ABSTRACT

By and Under the Authority of
Charles Jeffress
Assistant Secretary

TABLE OF CONTENTS

ABSTRACT

TABLE OF CONTENTS

1. Purpose

2. Scope

3. References

4. Action

5. Federal Program Change

6. Background

7. Inspection Guidelines for the Standard on Respiratory Protection, 29 CFR 1910.134.

   1. Scope and Application
   2. Permissible Practice - 1910.134(a)(1) and (a)(2)
   3. Definitions-1910.134(b)
   4. Respiratory Protection Program-1910.134(c)(1)
   5. Selection of Respirators and Hazard Evaluation-1910.134(d)
   6. Medical Evaluation - 1910.134(e)
   7. Fit Testing-1910.134(f)
   8. Use of Respirators
   9. Maintenance and Care of Respirators - 1910.134 (h)(1)
   10. Breathing Air Quality and Use 1910.134 (i)
   11. Identification of Filters, Cartridges, and Canisters 1910.134 (j)
   12. Training and Information 1910.134 (k)
   13. Program Evaluation 1910.134(l)
   14. Recordkeeping - 1910.134(m)
   15. Dates 1910.134 (n)
   16. Appendices

8. Interface with Other Standards

9. Classification and Grouping of Violations.

10. Authorization to Review Limited Medical Information.

11. Training for OSHA Personnel.

12. Medical Examinations for OSHA Personnel

13. Protection of OSHA Personnel

APPENDIX A.

CHANGE SCHEDULES GUIDE - A LISTING OF METHODS

INDEX

1. Purpose. This instruction establishes agency interpretations and enforcement policies, and provides instructions to ensure uniform enforcement of the Respiratory Protection Standard, 29 CFR 1910.134.

2. Scope. This instruction applies OSHA-wide.

3. References

   1. OSHA Instruction, CPL 2.103, Field Inspection Reference Manual, September 26, 1994.

   2. OSHA Instruction CPL 2.100, Inspection Procedures for the Permit Required Confined Space Standard, May 5, 1995.

   3. OSHA Instruction CPL 2.111, Citation Policy for Paperwork and Written Program Violations, November 27, 1995.

   4. OSHA Instruction, CPL 2-2.30, Authorization of Review of Medical Opinions, November 14, 1980.

   5. OSHA Instruction, CPL 2-2.32, Authorization of Review of Specific Medical Information, January 19, 1981.

   6. OSHA Instruction, CPL 2-2.33, Rules of Agency Practice and Procedure Concerning OSHA Access to Employee Medical Records-Procedures Governing Enforcement Activities, February 8, 1982.

   7. OSHA Instruction, CPL 2-2.46, Authorization and Procedures for Reviewing Medical Records, January 5, 1989.

   8. OSHA Instruction CPL 2-2.59A, Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, April 24, 1998.

   9. OSHA Instruction, PER 8-2.4, CSHO Pre-Employment Medical Examinations, March 31, 1989.

   10. OSHA Instruction, PER 8-2.5, CSHO Medical Examinations, March 31, 1989.

   11. 29 CFR 1910.134, Respiratory Protection Standard.

   12. NIOSH Respirator Certification Requirements 42 CFR 84 and 30 CFR 11.

   13. 1992 American National Standards Institute (ANSI) Z88.2 Respirator Standard.

4. Action. OSHA Regional Administrators and Area Directors shall use the guidelines in this instruction to ensure uniform enforcement of the Respiratory Protection Standard, 29 CFR 1910.134.

5. Federal Program Change. This instruction describes a Federal Program Change for which State adoption is not required. NOTE: In order to effectively enforce safety and health standards, guidance to compliance staff is necessary. Therefore, although adoption of this instruction is not required, States are expected to have standards, enforcement policies and procedures which are at least as effective as those of Federal OSHA.

6. Background. In 1971, OSHA adopted the ANSI standard Z88.2-1969, "Practices for Respiratory Protection," as well as ANSI Standard K13.1-1969, "Identification of Gas Mask Canisters" as its standard for respiratory protection. In April of 1971, OSHA promulgated 29 CFR 1926.103, the initial respiratory protection standard for the construction industry. On February 9, 1979, OSHA announced that 29 CFR 1910.134 would be formally recognized as also being applicable to the construction industry (44 FR 8577).

   On November 15, 1994, OSHA issued a Notice of Proposed Rulemaking to revise 29 CFR 1910.134. Public hearings were held in 1995, and the Final Rule was published in the Federal Register on January 8, 1998. The new standard updates the previous standard and incorporates new technology and current scientific knowledge regarding respiratory protection. Application of the requirements of the new standard in affected workplaces will promote more effective use of respirators and provide greater compliance flexibility. Language in the new standard has been developed to make some requirements in the previous standard more understandable. On April 23, 1998, corrections to the regulatory text were published in the Federal Register.

   The new respiratory protection standard also makes the respiratory protection provisions of other health standards consistent with each other and with the final rule. This will make these provisions easier to administer.

   The prior Respirator Standard, 1910.134, remains in effect until October 5, 1998, the date when employers must be in compliance with the new standard. On October 5, the prior 1910.134 will be retained, but re-designated as 1910.139. It will apply only to respiratory protection against M. tuberculosis (TB) until OSHA has promulgated the final standard for Occupational Exposure to Tuberculosis.

   *On October 5, the prior 1910.134 was retained, but re-designated as 1910.139. It applied only to respiratory protection against M. tuberculosis (TB) until OSHA withdrew promulgation of a final standard for Occupational Exposure to Tuberculosis on December 31, 2003. At that time OSHA also revoked 1910.139. Effective January 1, 2004, employers, who have employees required to wear respirators for protection against TB, must also be in compliance with the new standard.*

7. Inspection Guidelines for the Standard on Respiratory Protection, 29 CFR 1910.134. These guidelines relate to specific provisions of 29 CFR 1910.134 and are provided to assist compliance officers with conducting inspections where the standard may apply. Any subparagraphs of the standard not discussed in this Directive, should be enforced according to their terms.

1. Scope and Application

   1. This new standard applies to all respirator usage in General Industry, Shipyards, Marine Terminals, Longshoring and Construction workplaces. It does not apply to agricultural operations or to occupational exposure to M. tuberculosis. Respiratory protection against tuberculosis will continue to be enforced under the old 1910.134, which has been redesignated 1910.139.

   2. The standard covers respirator use where respirators are being worn to protect employees from exposure to air contaminants above an exposure limit or are otherwise necessary to protect employee health, where respirators are otherwise required to be worn by the employer, and where respirators are voluntarily worn by employees for comfort or other reasons.

2. Permissible Practice - 1910.134(a)(1) and (a)(2): Section 134 (a)(1) restates OSHA's longstanding policy that engineering and work practice controls should be the primary means used to reduce employee exposure to toxic chemicals, and that respirators should only be used if engineering or work practice controls are infeasible or while they are being implemented. This preference for engineering and work practice controls is stated in a number of OSHA's substance specific standards (for example, the asbestos standard) and in the standards (29 CFR 1910.1000 and, for construction work, 29 CFR 1926.55) establishing permissible exposure limits for a number of harmful air contaminants. Feasible engineering, administrative or work practice controls must be instituted even though they may not be sufficient to reduce exposure to or below the permissible exposure limit (PEL). They must be used in conjunction with respirators whenever exposures exceed permitted levels.

1. Inspection Guidelines. The compliance officer should determine what engineering controls are in place and what work practices have been instituted to effectively reduce exposure. If controls are in place, but sampling results indicate these controls have not reduced air contaminant levels to the extent necessary to protect the health of the employee, then the CSHO should determine if the appropriate respirators are being provided and properly used. Even if the employer has not instituted the required engineering controls, failure to provide respirators to protect employees health is citable under 1910.134.

2. Citation Guidelines: In cases where an overexposure to an OSHA Permissible Exposure Limit (PEL), (either an 8-hour time-weighted-average , Ceiling Value, Short Term Exposure Limit or Acceptable Maximum Peak) is exceeded, the following principles apply:

   1. Violations for Exceeding an Exposure Limit. Where a PEL is exceeded for a substance listed in Table Z of 1910.1000 or Appendix A of 1926.55, the appropriate paragraph 1910.1000(a) thru (d), or 1926.55(a), should be cited. For substance-specific standards, the appropriate paragraph for exceeding the PEL should be cited.

