OSHA 1910 Safety Standard and Respirator Training

By Diane M. Calabrese / Published May 2021

Grab, don, and dash. That works with a knit cap or winter scarf.

But with a respirator? No. Employees required to wear respirators must be properly fitted and medically evaluated to ensure they can tolerate the device. Therein are two protocols in OSHA standards for respiratory protection (1910.134 in 29 CFR).

OSHA provides abundant help with standards. And the eTool for Respiratory Protection at https://www.osha.gov/SLTC/etools/respiratory/respirator_basics.html is a must-have as basic reference about 1910.134.

Subsections of 1910.134 describe selection of the device, medical evaluation of the wearer, fit-testing, use, maintenance, air quality, and training. The standard also has an appendix on user seal-check procedures, a check that is mandatory.

Everyone who uses a respirator on a jobsite must be trained in safe use. That includes those who voluntarily wear a respirator when the device is not required.

Perhaps the biggest challenge for any employer is determining who needs respiratory protection. For one, it is most definitely not just contractors.

“Identifying when a respirator is required or not required can be difficult,” says Leighton Light, GSP, safety manager and water treatment sales at Chappell Supply and Equipment in Oklahoma City, OK. “I use the product’s SDS (safety data sheet), specifically section eight, Exposure Controls/Personal Protective Equipment, to help me identify when a respirator is needed.”

The SDS is a “starting point to help you identify whether a respirator is to be used with the product or not,” says Light. He explains that the full scope of the activity at a company will determine respirator usage.

“Our company is a distributor and manufacturer of multiple products that are used in the industrial cleaning industry,” explains Light. “A small number of our company’s chemicals require respiratory protection when working with, handling, or applying these specific products.”

Light, who leads the respirator training program at his company, offers two recommendations on how to get started. One is to become familiar with 29 CFR 1910.134. “It will help you understand terminology and minimum mandatory compliance guidelines.”

Also turn to “another great resource,” says Light. That is ANSI 88.2 “to find best practices for proper use and performance of respirator protection.” 

Respirator training is “active because of the work being performed here in our facility,” says Light. “We have a small number of employees who require the use of half-face respirators because they work with chemicals. Respirator training and fit testing for our half-face respirators in performed annually per standards set in 1910.134.”

A respirator must be matched not only to the person using it but also to the environment in which it will function. “The most challenging part of a respirator program is identifying the specific type of respirator and what type of cartridge or cannister is needed for your specific application,” says Light.

“Respirators are commonly available in quarter-face, half-face, or full-face styles,” explains Light. “Cartridges have a specific purpose—to filter out the specific contaminant you are trying to filter out.”

Manufacturers of respirators aim to simplify choices, and Light gives us one example.

“The specific colors on the box or cartridges correlate with organic vapors, acid gases, pesticides, carbon monoxide, etc.,” says Light. “There are charts you can find online to help find the specific cartridge you need for your application.”

Training Assistance

Not every company has a safety officer in house who can do training. Professional organizations and consultancies help those who do not.

“The PWNA has established a respirator safety program for the industry,” says Michael Draper, director of compliance and safety for the Pressure Washers of North America. “Also, Expert Safety Services has a respirator program as well.”

Complexity was introduced into the respirator sphere in 2020. In addition to the ongoing need for contractors to learn about respirator function, cartridge life, need for documentation, and more, competition for devices became keen. 

“The issues with ongoing need for training remain, and the pandemic has not helped with the issue with respirators, cartridges, and even N-95s becoming hard to come by,” says Draper. “The issue is further
complicated by people in the industry not having a full understanding of advice they give.”

Draper cites three areas where understanding must be improved. They are “nuisance levels versus non-nuisance, assigned protective factors versus permissible exposure limits, and what constitutes a respirator and what doesn’t.”

Clarity is the goal of safety experts. “There is bad advice being given in the industry,” says Draper, “so further education is needed. That’s why the PWNA remains vigilant in the areas of safety and compliance.”

Indeed, the vigilance spans all expectations established by OSHA
in 1910. In October, when Draper last responded to some questions from us, he had recently sought clarification from OSHA concerning OSHA 1910.27 (scaffolds and rope descent systems). 

