FOX Corporation is committed to minimizing the use of respiratory protection in favor of other exposure controls wherever possible. When respiratory protection is specified, worker qualifications and training, and respirator usage procedures, must conform to the requirements in this Procedure.
1.0 SCOPE
FOX Corporation (FOX) requires that the use of respiratory protection be implemented only as an interim measure to protect employees from identified hazards until other controls can be instituted, or where the use of such controls is ineffective or impractical.
2.0 Definitions
Adequate Warning Property:
a characteristic of a hazardous chemical, such as odor, taste, or irritation effects, which is detectable and persistent at concentrations at, or below, the Occupational Exposure Limit, and exposure at that level does not cause olfactory fatigue.
Air-Line Respirator:
a type of air supplying respirator by which an air line or hose supplies the user with air from a remote portable or stationary source of compressed air.
Air-Purifying Respirator:
a respiratory protective device designed to remove air contaminants (i.e., dust, fumes, mists, gases, vapors, or aerosols) from the ambient air, using filters and/or adsorbent cartridges.
Assigned Protection Factor:
a multiplier number assigned by the American National Standards Institute (ANSI) in Standard Z88.2, which indicates the capability of a respirator to afford, at a minimum, the specified degree of protection.
Atmosphere-Supplying Respirator:
supplies the wearer with air or oxygen from a source independent of the immediate ambient atmosphere. This includes airline respirators and self-contained breathing apparatus units.
Canister or Cartridge:
the element of an air‑purifying respirator that contains the sorbent, filter, and/or catalyst that removes specific contaminants from the air, as it is drawn through the canister/cartridge.
Immediately Dangerous to Life or Health (IDLH):
an atmospheric condition that poses an immediate threat to life; causes irreversible or delayed adverse health effects; or interferes with an individual’s ability to escape from a dangerous atmosphere.
Negative Pressure Respirator:
a respirator in which the air pressure inside the facepiece is negative, relative to the outside air pressure, during inhalation.
Occupational Exposure Limit (OEL):
the highest allowable airborne concentration of a chemical to which a worker can be exposed, as averaged over a specified time limit. For Fox activities, OELs correspond to the Permissible Exposure Limit requirements established in the California Code of Regulations (CCR), Title 8, Chapter 4, Subchapter 7, Section 5155, Table AC-1.
Oxygen-Deficient Atmosphere:
an atmosphere that contains oxygen content of less than nineteen point five (19.5) percent (%) by volume.
Positive Pressure Respirator:
an atmosphere-supplying respirator, designed so that the air pressure inside the facepiece is positive, in relation to the outside air pressure, during both inhalation and exhalation.
Qualitative Fit Test:
an assessment of the adequacy of a respirator facepiece fit, which is respirator wearer determines by whether or not odor, taste, or irritation of a challenge agent, introduced to the outside of the respirator, is detected.
Quantitative Fit Test:
an assessment of the adequacy of respirator fit, determined by numerically measuring concentrations of a challenge agent inside and outside the facepiece. The ratio of the two measurements is an index of seal leakage between the respirator’s facepiece and the wearer’s face.
Self-Contained Breathing Apparatus (SCBA):
a type of air supplying respirator that utilizes compressed air cylinders, carried by the user, to provide breathing air.
Voluntary Use:
any use of respiratory protection that is not required for protection from an identified occupational exposure hazard, but is requested by an employee for his/her own comfort.
3.0 Responsibilities
In addition to required Environmental, Health and Safety (EHS) Program responsibilities discussed in EHS001, EHS Policy, the responsibilities described below are necessary to ensure the effectiveness of the procedure.
3.1 Department Heads
Department Heads will be responsible for:
- Ensuring that their assigned personnel comply with the qualifications for medical monitoring, training and fit testing, specified in Section 4.1.3, and maintaining documentation of this compliance.
- Ensuring that all uses of respiratory protection conform to the requirements in Section 4.2.
- Requesting support from the EHS Department for evaluating activities to determine if the use of respiratory protection is warranted.
- Forwarding any respiratory protection voluntary use requests to the EHS Department for review and approval.