      Exposures to levels of air contaminants which exceed ACGIH Threshold Limit Values (TLVs) or NIOSH recommended exposure limits (RELs), but which have no OSHA PEL, and which are considered to be serious exposure hazards, should be considered for violations of Section 5(a)(1) of the Act. Guidelines on citing Section 5(a)(1) can be found in the Field Inspection Reference Manual (CPL 2.103 Chapter III).

      Section 5(a)(1) shall not normally be used to impose a stricter requirement than that required by the standard. For example, if the standard provides for a permissible exposure limit (PEL) of 5 ppm, even if data establishes that a 3 ppm level is a recognized hazard, Section 5(a)(1) shall not be cited to require that the 3 ppm level be achieved unless the limits are based on different health effects. If the standard has only a time-weighted average permissible exposure level and the hazard involves exposure above a recognized ceiling level, the Area Director shall consult with the Regional Solicitor.

      NOTE: An exception to this rule may apply if it can be documented that "an employer knows a particular safety or health standard is inadequate to protect his workers against the specific hazard it is intended to address." Such cases shall be subject to pre-citation review.

      Section 5(a)(1) violations of the Act should be cited so as to cover all aspects of a serious hazard for which no standard exists. Related violations of the respirator or other standards should be grouped with any Section 5(a)(1) violations.

   2. Engineering and Administrative Controls. An employer's failure to implement feasible engineering or work practice controls should be cited under an applicable provision of a substance-specific standard (for example, section 1910.1000(f) of the general industry asbestos standard) or, for those substances listed in 1910.1000 or 1926.55, under 1910.1000(e) or 1926.55(b). The requirement to implement feasible engineering and administrative controls is in several substance-specific standards (for example, section 1910.1001(f) of the asbestos standard). These violations should normally be grouped with the overexposure. Section 1910.134 (a)(1) should not be cited along with 1910.1000(e) or 1926.55(b). Section 1910.134(a)(1) should not be cited when an employer fails to use engineering or work practice controls to reduce exposures to chemicals for which OSHA has not established permissible exposure limits. In appropriate circumstances, an employer's failure to use feasible engineering or work practice controls when there is no OSHA PEL may be citable under 5(a)(1) of the Act.

   3. The Requirement to Provide Respirators. Whether or not an employer has instituted required engineering or work practice controls, the employer's failure to provide respirators when employees are exposed to hazardous levels of air contaminants is citable under 1910.134. The requirement to provide respirators is found in several substance-specific standards (for example, 1910.1025(e) and (f) of the general industry lead standard). In cases involving those standards, where respirators have not been provided, the section of the substance-specific standard requiring respirators should be cited. If the substance is listed only in Table Z, the violation for not providing a respirator should be cited 1910.134(a)(2). These violations also would normally be grouped with the overexposure.

      The employer must provide the right type of respirator for the substance and level of exposure involved. If the employer provided the wrong kind of respirator, a citation should be issued under paragraph (d) for not providing an appropriate respirator, unless a substance specific standard is applicable.

   4. The Requirement to Ensure the Use of Respirators. Where respirators are needed to protect the health of the employees, employers must not only provide respirators but ensure that employees use them. In cases involving substance-specific standards, the section of the standard requiring respirator use should be cited when employers have not ensured respirator use. If the substance is only listed in Table Z (1910.1000) or Appendix A (1926.55), citations for not ensuring respirator use should be cited under 1910.1000(e) or 1926.55(b). For substances not listed in 1910.1000, 1926.55, or substance-specific standards, 1910.134(a)(1) should be cited when the employer fails to ensure respirator use.

   5. The Requirement to Have a Program. Paragraph (a)(2) requires the employer to establish and maintain a respiratory protection program that includes the requirements in 1910.134(c) whenever respirators are required to protect the health of the employee. The program must be in writing and contain all of the elements specified in 1910.134(c). If the employer has no program at all (i.e., no elements of a respirator program in place), a citation for violation of .134 (a)(2) should be issued. If respirators are used or other respirator violations are found, and there is no written program, then those violations and .134(c)(1) should be cited. If an employer has a written program, but an element required by .134(c) is omitted, then the subsection of .134(c) that requires the missing element should be cited.

      The specific actions that the employer must take are in 1910.134(d)-(m). If the employer's written program has all of the required elements, but the employer has not taken one of the actions required in .134(d)-(m), cite the applicable paragraph in .134(d)-(m). If no written program exists, but all other provisions of the standard have been met, a violation for lack of a written program would normally not be cited. CPL 2.111, Citation Policy for Paperwork and Written Programs, should be reviewed for guidance before citing the written program.

3. Definitions-1910.134(b): The revised standard now contains definitions inparagraph (b) that provide a clearer understanding of specific terminology used inthe standard and how these terms are applied to respirators and their use. Somedefinitions in the proposal were not included in the final standard, and some newdefinitions were added.

1. "Adequate warning properties" was not included in the final standardbecause the two major warning properties, odor and irritation, areunreliable or otherwise inappropriate to be used as primary indicators ofsorbent exhaustion.
2. "Assigned Protection Factor" has not yet been included in the standard.OSHA is conducting further rulemaking on this issue, and will eventuallyadd the APFs to the final standard. In the interim, OSHA will continue torefer to NIOSH APFs except in cases where APFs have been published insubstance-specific standards or are addressed by OSHA in separate lettersof interpretation. Employers must rely on the best available informationwhen selecting the appropriate respirator.
3. "Filtering facepiece" (dust mask) means a negative pressure particulaterespirator with a filter as an integral part of the facepiece or with the entirefacepiece composed of the filtering medium. Whenever a filteringfacepiece is used to meet the requirements of the standard, it must beNIOSH approved.
4. A "HEPA filter"(High Efficiency Particulate Air) is a filter that is99.97% efficient in removing monodispersed particles of 0.3 micrometersin diameter. NIOSH no longer uses this term in its new respiratorcertification standard (42 CFR 84). However, OSHA has retained thisdefinition because it is used in many of the existing substance-specificstandards. When HEPA filters are required by an OSHA standard, N100,R100, and P100 filters can be used to replace them.
Note: NIOSH Respirator Certification Requirements, 30 CFR 11 (Part11) were replaced by 42 CFR 84 (Part 84) on July 10, 1995. Onlycertifications of non-powered, air-purifying, particulate-filterrespirators were affected by this change. The remaining portions ofPart 11 were incorporated into Part 84 without change. Part 84permitted the manufacture and sale of non-powered-particulaterespirators certified under Part 11 until July 10, 1998.

Distributors who have purchased these respirators will be able tosell them until their inventories are depleted. Employers maycontinue to purchase available products and will be permitted touse them until their inventories are depleted, or until the shelf orservice life for the product expires. However, Dust/Mist andDust/Mist/Fume Filters may only be used for particulates withmass median aerodynamic diameters (MMAD) of least 2micrometers, in accordance with paragraph (d)(3)(iv)(C). Weldingfumes and silica flour may be examples of dust particulates thatare less than 2 micrometers. If the MMAD cannot be determined,a HEPA filter, or a filter certified by NIOSH under 42 CFR 84(N95 or higher) must be selected.

4. Respiratory Protection Program-1910.134(c)(1): A written respiratoryprotection program is required when necessary to protect the health of theemployee from workplace contaminants or when the employer requires the use ofrespirators. A limited written program is also required when respirators (otherthan filtering facepieces) are being voluntarily worn by employees. The programmust include workplace specific procedures and contain all applicable programelements. Where respirators are required, respirators (and their associatedrequirements such as fit-testing and maintenance), training and medicalevaluations must be provided at no cost to the employee. It is the intent of thestandard that the employer would not be required to incur any costs associatedwith voluntary use of filtering facepieces other than providing a copy of AppendixD to each user. If employers allow the voluntary use of respirators other thanfiltering facepieces, the costs associated with ensuring the respirator itself doesnot create a hazard, such as medical evaluations and maintenance must beprovided at no cost to the employee.

1. Inspection Guidelines. During inspections of workplaces whererespirators are used, the CSHO is to evaluate the respiratory program anddetermine if the employer's written program is adequate and complete forthat particular site.

The program must be tailored to cover the specific work operations andpractices in the workplace. The provisions listed in paragraph (c)(1)(i)thru (ix) of the standard must be included in the written program unless itis determined they are not applicable.

