators must be enrolled in the Respiratory Protection Program and complete the same requirements as employees who are required to wear respirators (i.e., they must receive fit testing, medical evaluation, and initial and annual training).

Refer to Appendix B for more information on voluntary use of respirators. Contact EHS to request to wear a respirator on a voluntary basis.

Emergency Use

CSUDH does not issue atmosphere-supplying respirators for use in immediately dangerous to life and health (IDLH) atmospheres. Respirators issued under this program shall not be used to enter any area that is designated as the exclusion ("hot" or "red") zone, or the contaminant reduction ("warm" or "yellow") zone of a hazardous materials incident. University Police officers are provided with CBRN powered air purifying respirators (PAPRs) for escape from hazardous materials environments during emergency response.

For continuous duty in maintaining the perimeter of hazardous materials or crowd control incidents, University Police officers shall use approved gas masks and other APRs. Respirators shall be selected that are approved for the contaminants that are believed to be present, and wearers shall not be located in atmospheres in which concentrations exceed the protection factor of the respirator.

Select University Police, laboratory and EHS employees who have received proper training, may use respiratory protection to clean up small chemical spills. Refer to the campus Chemical Hygiene Plan for information on small spill clean-up procedures: https://www.csudh.edu/Assets/csudh-sites/rm- ehos/docs/health-safety/2019/chemical-hygiene-plan.pdf

Respirator Care

Respirators are issued by the department. Respirator wearers are responsible for caring for their respirators. If a respirator exhibits any defects, return it to the department or EHS and request a new respirator.

Prior to and after each use, the respirator wearer must inspect all parts of the respirator to ensure it is not cracked, decomposed, distorted, frayed, loose, pitted, stretched, stiffened, swollen, torn, or warped. Such parts may include: rubberized face-piece, plastic adapters, inhalation valves flaps, headband straps, plastic exhalation valve seats, exhalation valve covers, and filter elements.

Employees must clean the respirator after each use with either respirator wipe pads or by removing the filters and straps and using a mild soap solution and a soft brush. After using soap, rinse with clean warm water and air dry. Store the respirators in a cool dry location without distorting the face-piece.

Cartridge Change-out Schedule

Air purifying respirator cartridges don't last forever. The useful service life of a cartridge depends upon many factors, including environmental conditions, breathing rate, cartridge filtering capacity, and the amount of contaminants in the air. The Program requires that employees follow the cartridge manufacturer’s recommendations for cartridge change-out schedule or one year from the date that cartridges were first used, whichever is sooner. If manufacturer’s recommendations are not available contact EHS for guidance.

Exposure Assessment

Employees wishing to use a respirator should contact EHS for an exposure assessment. EHS will establish whether exposures to hazardous substances exceeds Cal/OSHA permissible exposure limits (PELs). The employee enters the Program when exposures exceed the PEL and engineering and administrative controls cannot successfully reduce exposures. EHS compares exposures to the respirator protection factor to select the appropriate respirator.

Record Keeping

Program records include enrollee names, training tracking, completed fit tests, and medical evaluations. All program records for University Police officers shall be maintained by the University Police Department. Program records for all other employees shall be maintained by EHS except for complete medical evaluations, which are maintained by Western Medical Group.

Records shall be maintained in accordance with the CSU Executive Order 1031 record retention schedule: http://www.calstate.edu/recordsretention/documents/EHS.pdf

A copy of this program and the above records shall be made available to all affected employees, their representatives, and representatives of the Chief of the Division of Occupational Safety and Health.

Program Effectiveness Evaluation

EHS will evaluate the Program for effectiveness annually to ensure that the written Program is being properly implemented, and to consult with employees to ensure that they are using the respirators properly.

EHS will conduct evaluations of the workplace regularly to ensure that the provisions of the current written respiratory protection program are being effectively implemented and that it continues to be effective.

As part of the Program evaluation process, EHS will consult Program participants to assess the employees' views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be documented and corrected. Factors to be assessed include, but are not limited to:

Engineering controls that could eliminate the need for respiratory protection.
Respirator fit (including the ability to use the respirator without interfering with effective workplace performance).
Appropriate respirator selection for the hazards to which the employee is exposed.
Proper respirator use under the workplace conditions the employee encounters.
Proper respirator maintenance.

Directions for filling out Hazard Evaluatiuon Form

Directions - If you believe you are in need of respiratory protection.

Fill out the Hazard Evaluation Form to the best of your ability
The evaluation form is found in the "Forms" tab
Use N/A (non-applicable) if a question does not apply to you
Give as much detail and information as you may possible
Use Adobe Acrobat to open the form and answer the questions
Review your answers before submitting form
Submit form by hitting the submit button on the top right corner
Once submitted, EHS will review your form and get back to you