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Personal Protective Equipment Policy
In accordance with the requirements of the Amherst College Environmental Health & Safety Policy, OSHA 29 CFR 1910.132, 29 CFR 1910.134 and 29 CFR 1910.139 the following guidelines have been established to control occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, vapors and/or oxygen deficiency. Engineering controls such as local or general ventilation or substitution with a less harmful material shall be used whenever possible to mitigate the above referenced hazards. If these controls are not feasible, immediately available or not completely adequate then the use of NIOSH approved respirators, under the supervision of the Respiratory Program Administrator can be used.
Amherst College shall provide approved respiratory protection as part of this written respiratory protection program to any employee who, because of their occupation, has been assigned or required to wear this type of personal protective equipment. Respiratory protection, according to OSHA includes but is not limited to;
- air-purifying respirators
- demand respirators
- dust masks (filtering facepiece)
- escape-only respirators
- negative pressure respirators
- ½ face
- full face
- powered air purifying respirators (PAPR)
- pressure demand respirators
- self contained breathing apparatus (SCBA)
- supplied air respirators (SAR)
- Physician or Licensed Health Care Professional
- Respiratory Protection Program Administrator
- Respiratory Protection Program
- Medical Evaluation
- Fit Testing
- Respirator Use
- Training and Information
- Air-purifying respirator - a respirator with an air purifying canister, cartridge or filter that is designed to remove specific contaminants from the air through the air purifying element.
- Canister or cartridge - a filter, sorbent or catalyst, or combination thereof which is designed to remove specific contaminants from the air.
- Demand respirator - an atmosphere supplying respirator that admits breathing air to the facepiece only when a negative pressure within the mask is created by inhalation.
- Dust mask (filtering facepiece) - a negative pressure particulate respirator with a filter that is actually part of the facepiece or with the entire facepiece composed of the filtering medium.
- Employee exposure - exposure to a concentration of an airborne contaminant that would occur if the employee were not wearing respiratory protection.
- End-of-service-life indicator (ESLI) - a system that warns the respirator user about the end of life for the canister, cartridge or filter attached to the respirator or those in stock. The ESLI could be an expiration date, saturation level, change of color indicator or as deemed necessary by the Respiratory Program Administrator.
- Escape only respirator - a respirator designed to be used only for emergency exit
- Filter - part of the respirator that is designed to remove contaminants from the air
- Fit factor - a quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in the ambient air to its concentration inside the respirator when worn.
- Fit test - a protocol used to evaluate the fit of a respirator on an individual.
- High efficiency particulate air (HEPA) - a filter that is at least 99.97% efficient to remove particles from the air of 0.3 micrometers in diameter of larger. HEPA filters are classified as N100 (non oil resistant), R100 (oil resistant) or P100 (oil proof).
- Immediately dangerous to life and health (IDLH) - an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individuals ability to escape from a dangerous atmosphere.
- Negative pressure respirator - a respirator in which air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator
- Oxygen deficient atmosphere - oxygen level in the atmosphere is below 19.5%.
- Physician or Licensed Health Care Professional (PLHCP) - an individual who is legally permitted to provide some or all of the health care services.
- Positive pressure respirator - a respirator in which the pressure inside the facepeice exceeds the ambient air pressure outside the respirator.
- Powered air purifying respirator (PAPR) - a respirator that uses a blower to force the ambient air through the air purifying canister, cartridge or filter.
- Pressure demand respirator - a positive pressure atmosphere supplying respirator that admits breathing air to the facepiece when the positive pressure is reduced inside the facepiece by inhalation.
- Qualitative fit test (QLFT) - a pass fail fit test to assess the adequacy of the respirator fit that relies on the individual's response to the test agent (i.e. irritant smoke).
- Quantitative fit test (QNFT) - assessment of the adequacy of the respirator fit by numerically measuring the amount of leakage into the respirator.
- Self contained breathing apparatus (SCBA) - an atmosphere supplying respirator for which the breathing air source is designed to be carried by the user.
- Supplied air respirator (SAR) - also known as an air line respirator is an atmosphere supplying respirator for which the source of air is not carried by the user.
- Tight fitting facepiece - a respirator that forms a complete seal with the face.
- User seal check - an action used by the respirator user to determine if the respirator is properly seated to the face.
In accordance with the regulatory requirements, Amherst College must identify a Physician or other Licensed Health Care Professional to perform medical evaluations using a medical questionnaire or an initial medical examination to obtain the necessary medical information about the potential respirator user.
- The PLHCP is: Dr. Alan Calhoun, UMass Health Services Director
As is required by OSHA, the Amherst College Respiratory Protection Policy Administrator must be specifically identified by name not title. The individual must be qualified by appropriate experience or training to oversee the respiratory protection program and conduct the required evaluations of program effectiveness. The program administrator need not be the Physician or Licensed Health Care Professional, hereafter referred to as the PLHCP.