These provisions are to be considered when evaluating a written program:

1. (i) procedures for selecting respirators
2. (ii) medical evaluations for users,
3. (iii) fit-testing procedures for tight-fitting respirators,
4. (iv) procedures for proper use during routine and emergencysituations,
5. (v) procedures for cleaning, storing, disinfecting, etc.,
6. (vi) procedures to ensure adequate air quality and flow foratmosphere-supplying respirators
7. (vii) training on respiratory hazards,
8. (viii) training on proper use, donning and removing the respiratoretc.,
9. (ix) procedures for regularly evaluating the effectiveness of theprogram.

Compliance with the program should be verified during the walkaround bypersonal observation and employee interviews.

2. Citation Guidelines. If respirators are required to be worn in theworkplace or respirators other than dust masks are worn by voluntaryusers, a written program is required. An overexposure is not required tocite this paragraph. If the CSHO determines that specific provisions arelacking or deficient in the written program, the CSHO should cite section(c)(1) with the specific element(s) that are missing. Discrepanciesbetween the written program and implemented work practices at theworksite should be cited by the appropriate paragraph in the standard thatrequires the work practice. If overexposures are found and no program atall exists, paragraph (a)(2) should be cited.
3. (c)(2) Voluntary Use: Normally, respirators that are voluntarily used byemployees will be filtering facepieces (dust masks). NIOSH-approvedrespirators are strongly recommended, but they are not required forvoluntary use. This voluntary use of dust masks alone does not require theemployer to have a written program. For filtering facepiece respirator use,the employer needs only ensure that dust masks are not dirty orcontaminated, that their use does not interfere with the employee's abilityto work safely, and that a copy of Appendix D is provided to eachvoluntary wearer. Merely posting Appendix D is not considered adequate.

Use of elastomeric or supplied-air respirators, even when voluntary on thepart of the employee, will require the employer to include all elements in awritten program that will ensure use of these respirators does not create ahazard.

4. Inspection Guidelines Even though employees may be voluntarily usingrespirators, adverse health conditions can be caused by the wearing of arespirator itself. Examples include, but are not limited to;

1. (1) an employee's health being jeopardized by the wearing of arespirator (e.g., employee has a cardiac and/or pulmonary disorderthat could be aggravated by respirator use),
2. (2) the wearing of a dirty respirator that can cause dermatitis oringestion of a hazardous chemical;
3. (3) the sharing of a respirator that leads to transmittal of disease.
5. Citation Guidelines Maintenance (h) and medical evaluation (e) violationsshould be considered for all situations where employees have elected touse a respirator, other than a dust mask, for personal comfort. Ifoverexposures are found, then all other applicable subparagraphs shouldbe cited.
6. (c)(3) Program Administrator: A "respiratory protection programadministrator" is required to oversee and evaluate the respirator program.This individual must be suitably trained and have the appropriateaccountability and responsibility to manage the full respiratory protectionprogram.

Companies with multiple worksites may have a program administrator ateach worksite, as long as this person is qualified and retains theaccountability and responsibility for the day-to-day operation of thespecific program for that site. Alternatively, a company may opt to haveone program administrator for several sites and/or one program for severalsimilar sites as long as the program contains the necessary elements andaddresses the hazards at those sites.

7. Inspection Guidelines. The extent of training or experience required forthe program administrator will vary based on the complexity of therespiratory hazards in the workplace. Where significant programdeficiencies are discovered, compliance officers should discuss questionsabout the program with the program administrator to determine howfamiliar she or he is with respirators, the hazards in the workplace,respirator use in the facility, the respirator standard and the company'srespirator program.
5. Selection of Respirators and Hazard Evaluation-1910.134(d): The employeris required to select and provide an appropriate respirator (NIOSH certified) basedon the respiratory hazard(s) present in the workplace. The employer must identifyhazardous airborne contaminants that employees may inhale and make areasonable estimate of employee exposures in determining the appropriaterespirator for employees to use. Oxygen deficient atmospheres and thoseatmospheres that are not or cannot be estimated must be treated as IDLHenvironments. Where a contaminant is regulated by a substance-specific standardthat requires monitoring, failure to monitor in accordance with the standard'sterms would be cited under that standard. For other contaminants, although themost reliable and accurate method to determine exposure is to conduct personalair monitoring, it is not explicitly required by the respirator standard. Instead,other means can be used to estimate workplace exposures. Acceptable meansinclude:
• Use of objective data - this is the use of data obtained from industrystudies, trade associations, or from tests conducted by chemicalmanufacturers which demonstrate that air contaminants cannot be releasedin the workplace in airborne concentrations that are IDLH. The objectivedata shall represent the highest contaminant exposures likely to occurunder reasonably foreseeable conditions of processing, use, or handling.The employer must document the use of objective data as part of theirwritten program.
• Application of mathematical approaches - the preamble to the final rule(p. 1199) states that employers can use data on the physical and chemicalproperties of air contaminants, combined with information on roomdimensions, air exchange rates, contaminant release rates, and otherpertinent data including exposure patterns and work practices to estimatethe maximum exposure that could be anticipated in the workplace.
• As a continuing practice, employers are required to identify hazards as aresult of changes in the workplace such as a change in equipment, process,products, or control measures that could result in new exposures.Appropriate respirators should be provided as necessary.
1. Inspection Guidelines. The CSHO should closely scrutinize theemployer's estimate of employee exposure and determine if the hazardassessment is based on appropriate data and reliable information. OSHApersonnel have considerable experience evaluating air monitoring data forrepresentativeness of the sample and reliability and accuracy of data.Where objective data are used in the workplace to determine employeeexposure, the data must have been obtained under conditions whichclosely resemble the process, types of materials, control methods, workpractices, and environmental conditions.

In regards to mathematical predictive equations, their use should belimited to situations where workplace factors, such as contaminant releaseand ventilation system performance, are fairly constant over the work shiftand predictable. The results should incorporate reasonable safety factorsand be interpreted conservatively. CSHO's must exercise a great deal ofprofessional judgement in concluding if the mathematical approachprovides appropriate guidance. (e.g., The methylene chloride standardforbids the use of APR's for protection against methylene chloride andwould supercede any model which predicts a changeout time for thischemical.)

The CSHO should examine the employer's Hazard CommunicationProgram for further information on existing respiratory hazards in theworkplace.

The Hazard Communication Standard requires employers to inventory thehazardous chemicals in their workplace and to maintain copies of materialsafety data sheets (MSDS) for each hazardous chemical. In a similarmanner under the respirator standard, the employer must examine theworkplace and determine if the quantity, circumstances, and use of thehazardous chemicals require further evaluation for respiratory hazards.MSDSs contain information such as physical and chemical characteristicsand hazards, primary route(s) of entry, and generally applicable controlmeasures. Some MSDSs include some recommendations on appropriaterespiratory protection.

For those chemicals that do present a potential respiratory hazard,employers can contact the chemical manufacturer for additionalinformation on predicted exposure levels and methods to further controlworker exposure.

The CSHO should be aware of the potential for an emergency situationand the type of respirators selected. The employer must provide theappropriate emergency escape respirator in the immediate work area foremployee use and address emergency use respirators in the writtenrespirator program.

The CSHO should also investigate, through routine employee interviews,what actions the employer has taken to re-evaluate employee exposurewhen employees have made health complaints to determine if appropriateaction has been taken to address a respiratory hazard.

Respirators required to be used in the workplace must be NIOSH-approved and appropriate for the hazard. Part 84 respirators with an "N"designation should not be used in work settings where oil aerosols aregenerated, while those with an "R" designation should be used for onlyone shift when oil is present. Respirators with a "P" designation may beused for more than one work shift, even when oil is present. Employersmust follow respirator manufacturer's recommendations.

2. Citation Guidelines. If the employer has not made any effort to assess therespiratory hazards, and there is potential for an overexposure, the CSHOshould cite section (d)(1)(iii). The extent to which the employer exploredways to reasonably estimate exposures must be evaluated at each worksite.

Inappropriate respirators [(d)(1)(i)] should be cited when the CSHOdocuments an overexposure is possible, and a suitable respirator is notbeing used for protection against that exposure . Unapproved [(d)(1)(ii)]respirators can be cited even where an overexposure has not beenestablished.

