1910.134(c)(3) requires employers to designate a person as the respiratory protection “program administrator” and to ensure that this person is qualified to perform the responsibilities of this position. The person can be qualified either by appropriate training or experience or both. The administrator is also the person responsible for evaluating the program, as stated in paragraph (c)(3). The training requirements and experience level necessary for the program administrator were the subject of substantial comment. OSHA proposed that the program supervisor be a person “qualified by appropriate training and/or experience” to be responsible for the respirator program.
OSHA discussed these qualifications in the preamble to the NPRM at 59 FR 58898-58899. That proposal discussion reiterated many of the points that are described above: that the level of training appropriate for a workplace with limited respirator use would be quite different from another with extensive use of different respirator types, and that the program administrator can work with a workplace respirator committee, or assign responsibility for portions of the program to industrial hygienists, safety professionals, or other respirator experts while retaining overall responsibility for the program. In other words, the level of training of the program administrator must be adequate to deal with the complexity of the respirator program.
Specifying in detail the type and extent of training required for program administrators depends upon the type of workplace and is best left to the employer, in OSHA’s opinion. For example, the level of training that would be appropriate for a workplace with limited respirator use would be quite different from that required at another workplace with extensive respirator use for IDLH atmospheres, highly toxic chemicals, or other complex respirator use operations. Therefore, OSHA adopted a definition of training and experience that uses performance language and is similar to the ANSI Z88.2-1992 standard’s requirement. However, OSHA does require employers to ensure that the level of training for the respirator program administrator is adequate to deal with the complexity of the workplace. In keeping with this approach, OSHA has NOT established any one training program, such as the NIOSH respirator course, as the level of training program administrators must achieve. OSHA believes that NIOSH’s course is excellent, and therefore more than sufficient in most cases.
The final standard continues to require that a person qualified by training or experience be designated to be responsible for the overall management and administration of the program to ensure that the integrity of the respiratory protection program is maintained through the continuous oversight of one responsible individual. The program administrator may serve largely in an oversight and coordination role between the various subunits or departments that perform duties in support of the respiratory program. Regardless of the number of subunits, each employer must ensure that all subunits report to one overall program administrator for coordination of the program. The program administrator can use the assistance of industrial hygienists, safety professionals, or other respirator experts to help run the respirator program. The program administrator can work with a committee or assign responsibility for portions of the program to other personnel, but the overall responsibility for the operation of the program must remain with the designated program administrator. This approach promotes coordination of all facets of the program. For large companies or multiple worksites, the program administrator can delegate to a qualified person the responsibility for the day-to-day operation of the program at a specific site or for a specific activity. However, coordination between different worksites is an important aspect of the operation of a good program; therefore, ensuring implementation of the overall respirator program remains the duty and responsibility of the program administrator. For small and moderate sized employers, OSHA believes that the duties of a program administrator will require only a small part of one employee’s time.
Source: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=PREAMBLES&p_id=1053