3.2 Employees
All Fox employees will observe the requirements specified in this Procedure when using respiratory protection
3.3 Environmental, Health and Safety Department
The EHS Department will:
- Develop appropriate standards for the use of respiratory protection operations in all Fox activities.
- Evaluate workplace conditions and activities to identify respiratory protection needs on a task-specific basis.
- Specify when the use of respiratory protection is required for specific tasks, and what type of respirator will be used.
- Review and approve requests for voluntary use of respiratory protection.
- Maintain medical records for Fox employees enrolled in the Respiratory Protection Program.
- Track employee status and notify Department Heads regarding upcoming annual evaluations.
- Coordinate the scheduling of respirator fit-testing and examinations.
- Work with Department Heads to resolve delinquent employee examinations.
- Provide copies of medical restriction recommendations to the Worker’s Compensation Department.
- Review and update this Procedure annually or as necessary to comply with regulatory changes.
4.0 Procedure
4.1 Approval to Use Respiratory Protection
The use of respiratory protection for the control of worker exposures to airborne hazards represents an interim solution to the management of workplace occupational exposures.
Whenever possible, controlling or eliminating workers’ exposures to airborne chemical hazards, is desirable.
In order of preference:
- Product replacement: Eliminate the exposure hazard through elimination of the hazardous material.
- Installation of engineering controls: Use ventilation systems or other equipment to capture/control the hazard to an acceptable level.
- Implementation of administrative controls: Use work procedures or other processes that control exposures to acceptable levels.
The use of respiratory protection represents a last effort at exposure control, and should be viewed as an interim solution, pending implementation of one or more of the above procedures.
- Identification of the need for the use of respiratory protection must be based upon recommendation of the EHS Department, by professional evaluation of potential worker exposures.
- Only the EHS Department may specify a requirement for the use of respiratory protection during Fox activities, and respiratory protection cannot be used without the approval of the EHS Department.
- Any worker may make a request for voluntary use of respiratory protection; however, the request must be approved by the EHS Department prior to implementation.
4.2 Selection of Respiratory Protection
Once the need for the use of respiratory protection is established, selection of the appropriate respirator type will be determined by several factors:
- The type of respiratory hazard (airborne hazardous chemical, oxygen-deficient atmosphere, welding fume, etc.).
- The degree of actual or expected exposure.
- The duration and frequency of the exposure.
These factors will be evaluated by the EHS Department based upon:
- Measurement of the atmospheric conditions.
- Past exposure assessment data.
- Knowledge of conditions expected in the work area.
- The capabilities and limitations of various types of respirators available for use.
All oxygen-deficient atmospheres will be considered to be IDLH.
The appropriate respiratory protection device will be selected by the EHS Department based upon the assigned protection factors found in Table 1, and the following criteria:
- The National Institute for Occupational Safety and Health (NIOSH) must approve any respiratory protection device for use in the intended application.
- No respirator may be used if the assigned protection factor will not reduce the worker exposure to less than one-half (1/2) of the applicable Occupational Exposure Limit (OEL).
- Air purifying respirators may not be used unless a cartridge is available, which is NIOSH-approved for control of the airborne hazard/chemical, and the airborne contaminant presents an adequate warning property to alert the user to breakthrough or inadequate fit of the respirator.
- Air purifying respirators cannot be used for any IDLH atmospheres. (Airline respiratory protection or a self-contained breathing apparatus is required.)
- Air purifying respirators will not be used where the maximum use concentration for an air contaminant exceeds the limitations specified on the NIOSH approval label for the cartridge, canister, or filter for such respirators.