3. (d)(3)(iii)(B) Air-purifying Respirators for Protection Against Gases andVapors on Atmospheres That Are Not IDLH - If a cartridge/canister airpurifying respirator for the protection against gases and vapors does nothave an ESLI, then the employer must implement a cartridge/canisterchange schedule based on objective information that will ensure thecartridges/canisters are changed before the end of their service life. Thepurpose of a change schedule is to establish the time period for replacingrespirator cartridges and canisters; this is critical to preventingcontaminants from respirator breakthrough, and thereby over-exposingworkers. Data and information relied upon to establish the schedule mustbe included in the respirator program. The requirements for several ofOSHA's chemical specific standards already address this issue and havebeen retained. These include:

a.	Acrylonitrile 1910.1045(h)(2)(ii)	end-of-service life or end ofshift (whichever occurs first)
b.	Benzene 1910.1028(g)(2)(ii)	end-of-service life orbeginning of shift (whicheveroccurs first)
c.	Butadiene 1910.1051 (h)(2)(ii)	every 1, 2 or 4 hoursdependent on concentrationaccording to Table 1 and atbeginning of each shift
d.	Formaldehyde 1910.1048 (g)(2)(ii) -	for cartridges every threehours or end of shift(whichever is sooner); forcanisters, every 2 or 4 hoursaccording to the schedule in(g)(3)(iv)
e.	Vinyl chloride 1910.1017(g)(3)(ii)	end-of-service life or end ofshift in which they are firstused (whichever occurs first)
f.	Methylene chloride - 1910.1052 (g)(2)(ii)	canisters may only be used for emergency escape and must be replaced after use.

Change schedules for all other gases and vapors must be established andimplemented by the employer. OSHA has stated in the preamble to thefinal rule that the employer is not required to research and analyzeexperimental breakthrough data, but may obtain information from sourceswho have expertise and knowledge that can help the employer to developreasonable change schedules. The new standard prohibits the use ofwarning properties as the sole basis for determining change schedules.However respirator users should be trained to understand that abnormalodor or irritation is evidence that respirator cartridges need to be replaced.Where an effective change schedule is implemented, air-purifying gas andvapor respirators may be used for hazardous chemicals, including thosewith few or no warning properties.

4. Inspection Guidelines - OSHA understands that new or existing objectivedata could be presented in a variety of formats and from a number ofdifferent sources. CSHOs should approach the evaluation of thisrequirement with professional judgement and flexibility. There are anumber of factors that influence the service life of a cartridge. Some ofthe more significant factors include: the contaminant's chemicalproperties, temperature, humidity, contaminant concentration, work rate(breathing rate) of the respirator user, variability of respirator cartridgesbetween manufacturers, and the presence of multiple contaminants. Toensure fair and reasonable enforcement of this provision, the followingguidelines are presented to assist the CSHO in determining compliancewith this provision.

1. Availability of Objective Data: Ascertain if there are sources ofobjective data for the particular make and model of the respiratorcartridge/canister and if this data is sufficient to implement changeschedules. Typical sources would include: respiratormanufacturers, industry organizations, trade associations,professional societies, chemical manufacturers (MSDS), academicinstitutions, and ad hoc committees. The CSHO should determineif the employer has access to adequate information to comply withthis provision. For a list of some options that employers may usein developing their change schedules, refer to Appendix A.
2. Use of Inappropriate Respirator Cartridge/canister: Determine ifthe air purifying respirator is appropriate for the contaminantpresent in the workplace. In some cases, the breakthrough timemay be so rapid (minutes) that air purifying respirators are notfeasible and supplied air respirators should be used. CSHOsshould consult respirator manufacturers and other referencematerial for this information.
3. Change Schedules For Mixtures: Establishing cartridge service lifefor mixtures of contaminants is a complex task and one thatrequires considerable professional judgement to create a reasonablechange schedule. Cartridge service life for mixtures is bestdetermined using experimental methods. Change schedules arevery difficult to develop for mixtures using predictivemathematical models.

The change schedule for a mixture should be based on reasonableassumptions that include a margin of safety for the worker wearingthe respirator. Where the individual compounds in the mixturehave similar breakthrough times (i.e. within one order ofmagnitude), service life of the cartridge should be establishedassuming the mixture stream behaves as a pure system of the mostrapidly migrating component or compound with the shortestbreakthrough time (i.e., sum up the concentration of thecomponents). Where the individual compounds in the mixturevary by 2 orders of magnitude or greater, the service life may bebased on the contaminant with the shortest breakthrough time.OSHA believes that an approach such as this reflects good healthand safety practice where neither objective or experimental data isavailable for the mixture.

OSHA believes that change schedule information will becomemore available to the respirator user community and will evolve inquality. The CSHO should review the written respiratoryprotection program to ensure that it describes the information anddata relied upon and the basis for the canister and cartridge changeschedule and the basis for reliance on the data as required by thestandard. Again, CSHOs should exercise judgement in evaluatingmathematical models, rules of thumb, experimental data, use ofanalogous chemical structures, and other reasoned approaches.

4. Chemical Contaminant Migration: CSHO's should be aware thatsome contaminants have a tendency to migrate throughcartridge/canister sorbent material during periods of storage ornon-use. This is characteristic of the contaminant-carbon bedinteraction for organic chemicals with boiling points below 65Centigrade and would predictably shorten breakthrough times. Incases where respirators are used for multiple days this couldpresent an additional exposure to the respirator user. Wherecontaminant migration is possible, respirator cartridges/canistersshould be changed after every workshift where exposure occursunless the employer has specific objective data to the contrary(desorption studies) showing the performance of the cartridge inthe conditions and schedule of use/non-use found in the workplace.
5. Citation Guidelines. If the employer has or could have had the knowledgeavailable to implement change schedules and had done little or nothing todetermine accurate change schedules, (d)(3)(iii)(B) should be cited. Forcitation purposes, the CSHO should document the purpose of respiratoruse, make and model of respirator(s), identification and concentration ofcontaminant (s), duration of use, exposure to a mixture of contaminantsand any other relevant user and workplace factors.
6. Medical Evaluation - 1910.134(e): Employers must provide a medical evaluationto determine each employee's fitness to wear a respirator. The evaluation must beprovided before the initial fit-testing and before the respirator is used for the firsttime. Medical evaluations consist of the administration of a medicalquestionnaire, which is found in the mandatory Appendix C of the standard, orprovision of a physical examination that elicits the same information as thequestionnaire for the employee. An employer, who opts to provide physicalexaminations to his or her employees, need not also administer the medicalquestionnaire. These evaluations are required for all respirator users except foremployees who voluntarily use dusts masks and for those whose only respiratorwould be the use of escape-only respirators. SCBA's are not considered escape-only respirators. Employees who refuse to be medically evaluated cannot beassigned to work in areas where they are required to wear a respirator.

Where employers use a transient workforce, (e.g., temporary or constructionworkers), the employer may accept the written medical recommendation of theemployee's ability to use a respirator as determined by their previous employer'sPLCHP only if the work conditions and type and weight of the respirator remainsthe same and appropriate for use at their new work site. In this situation, theemployer must obtain from the previous employer a copy of the PLCHPs writtenrecommendation.

Section (e)(2)(ii) requires the employer to obtain the information required in thequestionnaire or provide the initial examination prior to performing fit testing ofemployees and prior to requiring the employee to wear the respirator in theworkplace. When using the questionnaire, the employer may not change thewording of questions in Part A , if the form is being used as the sole means toevaluate employees. The Physician or other Licensed Health Care Professional(PLHCP) may add questions to the questionnaire that could assist in determiningwhether the employee can perform the work while wearing respiratory protection.

In order to maintain strict confidentiality of the information obtained in thequestionnaire, the employer's role is limited to distributing the blankquestionnaire to the employee for him or her to fill out, or providing it to thePLHCP, who will administer the questionnaire to the employee. If the employerprovides the questionnaire to the employee, an addressed and postage-paidenvelope should also be provided for the employee to mail it to the PLHCP. Thequestionnaire and findings may also be maintained by the employer's medicaloffice, if the health office is administratively separate from the employer's centraladministration offices.

If the employer does not have or chooses not to use an in-house medical staff,arrangements must be made for a physician or other licensed healthcareprofessional (PLHCP) to perform the medical evaluations. The PLHCP may bea physician, a registered nurse, a nurse practitioner, a physician assistant, or otherlicensed health care professional acting within the scope of his or her state license,registration, or certification. The PLCHP must be legally permitted by his or herprofessional license to conduct the type of medical evaluation required by therespirator standard. Scope of practice for non-physician PLCHPs will vary fromstate to state. All PLCHPs who participate in any aspect of the medical evaluationmust be practicing within the scope of their license. For assistance in determiningwhich state licensing board or agency to contact to determine a PLCHP's legallypermitted scope of practice, the CSHO can contact the Directorate of TechnicalSupport in OSHA's National Office.

