Many of us manage a Respiratory Protection Program for all types of respirators and many types of hazards. What many programs lack is the annual evaluation of the program and its execution. The written program should contain information on how and who will perform this evaluation and although the standard does not state this evaluation be done annually, I would strongly suggest this frequency. Let’s take a look at what is required…
1910.134(l) Program evaluation.
This section requires the employer to conduct evaluations of the workplace to ensure that the written respiratory protection program is being properly implemented, and to consult employees to ensure that they are using the respirators properly.
1910.134(l)(1) The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
1910.134(l)(2) The employer shall regularly consult employees required to use respirators to assess the employees’ views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. Factors to be assessed include, but are not limited to:
1910.134(l)(2)(i) Respirator fit (including the ability to use the respirator without interfering with effective workplace performance);
1910.134(l)(2)(ii) Appropriate respirator selection for the hazards to which the employee is exposed;
1910.134(l)(2)(iii) Proper respirator use under the workplace conditions the employee encounters; and
1910.134(l)(2)(iv) Proper respirator maintenance.
The CSHO will evaluate how well the written respiratory protection program is being implemented in the workplace. Any observed deficiencies in the program and evaluation procedures should be discussed with the program administrator to determine what previous efforts she or he may have made to evaluate how well the employer’s program was working. Deficiencies should also be discussed with employees to determine how long any deficiency has existed and what requests or complaints about the respiratory protection program if any, they have made to the program administrator. If the program administrator keeps a written assessment, implemented changes may be considered as efforts toward improvement. Recent changes in the workplace such as new processes should have been evaluated for necessary respiratory protection program changes.