Table 1 – Assigned Protection Factors
Type of Respirator |
Half Mask |
Full Face |
Helmet/ Hood |
Loose-Fitting
|
Powered Air Purifying |
50 |
1,0001 |
1,0001 |
25 |
Air purifying |
10 |
100 |
N/A |
N/A |
Air Line Respirators(Pressure Demand or Continuous Flow) |
50 |
1000 |
1000 |
25 |
Self Contained Breathing Apparatus (Pressure Demand)With Air LineWithout Air Line |
N/A N/A |
2 2 |
N/A N/A |
N/A N/A |
1) Protection factors listed are for high-efficiency filters and adsorbents (cartridges and canisters). With dust filters, an assigned protection factor of 100 is to be used due to the limitations of the filter.2) Positive-pressure respirators are currently regarded as providing the highest level of respiratory protection, and are routinely used for entry into IDLH environments. Where hazardous concentrations can be estimated, an assigned protection factor of no higher than 10,000 may be used upon the approval of the EHS Department.NOTE: For combination respirators, e.g., airline respirators equipped with an air-purifying filter, the mode of operation in use will dictate the assigned protection factor to be applied. |
4.3 Respirator Wearer Qualifications
Any user of respiratory protection must meet the following qualifications:
4.3.1 Medical and Physical Requirements
- Employees who wear respiratory protection must be medically evaluated to ensure that they are able to wear respirators as part of Fox’s Medical Surveillance Program (see EHS 203, Medical Surveillance Program).
- The results of the evaluation will be summarized in a written evaluation of the employee’s ability to wear respirators, and will include limitations, if any.
4.3.2 Training
Respirator protection training will be provided to all employees required to wear respiratory protective equipment. Vendors or other providers can teach training courses, if the course material and trainers are consistent with regulatory standards. On-the-job training (OJT) on respiratory protection may also be given by Fox personnel, if approved by the EHS Department.
4.3.2.1 Training Content
Employees who are qualified to wear respirators must be able to demonstrate knowledge of the following information:
- Why a particular respirator is necessary and how improper fit, usage, or maintenance can compromise the respirator
- What the limitations and capabilities of the respirator are
- How to inspect, put on, remove, and use the respirator
- How the respirator will be stored and maintained
- How to clean the respirator
- How to recognize medical signs and symptoms that might limit or prevent the effective use of a specific respirator
- Discussions of the types of jobs that personnel may perform that require respirators, the hazards for which respirators would be required, and the typical types of respirators
- General content of this Procedure.
Training will also include hands-on use and experience, wearing the specific type of respirator to be used on the job.
4.3.2.2 Training Frequency
- Respiratory protection training will be conducted annually and will be documented.
- The Department Head for all personnel assigned to use respiratory protection will maintain documentation.
- The expiration of training will coincide with the expiration of the employee’s fit test (see Section 4.1.3.3).
- Retraining will be administered if changes to equipment or worksite circumstances are significant and not covered in previous training, or an employee
exhibits a lack of understanding about any of the elements of this Procedure.
4.3.2.3 Fit Testing
- Any employee assigned to use a negative pressure respirator will be fit-tested for use of the respirator prior to initial use, and annually
thereafter, to determine the manufacturer, model, and size of respirator that best fits. - The fit testing must be accomplished, using one of the three accepted qualitative fit test methods.
(Quantitative fit testing may be performed; however, accepted protection factors of respirators will be based solely upon qualitative factors specified in
the regulation):- Irritant smoke
- Isoamyl acetate
- Bitrex
- Porta-Count® (quantitative method).
- The employee will be issued a Fit Test Record (Attachment 1) that indicates the make, model, and size of the facepiece fitted.
- The record will be valid for exactly one (1) year from day of issue.
4.4 Respirator Issue, Maintenance and Storage1
4.4.1 Respirator Issue
Respiratory protection equipment issued for use by Fox employees will be individually provided to each user, who is solely responsible for its use and care.
The use of “group” respirators is not permitted.
The following requirements will apply to all respirator issue/use:
- The employee will be issued only the manufacturer’s model and size respirator for which he/she has been trained and fit tested.
- Only employees who have been trained, fit tested, and medically qualified in accordance with this Procedure will be issued a respirator.
4.4.2 Maintenance, Inspection, and Storage
4.4.2.1 Cleaning and Disinfection
Respirators must be cleaned after each use. Use a cleaner/disinfectant that is made for respirator cleaning.
Under no circumstances, will any alcohol-containing cleaner be used.
- Do not clean with solvents.
- Use a brush and warm water.
- Wash with a mild dish detergent or a combination of detergent and disinfectant.
- Rinse with clean water, or rinse once with a disinfectant and once with clean water.
- The clean water rinse removes excess detergent or disinfectant that can cause skin irritation or dermatitis.
- Dry on a rack, clean surface, or hang from a clothesline.
- Position the respirator so that the facepiece rubber will not “set” crookedly as it dries.