The employer must ensure that the questionnaire is administered in such a mannerthat employees can understand the content and the confidentiality of the record ismaintained. Where the employee cannot understand English, the employer musthave the questionnaire translated into the employee's language either through atranslator or a translated written copy. The questionnaire has been translated intoSpanish and is available on OSHA's homepage (www.osha.gov) in the RespiratorQ & A Document. In cases where the employee cannot read, the employee canrequest someone other than the employer to orally read them the questionnaire orthe PLHCP may obtain through an interview or examination the same informationrequested on the medical questionnaire.

1. Inspection Guidelines. The CSHO should determine if the requirements ofparagraph (e) are being met by interviewing a number of employees andasking if they have been provided with a confidential evaluation of theirability to wear a respirator, either by the administration of the medicalquestionnaire or by physical examination. Compliance officers shoulddetermine what mechanism the employer is using to ensure that theemployer does not see the answers to the questionnaire in order tomaintain confidentiality. The CSHO can verify that these medicalevaluations have in fact been conducted by asking the employer to see thewritten recommendation of the employee's ability to use a respirator. Theemployee should have also received a copy. The recommendation mustcontain only the information required by subparagraph (e)(6).

The CSHO should determine what supplemental information was given tothe PLHCP by the employer. This can be done through interviewing thePLHCP or reviewing documentation from the employer. If the employeris relying on a medical evaluation for the employee from a previousemployer (which is allowed only when the employer uses a transientworkforce), the CSHO should determine that the work conditions andrespirator remained the same.

If the CSHO suspects the employee(s) did not receive a medical evaluationor have not answered the questionnaire honestly (e.g., been "coached" bythe employer on how to respond to the mandatory questions fromAppendix C), then the CSHO should ask to interview the PLHCP. If thisinterview still results in questions, the CSHO may wish to obtain aMedical Access Order and review the actual medical questionnaire and/orthe physical examination records where necessitated by this paragraph ofthe rule.

The CSHO should also ensure that any required physical examinationshave in fact been conducted, as per (e)(3) and (e)(7). A positive answer toany question in Part A, Section 2, Questions 1-8 (also questions 10-15 forSCBA and full-face respirator users) requires a follow-up by the PLCHP.The PLCHP may evaluate positive responses through consultation with theemployee to determine if the positive response is not relevant to theemployee's ability to wear a respirator or if further physical examination isnecessary (e.g., brief smoking history in the past, as compared to currentheavy smoker status).

If questions arise regarding the issue of qualifications of the PLHCP, theCSHO should inquire with the state licensing board or the applicableregistration or certification agencies in that state to ensure that the PLCHPis acting within the scope of his or her practice.

2. Citation Guidelines: If medical evaluations are not provided, a violationof (e)(1) exists. If the PLHCP designated by the employer is not operatingwithin the scope of their license or their license has expired or is invalid,the employer should be cited under paragraph (e)(2)(i) for choosing aninappropriate PLHCP.

1. If the employer's medical evaluation does not obtain the mandatoryinformation required in Part A, Sections 1 and 2 of Appendix C,then a violation of (e)(2)(ii) exists.
2. If the PLHCP is not provided with the appropriate supplementalinformation, a violation of (e)(5) exists.
7. Fit Testing-1910.134(f): Fit testing is required for all employees using negativeor positive pressure tight-fitting respirators, where such respirators are required byOSHA or where the employer requires the use of such a respirator. A fit test isnot required for voluntary users or for escape-only respirators.

The fit test must be performed before the respirator is used in the workplace. Itmust be repeated at least annually and whenever a different respirator facepiece isused or a change in the employee's physical condition could affect respirator fit. Ifthe respirator subsequently becomes unacceptable (i.e., causes irritation or pain tothe employee) to the employee, the employee must be given the opportunity toselect a different respirator facepiece and be retested.

Qualitative Fit-Testing (QLFT) may be used to fit test negative pressure air-purifying respirators, if they will only be used in atmospheres less than ten timesthe PEL, since existing evidence only validates the QLFT protocols listed inAppendix A to identify respirators that achieve a fit factor of 100. For greaterconcentrations, Quantitative Fit-Testing (QNFT) must be used. Whenquantitative fit-testing is used, all full-facepiece respirators must meet or exceed afit factor of 500, while quarter - and half-mask respirators must meet or exceed100. For all positive pressure, atmosphere-supplying respirators, either qualitativeor quantitative fit testing may be used. While atmosphere-supplying respiratorsare fit-tested in the negative pressure mode, these respirators are most often usedas positive pressure respirators in the workplace. Positive pressure atmosphere-supplying respirators that pass the QLFT or QNFT fit test may be used at thehigher protection factors assigned these respirators. See Table 1 for a summary.

1. Inspection Guidelines. The CSHO should determine which protocol wasused for fit testing and if all employees who are wearing tight-fittingrespirators have been fit-tested in the last twelve months for the respiratorthey are wearing. Fit testing procedures should be discussed with theprogram administrator. If fit testing is being performed, the CSHO shouldobserve the company's procedures and evaluate their adherence to theprescribed protocol.

1. Where employees move from job to job within the year (e.g.,temporary or construction workers), their fit test need not berepeated, if the employer obtains a copy of the original fit testrecord and the same respirator make, model and size is availableand appropriate for use at their new work site.
2. Citation Guidelines. Fit test records should be reviewed. If no fit testrecord is found it must be determined if they were not maintained[(m)(2)(ii)] or the test was not performed [(f)(2)] and cited accordingly.For not following prescribed protocol, cite (f)(5). Using QLFT fornegative pressure APR's used in atmospheres greater than 10 times thePEL would be cited as (f)(6).

1. If fit testing was done by a previous employer within the requiredtime, but no fit test record was obtained by the current employer, acitation for (m)(2) should be issued.
2. If the CSHO determines the fit testing was not appropriate for thepresent respirator usage, citations for the appropriate requirementsof paragraph (f) should be issued.

Table 1 Acceptable Fit-Testing Methods
	QLFT	QNFT
Half-Face, Negative Pressure, APR (<100 fit factor)	Yes	Yes
Full-Face, Negative Pressure, APR (<100 fit factor)used in atmospheres up to 10 times the PEL	Yes	Yes
Full-Face, Negative Pressure, APR (>100 fit factor)	No	Yes
PAPR	Yes	Yes
Supplied-Air Respirators (SAR), or SCBA used inNegative Pressure (Demand Mode) (>100 fit factor)	No	Yes
Supplied-Air Respirators (SAR), or SCBA used inPositive Pressure (Pressure Demand Mode)	Yes	Yes
SCBA - Structural Fire Fighting, Positive Pressure	Yes	Yes
SCBA/SAR - IDLH, Positive Pressure	Yes	Yes
Mouthbit Respirators	Fit-testing NotRequired
Loose-fitting Respirators (e.g., hoods, helmets)

8. Use of Respirators - 1910.134(g): Employers must establish and implementprocedures for the proper use of respirators. These procedures include prohibitingconditions that may result in facepiece leakage, preventing employees fromremoving respirators in hazardous environments, ensuring continued respiratoroperation throughout the shift, and establishing procedures for the use ofrespirators in IDLH atmospheres.

1. Facepiece Seal Protection (g)(1):

1. Inspection Guidelines - The CSHO should be alert for the presenceof facial hair (more than one day's growth) that comes between thesealing surface of the respirator and the face as well as otherconditions that could result in facepiece seal leakage or interferewith valve function of tight-fitting respirators, such as the presenceof facial scars, the wearing of jewelry, or the use of headgear thatprojects under the facepiece seal. Corrective glasses or goggles orother personal protective equipment (such as faceshields,protective clothing, and helmets) must not interfere with the seal ofthe facepiece to the face of the user. If employees wear othersafety equipment with their respirators, the employee must pass anappropriate fit test while wearing the equipment to determine if itinterferes with the seal.

Employees should be observed to determine if the seal checkprocedures are being performed each time the respirator is donned.The procedure used must be one listed in Appendix B-1 orrecommended by the manufacturer if the employer demonstrates itis as effective as those listed in Appendix B-1. Alternative sealchecks must be based on scientific studies. [The face fit isconsidered satisfactory if a slight positive pressure can be built upinside the facepiece when the exhalation valve or surface iscovered, the user exhales gently, and there is no evidence ofoutward leakage at the seal. The negative check requires coveringthe inlet opening or surface, inhaling gently, and having thefacepiece remain in a slightly collapsed condition with no inwardleakage of air detected.]