- The Program Administrator is: Richard A. Mears, Environmental Health & Safety Manager.
Amherst College has developed and implemented this written respirator program with required work site specific procedures and elements to better protect our employees from occupational diseases caused by the breathing of contaminated air, or the lack thereof. If necessary, because engineering controls are non-existent or not feasible, and when substitution of a less hazardous material is not practical, the Policy Administrator shall provide the employee with a NIOSH approved respirator.
The respirator program shall be updated annually or as necessary to reflect any changes in the workplace conditions that effect respirator use. Amherst College shall include the following as part of our respiratory protection policy:
- procedures for selecting respirators
- medical evaluations of those employees required to wear respirators
- fit testing procedures
- proper use under emergency conditions
- cleaning, disinfecting, inspecting, maintenance and storage procedures
- procedures to ensure adequate flow, quality and quantity of breathing air
- training for employees specific to their line of work and potential hazards
- training for employees in the proper use of respirators
- procedures to effectively measure program effectiveness
- Amherst College is not obligated to include those employees that are not required to wear a respirator in the written respiratory protection program. However, if the employee chooses to request a non-mandated respirator, including a dust mask from the college, or they opt to bring in their own respirator, the college must ensure that the respirator will;
- not create a hazard for the user
- be cleaned, maintained and stored properly
- be worn by an employee who is medically able to use it.
- Amherst College must provide the approved respirators, training and medical evaluations to any employee who is required to wear them, at no cost.
The Amherst College Respiratory Protection Policy Administrator has identified the following occupations for respirator use;
- Any individual who has been assigned the task of cleaning up blood and other body fluids. This would include but is not limited to;
- CPR / First Aid Providers
- Custodial staff
- Environmental Health & Safety
- Emergency Medical Services Personnel
- Police Officer(s)
- Carpentry Shop Staff
- Environmental Health & Safety Mgr.
- Grounds personnel applying, mixing or otherwise using pesticides
- Mechanical Shop Staff
- Paint Shop Staff
The Respiratory Protection Program Administrator shall identify and evaluate respiratory hazards at each specific work site to determine if proper engineering controls or substitutions were attempted and/or to select the proper type of respiratory protection for the potential user. Amherst College shall provide the appropriate NIOSH approved respirator for the hazard to which the employee is exposed. The evaluation must include a list of respiratory hazards, potential harms and the length of time to which the employee may be exposed.
If the program administrator can not identify the hazard or potential hazard, Amherst College shall consider the atmosphere to be unknown, and as such shall treat the area as a worst case hazard utilizing the guidelines of a material considered to be IDLH.
Amherst College shall, whenever possible, provide the employee with a powered air purifying respirator (PAPR). The PAPR, unlike a negative pressure respirator, if not worn more than 30 days throughout the year does not require annual medical evaluations and will provide better protection for the user. Should the required respirator user opt for either a ½ face or full face negative pressure respirator instead of the PAPR they will be required to get a medical examination, annually. Amherst College currently does not provide our employees with a supplied air or self contained breathing apparatus for IDLH atmospheres including those that are oxygen deficient, below 19.5%. Therefore, any IDLH or potential IDLH atmospheric conditions must be reported to the Environmental Health and Safety Manager, through the Amherst College Campus Police Department. For these atmospheric hazards, the Amherst Fire Department will most likely be summoned.
All air purifying respirators provided by Amherst College including ½ and full face negative pressure respirators and PAPR's can, with proper training be used to work around some chemicals, cleaning agents, asbestos and lead. Others, such as the dust and Tuberculosis (TB) masks have limited uses and must not be used for unapproved work activities. Care must be used when working with dust masks (filtering facepieces) in most cases they are not approved.
Respirators, canisters, cartridges and filters, if not equipped with an end-of-service-life indicator or ESLI must have a change schedule implemented by the program administrator. The change schedule should correspond to the following guidelines. The canisters, cartridges and filters should be changed;
- if they become plugged and breathing is made more difficult
- if they become wet
- if the expiration date has passed or the color indicator identifies saturation levels, or
- every 6 months, unless protected and infrequently used
Amherst College must provide the employee with a medical evaluation to determine if they are physically able to use a respirator, dust or TB mask. The employee must complete the medical evaluation before they can be fit tested for any type of respirator. The medical evaluation can be performed in one of two ways;
- a medical questionnaire given to the employee by the program administrator, which is then turned over to the PLHCP for review, or
- a full medical examination performed by the PLHCP or their designee
- Follow-up medical examinations are provided to any employee that the PLHCP deems necessary. The follow-up should include consultations, diagnostic procedures and medical tests that the PLHCP has determined are necessary in order for them to make the necessary final decision on whether or not a potential user can make use of a respirator.
The medical questionnaire and/or examinations shall be administered confidentially during the employee's normal working hours or at a time and place convenient to the employee. The questionnaire must be easy to understand. Amherst College must provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP.