4.4.2.2 Inspection
- Workers using respirators might be required to install or change cartridges on respirators.
- Workers will inspect each respirator prior to each use to ensure that it is in proper working condition.
- Workers will immediately report problems found during these inspections to their supervisor.
- Worker inspections will be performed according to the respirator manufacturer’s recommendations.
4.4.2.3 Storage
- After cleaning, store the respirator in a clean, sealable plastic bag, ensuring nothing is stored on top of the respirator, which could crush or damage it.
- When storing rubber full-face respirators, do not pull the head strap over the lens, as the antioxidant in the rubber can damage the lens.
- All respirators will be stored in a manner that protects them from damage, dust, sunlight, extreme temperatures, excessive moisture, or damaging chemicals.
- Facepieces cannot be stored for more than two weeks at temperatures less than thirty-two (32) degrees F (°F) or greater than one hundred twenty (120) degrees F (°F).
- For air purifying respirators, adsorbent-containing cartridges must be stored in plastic bags that are sealed and intact. Properly stored adsorbent cartridges have a shelf life of three (3) years.
- Particulate matter (filter) cartridges do not have to be stored in plastic bags and have no shelf life limit.
4.4.2.4 Maintenance
- The only on-site maintenance allowed for respirators is:
- The changing of cartridges
- Inspection of the respirator for defects
- Cleaning.
- Personnel specifically trained by the manufacturer can only perform replacement of respirator parts.
- Only the manufacturer’s NIOSH-approved parts designed for the equipment will be used.
4.5 Respirator Use
4.5.1 General
To provide protection from inhalation of airborne contaminants, respirators must be properly used.
The following will be adhered to at all times:
- All parts supplied with the respirator (including the air hose that connects to the respirator) are specifically approved as a unit.
- Only the employee to whom it is issued and fit tested will use a respirator.
- Only employees with current training, fit test, and medical approval will wear any respirator.
- Personnel will inspect the respirator prior to each use to ensure that it is not defective.
- Negative pressure respirators must not be worn where conditions prevent a good seal.
This includes:
- Facial hair that might interfere with the seal or the working of the respirator
- Beards, goatees, or other facial hair, which might affect the respirator seal, are prohibited.
- Scars that might cause leakage between the face and facepiece
- Use of eyeglasses
If a worker must wear vision correction, lenses fitted to the spectacle frame that are the make and model specific to the facepiece worn, will be used.
- Any other condition that prevents a good seal, such as donning a respirator after putting on a hood.
- The hood could protrude into the sealing area.
6. Employees must not wear personally owned respirators when performing work.
4.5.2 Air Purifying Respirators
The following requirements will apply to all use of air purifying respirators by Fox personnel:
- It is critical that air-purifying respirators have the appropriate cartridges attached for the contaminant(s) of concern; otherwise, the respirator
will not protect the employee. - When using air-purifying respirators with chemical cartridges, if an odor is noted, or if irritation results, exit the work area, and replace the
cartridges. - When using air-purifying respirators with particulate matter filters, replace the filters when breathing becomes difficult.
- Chemical cartridges shall be discarded if odor or irritation is noted.
- Chemical cartridges must not be used after the manufacturer’s expiration date.
4.6 Voluntary Use Respirators
Employees may choose to voluntarily use a company-provided respirator when the EHS Department has determined that such use will not in itself create a hazard. Should an employee wish to receive a respirator for personal use, they must complete the Voluntary Respirator Use Request Form located here. Once completed and reviewed by the EHS Department, they will be provided an appropriate and authorized respiratory protective device.
Supervisors are responsible for ensuring the requesting employee use care for the respirator properly. Medical evaluations are not required for voluntary users of paper, filtering face piece respirators. Fit testing is not required for voluntary use of any respirator.
5.0 REFERENCES
EHS 001, EHS Policy
EHS 204, Medical Surveillance Program
Occupational Safety and Health Administration Video – Voluntary Use Respirators
6.0 ATTACHMENTS
Attachment 1 – Fit Test Record
Attachment 2 – Medical Evaluation Questionnaire.
[1]
This requirement pertains to any voluntary use of respiratory protection, as well any EH&S Department-specified use.