2. Citation Guidelines - CSHO should cite (g)(1)(i)(A) whenemployees' facial hair comes between the sealing surface of thefacepiece and the face or interferes with valve function;(g)(1)(i)(B) when any other condition except for those listed in(g)(1)(ii) interferes with the face-to-facepiece seal; (g)(1)(ii) whenthe employee is wearing equipment (e.g., glasses, goggles, helmets,etc.) that affects the face-to-facepiece seal, but was not wornduring fit testing; (g)(1)(iii) if user seal checking is not beingperformed or the employer has not demonstrated that theprocedures used are those listed in or as effective as those inAppendix B-1. This paragraph should not be cited in voluntary usesituations, if overexposures are not found.
2. Continuing Respirator Effectiveness (g)(2):

1. Inspection Guidelines - The employer is required, by paragraph(c)(1)(ix), to address in its written program the type of regularsurveillance of the workplace necessary to evaluate theeffectiveness of the respirator program. The surveillanceprocedures may include continuous or periodic monitoring, on-siteobservations, and notation of problems. The intensity of thesurveillance should be tailored to the hazards present in theworkplace. Highly hazardous substances that pose acuterespiratory hazards merit a higher degree of surveillance.

Section (g)(2)(ii) requires that employers ensure that employeesleave the respirator-use area to correct certain problems associatedwith respirator use, including the detection of contaminantbreakthrough, and to replace the respirator or its filters orcartridges. Employees should be interviewed [e.g., What do youdo if you notice a leak? ] to determine whether there are anypolicies or actions which would prohibit or impede them fromleaving the area should they have significant problems with theirrespirators or which impede the replacing of filters or cartridges.Paragraph (g)(2)(iii) is designed to prevent employees fromreentering a workplace after leaving because of a significantrespirator failure without first assuring the proper functioning ofthe respirator.

2. Citation Guidelines - The CSHO should cite (c)(1)(ix) if thewritten procedures are inadequate to identify problems or changes;(g)(2)(i) if the routine surveillance of the work conditions is notperformed; the appropriate section of (g)(2)(ii)(A), (B) or (C), ifprohibitions to leaving an area are identified or if employees fail toleave the area when the standard requires them to do so; (g)(2)(iii)if employees are allowed back into an area before the employer hasreplaced or repaired the respirator.
3. Procedures for IDLH Atmospheres (g)(3):

1. Inspection Guidelines - The employer must be prepared foremergency rescue or respirator failure whenever employee(s) areworking inside of an IDLH atmosphere. At least one person mustbe on standby outside the IDLH atmosphere and maintaincommunication with the person inside at all times. The standbyperson(s) must be trained and equipped to provide an effectiveemergency rescue. Except in emergency situations, environmentscontaining IDLH atmospheres are frequently well enoughcharacterized and controlled that a single standby person canmonitor the status of multiple entrants. The need for multiplestandbys should be evaluated in context with the ability of thestandby personnel to meet all their standby duties, including theirability to monitor the worker(s) in the area and their ability toinitiate effective rescue procedures. Planning is critical foreffective response to emergency situations through thedevelopment of specific emergency procedures. These proceduresshould address how the employer will be notified when standbyperson(s) outside of the IDLH atmosphere enter the IDLHatmosphere to provide emergency rescue and what actions will betaken or assistance provided by the employer. Emergencyprocedures must be developed and included in the employer'swritten respirator program.

For work performed outside of visual contact, voice, radio or signalline are permitted. CSHOs should specifically review protocols forcommunication, rescue, and notification for employees enteringIDLH atmospheres. Communication protocols must be establishedthat allow the standby person to monitor entrant status and enablethe standby(s) to alert entrants of the need to evacuate the area. Itis not sufficient to rely on the employees in the IDLH area to callfor help when needed.

Paragraph (g)(3) does not apply to IDLH atmospheres in a permit-required confined space (PRCS) or to environments in which thereis an uncontrolled release of a hazardous substance. IDLHatmospheres in a PRCS are specifically addressed in the PRCSstandard, 1910.146, and its accompanying directive, CPL 2.100.Environments in which there is an emergency release of ahazardous substance are addressed in paragraph (q) of OSHA'sHAZWOPER standard, 1910.120 or 1926.65, and itsaccompanying directive, CPL 2-2.59A. In facilities where anuncontrolled release of a hazardous substance could create anemergency IDLH atmosphere, employers must follow therequirements of HAZWOPER paragraph (q). These situationsmust be addressed in the employer's emergency response plan andthe response procedures must be consistent with that standard.

2. Citation Guidelines - If an IDLH area meets the definition of aconfined space, then the requirements of 1910.146 would applyand the appropriate section of 1910.146 should be cited wheredeficiencies are noted. If the IDLH is a result of an uncontrolledrelease of a hazardous substance, then the appropriate section ofthe HAZWOPER standard, 1910.120 should be cited. Otherwise,violations should be cited under the applicable subparagraph of(g)(3). If adequate communication is not maintained between theentrants and the standby personnel located outside the IDLH area,(g)(3)(ii) should be cited.
4. Procedures for Interior Structural Firefighting, 1910.134(g)(4): Thissection applies to private sector workers engaged in firefighting, includingthose working in industrial fire brigades and private incorporated firecompanies, and to Federal employees under Section 19 of the Act. Theseor equivalent provisions apply to State and local government firefightersonly in the 25 States that operate OSHA-approved State plans which arerequired to adopt an identical or "at least as effective" standard and extendits coverage to public employees. (Coverage of volunteer firefighters inthese States varies by State and depends on State law.) The followingguidance will have applicability primarily in the State Plan States and inresponding to general inquiries.

The provision is limited to workers performing an interior attack on aninterior structural fire. In Subpart L ( 1910.155), OSHA has defined"interior structural fire fighting" to mean: "the physical activity of firesuppression, rescue or both, inside of buildings or enclosed structureswhich are beyond the incipient stage." This is firefighting to control orextinguish a fire in an advanced stage of burning, producing large amountsof smoke, heat and toxic products of combustion. Firefighter exposureduring this activity is extremely hazardous. The atmosphere is consideredIDLH and the use of Self Contained Breathing Apparatus is required. Bycontrast, incipient stage fire fighting involves the control orextinguishment of a fire in the initial or beginning stage, using portablefire extinguishers or small hose lines without the need for personalprotective equipment. It is the incident commander's responsibility, basedon training and experience, to judge whether a fire is an interior structuralfire, and how it will be attacked.

OSHA has discussed this provision in a number of documents.

1. Summarized below are some key points from those documents.

• There must always be at least two firefighters stationed outsideduring interior structural firefighting, and they must be trained,equipped and prepared to enter if necessary to rescue thefirefighters inside. However, the incident commander has theresponsibility and flexibility to determine when more than twooutside firefighters are necessary given the circumstances of thefire. The two-in/two-out rule does not require an arithmeticprogression for every firefighter inside, i.e. the rule should not beinterpreted as 4-in-4-out, 8-in-8-out, etc.
• It is important that the CSHO recognize that life-saving activitiesin interior structural fire fighting are not precluded by the standard.There is an explicit exemption in the standard that if life is injeopardy, firefighters have the discretion to perform the rescue, andthe "two-in/two-out" requirement is waived. There is no violationof the standard under such life-saving rescue circumstances.
• The two-in/two-out provision is not intended as a staffingrequirement. It does not require fire departments to hire additionalfirefighters; it does not require four-person fire companies; it doesnot require four persons on a fire truck. Most fire departmentshave more than four firefighters and can assemble the numbersrequired on the scene by waiting for others to arrive. During thistime the fire may be attacked only from the outside, sizing-upoperations may occur, and emergency rescue necessary to savelives may take place as discussed above. The "two-in/two-out"rule is a worker safety practice requirement, not a staffingrequirement.
• The standard allows one of the standby firefighters to have otherduties such as serving as the incident commander, safety officer, oroperator of fire apparatus. However, one of the outside firefightersmust actively monitor the status of the inside firefighters and maynot be assigned additional duties. The second outside firefightermay be involved in a wide variety of activities. Both of the outsidepersonnel must be able to provide support and assistance to the twointerior firefighters; any assignment of additional duties for one ofthe outside firefighters must be weighed against the potential forinterference with this requirement. Proper assignment offirefighting activities at an interior structural fire must bedetermined on a case-by-case basis and is dependent on theexisting firefighting situation. Compliance will always depend onconsideration of all the worksite variables and conditions, and thejudgement of the incident commander is critical in meeting thisperformance standard.
• The two firefighters (buddies) entering an IDLH atmosphere toperform interior structural firefighting must maintain visual orvoice communication at all times. Electronic methods ofcommunication such as the use of radios shall not be substitutedfor direct visual contact between the team members in the dangerarea. However, reliable electronic communication devices are notprohibited and certainly have value in augmenting communicationand may be used to communicate between inside team membersand outside standby personnel.
• For further explanation refer to the preamble of the RespiratoryProtection standard (vol. 63, No. 5, 1245-1248) and the RespiratorQuestion and Answer document (August 3, 1998). Bothdocuments can be found at OSHA's Homepage - www.osha.gov.
2. Inspection Guidelines - Section (g)(4) includes the requirements of(g)(3). The first and critical step in evaluating an employersresponse using the two-in/two-out rule is to determine if there wasinterior structural fire fighting activity. This determination willrequire consideration of the factors existing at the time of thefirefighting action and the basis for the Incident Commander'sfinding. CSHO should seek expert opinion from other authoritiessuch as a state or local fire Marshall or other fire protectionprofessionals and should thoroughly interview affected personnelto document the violation.
3. Citation Guidelines - If the CSHO's investigation reveals that thetwo-in/two-out rule was not followed during the interior attack ofan interior structural fire and there was no reasonable expectationthat someone was in jeopardy inside the building, the CSHOshould cite (g)(4)(i) or (g)(4)(ii) as a serious violation. If adequatecommunication is not maintained between the team inside and thestandby personnel located outside the IDLH, (g)(3)(ii) should becited.
9. Maintenance and Care of Respirators - 1910.134 (h)(1): Respirators must becleaned and disinfected as often as necessary to keep them in a sanitary condition.They must be properly stored to prevent damage and contamination, inspectedregularly and repaired as necessary.

