Does OSHA require an “individual” be appointed as the “respiratory protection program administrator,” or can the written respirator program state the “safety department,” “EHS Department,” or “safety team members” are the program administrator?
It is actually pretty common to find written respirator programs that list “the safety department” as the program administrator; however, this does not make it right. I always like to reference the Respirator Standard Compliance Directive, which states the following about the program administrator…
A “respiratory protection program administrator” is required to oversee and evaluate the respirator program. This individual must be suitably trained and have the appropriate accountability and responsibility to manage the full respiratory protection program. Companies with multiple worksites may have a program administrator at each worksite, as long as this person is qualified and retains the accountability and responsibility for the day-to-day operation of the specific program for that site. Alternatively, a company may opt to have one program administrator for several sites and/or one program for several similar sites as long as the program contains the necessary elements and addresses the hazards at those sites.
Also, remember that just because someone is assigned to the “safety department” does not make them a defunct respirator administrator. These days, we see a lot of “EHS Departments” that have employees who do not wear respirators and are certainly not qualified to be program administrators.
The extent of training or experience required for the program administrator will vary based on the complexity of the respiratory hazards in the workplace. Where significant program deficiencies are discovered, compliance officers should discuss questions about the program with the program administrator to determine how familiar she or he is with respirators, the hazards in the workplace, respirator use in the facility, the respirator standard, and the company’s respirator program.