Amherst College shall, before any fit test or work is started obtain a written recommendation from the PLHCP about the employee's ability to utilize a respirator. The following information is required to be part of the PLHCP's medical determination;
- whether or not there is limitations on respirator use by the employee for medical reasons
- the need if any for a follow-up medical evaluation(s)
- a statement that the PLHCP has provided the employee with a copy of the medical assessment and recommendations
Additional medical evaluations may be needed or required, if;
- the user reports medical signs or symptoms that may be related to the use of the respirator.
- deemed necessary by the supervisor, PLHCP or the program administrator
- a change occurs in working conditions.
- Seasonal and temporary workers are not exempt from the requirement for medical evaluations. If they are to wear respirators as part of their work, the medical examination is required.
- If any employee refuses to undergo a medical examination by the PLHCP prior to a fit test, the employee will not be able to use a respirator.
Before an employee can don or work with a respirator, OSHA requires that they have to be medically evaluated by the PLHCP.
- If approved by the PLHCP to wear a respirator, the program administrator can now fit test the employee with a negative or positive, tight-fitting facepiece.
- the fit test must be performed by the program administrator using the same make, model, style and size of respirator that will be utilized by the employee.
- the fit test must pass either a qualitative or quantitative test method as stipulated by the program administrator.
- the fit test must be re-administered, if the employee reports, or the PLHCP, supervisor or program administrator makes visual observations of, changes in the employees physical condition that could affect respirator fit
- For monetary reasons, and because Amherst College will not be sending personnel into an IDLH atmosphere, the program administrator has opted to use the qualitative fit test for all Physical Plant employees. A protection factor of 10 is all that is needed regardless of whether we utilize negative pressure or PAPR type respirators. Saccharin Solution, Irritant smoke such as stannic chloride or Bitrex (Denatonium Benzoate) can be used for the qualitative fit test.
If an employee of Amherst College is required to wear a respirator, the Policy Administrator will provide the wearer with the most comfortable approved respirator for that particular employee. However, it will be the responsibility of the employee and their supervisor to make sure that the respirator is being utilized for the assigned type of work and corresponding hazards. The employee shall not remove the facepiece in a hazardous atmosphere. They shall take all necessary steps to insure that they maintain a healthy and safe working environment for themselves as well as their co-workers.
- Amherst College, through the program administrator shall not permit respirators with tight-fitting facepieces to be worn by employees who have:
- facial hair that comes between the sealing surface of the respirator and the face of the user
- any condition that adversely affects the proper face-to-facepiece seal of the respirator
- Corrective lenses, such as prescription glasses can be attached to the facepiece of a full-face negative pressure respirator or worn under protective goggles.
- Contact lenses, unless used with either a PAPR or full face respirator must can not be utilized.
Whenever the employee dons a respirator, they shall perform a positive and negative test of their mask referred to as a "user seal check". The user seal check is done to verify that the respirator has been able to provide a proper seal around the users face so that air contaminants can not pass through. Although not a fool-proof system, the user seal check will identify any leaks or potential deficiencies in the facepiece.
- If the user encounters any deficiencies, leaks or missing parts they should take the respirator out of service and notify the Program Administrator. The administrator shall purchase and replace any missing or damaged parts, or replace the respirator in its' entirety.
The respirator user shall clean and disinfect their respirator after each use to remove moisture and any potential contamination.
- The program administrator as necessary will provide cleaning supplies and training.
- After cleaning and disinfecting has been completed, the user shall properly store the respirator to protect it from contamination, damage, dust, extreme heat, excessive moisture, chemicals and the cold.
- Follow manufacturers specifications for storage instructions
Canister, cartridge and filter replacement shall be the responsibility of the Program Administrator. The filters will meet the requirements for the new HEPA type now referred to as P100.
- Personnel looking for new cartridges should contact the program administrator as soon as possible for replacements.
Amherst College will provide all of the necessary and required training to employees that are required to wear any and all types of respirators including dust and TB masks. The training will be comprehensive, understandable and will re-occur annually, as required. The instruction will include;
- how the respirator is to be used
- proper fit, usage and maintenance
- respirator limitations
- how to inspect, don, remove and use the respirator
- how to identify the signs and symptoms of personnel in distress
All records for the Amherst College Respiratory Protection Guidelines will be kept in the office of Environmental Health & Safety or with the PLCHP, as required. Medical determinations by the PLHCP, fit tests, respirator types and filters and a copy of the program will be kept in the office referenced above. All medical questionnaires and examination results will be kept by the PLHCP as required by local, state and federal regulations.
Amherst College can not maintain a copy of the employee's completed medical questionnaire.
It is the responsibility of each and every supervisor to oversee the implementation and enforcement of this guideline. The Director of Facilities Planning and Management, the Assistant Director for Operations, the Environmental Health and Safety Committee and the office of Environmental Health and Safety have implemented this program for reasons of safety, health, and liability.