1. Inspection Guidelines. To ensure that respirators are clean and in goodworking order, the employer can have respirators cleaned and repaired in acentralized operation where respirators are passed out to employees ORthe employer may require the respirator user to perform all cleaning andrespirator maintenance functions. The CSHO should verify that theprocedures in the mandatory Appendix B-2 or an equivalent methodspecified by the manufacturer are being followed and are performed byemployees who are adequately trained in the proper respirator careprocedures. Respirators issued to more than one employee must becleaned and disinfected before being worn by another user. The use ofindividually-wrapped cleaning towelettes may be used as an interimmethod in the cleaning schedule for individually assigned respirators, butthey must not be the only method in place. During fit-testing, towelettesmay also be used between employees being tested, however theserespirators must be thoroughly cleaned at the end of each day, using theprocedures in Appendix B-2.

The employer must ensure that respirators are inspected before each useand during cleaning. The CSHO should observe the condition of therespirators being used in the workplace. One or more respirators shouldbe checked before employees enter, or as they leave the respirator area. Aminimally acceptable inspection procedure for ALL respirators includes acheck of respirator function, tightness of connections and the condition ofthe various parts, including but not limited to, the face piece, head straps,valves, connecting tube, and cartridges, canisters, or filters, and a check ofthe respirator's elastomer parts for pliability and signs of deterioration.

SCBA's also require an inspection of the air and oxygen cylinders toassure that the cylinder pressure is maintained at 90% of themanufacturer's recommended pressure level and that the regulator and lowpressure warning devices function properly. To assure that both theregulator and low pressure warning devices function properly the warningdevice must be activated and heard by the person performing theinspection. The CSHO should interview the individual who is inspectingSCBA's to determine if these regulator and low pressure warning devicesare being activated according to the respirator manufacturer's instructions.

The CSHO should also observe how respirators are stored in theworkplace. Respirators must be properly stored to protect them againstphysical damage, contamination, excessive moisture, extremetemperatures, sunlight, and damaging chemicals. Emergency userespirators must be stored in compartments OR in covers, both of whichmust be clearly marked as containing the emergency respirators.

2. Respirators That Are Available for Emergency Use: An inspection must beconducted monthly for all emergency use respirators. The employer mustcertify in writing that an inspection was performed. The certification mustinclude the name (or signature) of the person who made the inspection, thefindings of the inspection, any remedial action, and a serial number orother means of identifying the inspected respirator. The respirator mustalso be checked before and after each use.

1. Emergency escape-only respirators carried by employees must beinspected before being taken into the workplace for potential use.
3. Section (h)(4) Repairs: Defective respirators must be removed fromservice. A respirator is defective if one or more of its components ismissing, damaged, or visibly deteriorated. The employer must developsome means to ensure defective respirators are not used in the workplace.The employer can comply by placing an "out of service" tag on therespirator to help ensure that the defective respirator is not inadvertentlyused or by removing the respirator from the work area. An "appropriatelytrained" person must be responsible for performing repairs or adjustmentsto respirators.
4. Inspection Guidelines. The CSHO must interview the employee(s) at theworksite who repair respirators, and determine what training they havereceived. An appropriately trained person is an individual who hasreceived training from the manufacturer or otherwise has demonstratedthat he or she has the skills to return the respirator to its original state ofeffectiveness. The training is performance-oriented, so it is acceptable forthe employee to have acquired the skills through practice rather than byattending a formal training course. Repairs to reducing and admissionvalves, regulators, and alarms must be done by a technician trained by themanufacturer.

1. Only the respirator manufacturer's NIOSH-approved parts that aredesigned for the particular respirator being repaired can be used torepair a respirator.
2. CSHOs should cite for defective respirators not effectively beingremoved from service.
10. Breathing Air Quality and Use 1910.134 (i): Compressed breathing air mustmeet at least the requirements for Grade D breathing air. The ANSI/CGA G.7-1 -1989 specifies the contents of Grade D breathing air as: oxygen (volume/volume)of 19.5 to 23.5 %; hydrocarbon (condensed) of 5 mg/m? of air or less; carbonmonoxide of 10 ppm or less; carbon dioxide of 1,000 ppm or less; and the lack ofa noticeable odor.

1. Inspection Guidelines. If compressors are used to supply breathing air, theCSHO should note the location of the compressor intake and ensure it islocated in an area uncontaminated by either combustion exhaust gasesproduced by vehicles or the compressor itself (if applicable), or by otherexhaust gases ventilated from plant processes. A tag containing thesignature of the person authorized by the employer to change the in-linesorbent beds and filters and the date of the latest change must bemaintained at the compressor.

For air compressors that are not oil lubricated, a CO alarm is not required.However, the employer is required to ensure that carbon monoxide levelsin the breathing air do not exceed 10 ppm. Some practical methods forensuring that the carbon monoxide level does not exceed 10 ppm include;placing the air intake for the compressor in an area that the employerknows is free from contaminants; frequent or continuous monitoring of thebreathing air supply; the use of carbon monoxide filters; or the use of ahigh temperature alarm or shut off devices.

If the employer is using an oil-lubricated air compressor, it must haveeither a carbon monoxide alarm, high temperature alarm, or both. If only ahigh temperature alarm is used, then the breathing air must be tested forthe presence of carbon monoxide at intervals sufficient to ensure thatcarbon monoxide levels do not exceed 10 ppm. The alarm must be able toalert the users or another employee who knows to alert any respiratorusers.

If cylinders are used they must be marked with a NIOSH approval label.Cylinders of purchased breathing air must have a certificate of analysisfrom the supplier that the breathing air meets the required Grade D air andmoisture content.

If compressed or liquid oxygen is used, it must meet the specifications forbreathing oxygen outlined by the United States Pharmacopoeia (USP).Compressed oxygen must not be used for any respirators that previouslyused compressed air.

All breathing air couplings must be incompatible with those of non-respirable air or other gases used at the site to prevent inadvertentservicing of air line respirators with non-respirable gases or oxygen.

11. Identification of Filters, Cartridges, and Canisters 1910.134 (j): Theemployer must ensure that all canisters and filters are properly labeled and colorcoded with the NIOSH approval label and that the label is not removed, obscured,or defaced while in service. This requirement enables the employee using therespirator to check and confirm that the respirator has the appropriate filtersbefore the respirator is used and also allows fellow employees, supervisors, andthe respirator program administrator to readily determine that the employee isusing the appropriate filters.
1. Inspection Guidelines. The CSHO should verify that properly labeledfilters and canisters are being used, and that the labels remain legible.
2. Citation Guidelines. Date and time labels applied to the filters/cartridgesshould not be considered violations, but the employer must obscure aslittle as possible of the label to allow ready identification.
12. Training and Information 1910.134 (k): The employer is required to provideeffective training to employees who wear respirators. Training must be providedprior to an employee's use of a respirator in the workplace and must becomprehensive and understandable. Training must recur annually, and more oftenif retraining appears necessary to ensure safe use. The employer must ensure thateach employee can demonstrate a knowledge of all items in (k)(1)(i) thru (vii).Pre-testing may be used as a training aid to determine extent of retrainingrequired.