“OSHA has not yet responded to the PWNA concerning clarification on the differences between industrial rope access and rope descent systems,” says Draper. “However, they did respond to IWCA on the matter.”

The response to IWCA emphasized rope access is not exempt from OSHA requirements. (See letter to Stefan Bright, safety director at the International Window Cleaning Association via https://www.osha.gov/laws-regs/standardinterpretations/2020-05-21.)

“Rope access work does have to follow guidelines laid out in OSHA 1910.28-29 and 1910.140,” explains Draper. “So, while they aren’t working under 1910.27, they are not exempt from the standard.

“The second concern was whether if claiming rope access a person didn’t have to follow anchorage requirements as laid out under 1910.27,” continues Draper. “Again, OSHA stated that 1910.140 was in play and 1910.140 lays out the requirements for anchorages.”

[The OSHA subparts cited by Draper are 1910.27—scaffolds and rope descent systems, 1910.28—duty to have fall protection and falling object protection, 1910.29—fall protection systems and falling object protection criteria and practices, 1910.140—personal fall protection systems.]

A reply to PWNA will be welcome. “It is the hope that OSHA will indeed answer the questions posed to them by the PWNA, as there were other questions we laid out that would help clarify work methods,” says Draper. 

Standard 29 CFR 1910

Many subparts of OSHA’s 1910 standard apply to members of our industry. Training in the elements of the subpart D (walking-working surfaces) involving ladders (1910.23) and 1910.27 to 1910.29, and the subpart I (personal protective equipment) that includes 1910.134, can be complicated. Use of PPE for head (1910.135), feet (1910.136), etc. may be more straight-forward. Nevertheless, training and documentation must be done.

Standard 1910 is big, if not vast. Everything from exposure to occupational noise, 1910.95, to hazardous materials, 1910 subpart H, is included; and the standard can and does expand.

Members of our industry take many approaches, often overlapping, to ensure their employees are safe. In some cases, company owners serve as teachers and trainers for other companies. 

Jorge S. Aguilar, CEO of Empire Highrise USA in Kansas City, MO, has a commitment to safety that motivated him to earn many certifications. He is a certified safety instructor for IWCA, and he is also a trainer at Expert Safety Services.

“Safety is my passion. It is taken very seriously in our shop, during training, and in the field,” says Aguilar. He emphasizes that he wants his team to know how to work safely. His commitment to keeping em-
ployees focused on safety inspired him to teach others.

Following all OSHA guidelines keeps employees safe, explains Aguilar. Adherence to standards bolsters the entire team. Employees must “know the regulations to keep each other safe,” says Aguilar.  “Our company has created a written training manual that we follow daily during training in order to make sure we don’t miss anything.”

Documentation is part of the process. “The training is documented daily in order to log hours on rope in shop,” says Aguilar. “Once team members go in the field, this documentation continues on a daily basis.”

Although OSHA 1910 is a huge standard, the technical assistance provided alongside each subpart is good. Definitions (1910.134(b)) of respirators in https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=STANDARDS offer a quick immersion in terms like canister or cartridge (the container with filter or sorbent or catalyst or combination), components that remove specific contaminants from air passing through the container.

In addition to definitions, the same document offers guidance on qualifications for individuals fitting respirators, the difference between quantitative fit tests and qualitative fit tests, and maintenance and care of respirators. Charts condense protective attributes of quarter mask, half mask, full facepiece, helmet, and loose fitting facepiece. And details on cleaning, disinfecting, and storing respirators are provided.

Proper maintenance and care of respirators is essential. Respirators, like all PPE, keep employees safe
only when used correctly. If a respirator is soiled or not maintained, it could become a hazard to the user.

There is one type of respirator not uniquely matched to an individual. It is an escape-only respirator, which is grabbed and put on during emergency exits or in dire situations. 

Everyday use of respirators requires a device matched to conditions and fitted with precision. Application of a respirator in slapdash fashion leads to trouble—interesting old movies using the scenario aside.