1. Inspection Guidelines. The effectiveness of the training program can beevaluated by determining how well employees understand how to use theirrespirators. If respirators are improperly worn, missing parts, dirty,improperly stored, or the wrong cartridges are being used, the complianceofficer should interview the employee for knowledge of the respiratorrequirements.

Employees should be interviewed to determine if they have received therequired training and the extent of that training. If the CSHO detects atrend in employee responses that indicate training is not being conducted,or is conducted in a cursory manner, a closer review of the trainingprogram is necessary.

Employees who voluntarily wear respirators must, at least, be given theinformation in Appendix D.

2. Citation Guidelines. Lack of training should be cited. Citations forinsufficient training should usually be based on several interviews thatreveal a lack of understanding of the respirator program. Lack ofknowledge about the hazards for which the respirator is being used, couldalso indicate a deficiency in the employer's Hazard Communicationtraining [1910.1200(h)].
13. Program Evaluation 1910.134(l): The employer must conduct evaluations of theworkplace to ensure the written respiratory protection program is properlyimplemented. The employer must observe and consult employees to determine ifthey have any problems with the program and ensure that the respirators are usedproperly.

1. Inspection Guidelines. The CSHO should evaluate how well the writtenrespiratory program is being implemented in the workplace. Observeddeficiencies in the program and evaluation procedures should be discussedwith the program administrator to determine what previous efforts she orhe may have made to evaluate how well their program was working.Deficiencies should also be discussed with employees to determine howlong any deficiency has existed and what requests or complaints about therespirator program if any they have made to the program administrator. Ifthe program administrator keeps a written assessment, implementedchanges may be considered as efforts toward improvement. Recentchanges in the workplace such as new processes should have beenevaluated for necessary respiratory program changes.
2. Citation Guidelines. Multiple deficiencies found during the inspection,especially long term deficiencies, could indicate inadequate programevaluation.
14. Recordkeeping - 1910.134(m): For every employee required to wear a respirator,the employer must establish and retain medical evaluations and fit-testing records.Medical evaluation records must also be retained for employees who wearelastomeric facepiece respirators. An employee's medical evaluation recordsmust be made available to the employee and to OSHA in accordance with1910.1020. The employer must also make an employee's fit-testing recordsavailable to that employee and to OSHA. The standard does not intend for theemployer to make an employee's medical or fit-testing records available to anyother individual unless that individual is the employee's "designatedrepresentative" as defined in 1910.1020(c)(3).

1. Inspection Guidelines. Even though the employer must ensure themedical evaluations are maintained, the actual medical evaluations willnormally be maintained with the PLHCP, not the employer. Alternatively,the company nurse or doctor may maintain these files, but only medicalconfidentiality is maintained. The employer must retain a record of themedical evaluation which includes the PLHCP's written recommendation.If an employee states she or he has not had a medical evaluation, theCSHO should check if a medical evaluation record is on file.

Fit test records must be kept until the next fit test is administered. Each fittest record must contain the employee identification, type of fit test, datelast tested, the results of the test, and the make, model and size of therespirator tested. The CSHO should review these records to verify that fit-testing is being done annually and confirm that the fit-tested respirators arethe same models and sizes as those observed in the workplace.

The CSHO should also check on the availability of the written program.

2. Citation Guidelines. If a medical evaluation record cannot be found, itmust be determined whether the record was not maintained or theevaluation was not performed. If not maintained, (m)(1) would normallybe cited. If no record can be found and the employee confirms anevaluation was not performed, then (e)(1) would be cited.

Lack of a fit test record or lack of information on a fit test record would becited under (m)(2). If an employee is wearing a respirator different fromthat found in his fit test records then (f)(2) should be cited. Improper fittesting procedures would similarly be cited under the appropriatesubparagraph in (f).

15. Dates 1910.134 (n): The final standard became effective April 8, 1998. BySeptember 8, 1998, the employer must have evaluated the workplace to determineif respirator use is required. Compliance with all provisions is required no laterthan October 5, 1998.
16. Appendices: All appendices are mandatory.

1. Appendix A details fit testing protocols [see paragraph (f)(5)].
2. Appendix B-1 details User Seal Check Procedures [see paragraphg(1)(iii)].
3. Appendix B-2 details Respirator Cleaning Procedures [see paragraph(h)(1)].
4. Appendix C is the OSHA Respirator Medical Evaluation Questionnaire[see paragraph (e)(2)].
5. Appendix D is Information for Employees Using Respirators When NotRequired Under the Standard. This appendix must be provided to allemployees who voluntarily use respirators. [see paragraph (c)(2), (k)(6)]
8. Interface with Other Standards.

1. PEL Overexposures. Overexposures to Permissible Exposure Limits will usuallybe linked to compliance with the respirator standard. Most of these PEL's arelisted in Tables Z1- Z3 in 1910.1000 and Appendix A in 1926.55.
2. Standards Regulating Toxic Substance Exposure. A number of industry-specificstandards and substance-specific standards regulating exposure to toxic substanceshave been affected by the new respirator revisions. Many paragraphs from thesestandards that addressed respirator use, selection, and fit testing were deleted andnow refer to the provisions in 1910.134. Violations will now be cited under theappropriate paragraphs of 1910.134.
3. Medical Records Access. The Access to Employee Exposure and MedicalRecords Standard (29 CFR 1910.1020 ) requires that employees have access to allmedical and exposure records generated under this standard.
9. Classification and Grouping of Violations. The procedures in chapter III of the FieldInspection Reference Manual (FIRM) should be followed. The FIRM describes thecircumstances, such as proposing Willful or Criminal violations, where the CSHO or ADmay need to consult the Region or the Solicitor's office. The Citation Policy forPaperwork and Written Program Requirement Violations, CPL 2.111 , should bereviewed for guidance when citing the written program.
10. Authorization to Review Limited Medical Information. Appropriately qualifiedcompliance personnel are authorized to review medical records and medical opinionspertinent to compliance with the Respiratory Protection Standard. There are fourdirectives that address the limitations and procedures which are to be followed. They areOSHA Instruction(s) CPL 2-2.30 (Authorization to Review Medical Opinions); CPL2-2.32 (Access to Biological Monitoring Results); CPL 2-2.33 (Written Access Orders);and CPL 2-2.46 (Authorization to Review Specific Medical Records). In general, each ofthese instructions defines "qualified compliance personnel" as a field-qualified IndustrialHygienist who is at the journeyman level or a professional with specific training orexperience in medical disciplines. When inspections are conducted by teams, the Teamleader should ensure that a team member is so qualified.
11. Training for OSHA Personnel.

1. CSHO Experience. For all inspections on a site where respirators are used and theexposures are expected to be above the 8-hour TWA or the STEL, onlyexperienced and properly trained CSHOs shall perform the on-site evaluations.CSHOs are expected to be knowledgeable of the:

1. Potential hazards which may be encountered at the site,
2. Contents of the Respiratory Protection standard,
3. Appropriate PPE to be worn. Each CSHO who will be expected to usePPE must be trained in the proper care, use, and limitations of the PPE.

Instructions for the use of respiratory protection by CSHO's are containedin OSHA Instruction CPL 2-2.54. The CSHO should closely review andexamine all the data available on site concerning the exposures or potentialexposures in this particular location. If the employer cannot supplyadequate data to support the selection of the types of respirators that are inuse, the CSHO must not enter the areas where respirators are in use. If thehazard determination performed by the employer has been completed inaccordance with the standard, the CSHO must don the appropriaterespirator required in that work-site prior to the walkaround in areas whererespirators are required.

2. Emergency Procedures. For all inspections on a site where OSHA personnel areinvestigating an emergency that involves hazardous substances, the CSHO mustbe knowledgeable of:

1. Appropriate training required by 29 CFR 1910.120, or any applicableannual refresher training;
2. The ARA for Technical Support must be consulted for assistance indetermining the appropriateness of SCBA use by CSHOs.
12. Medical Examinations for OSHA Personnel.

1. Regional Administrators and Area Directors are responsible for implementing theCSHO Medical Examination program in accordance with OSHA Instruction,PER 8-2.5. This medical evaluation is more stringent than what is required by therevised Respiratory Protection Standard.
2. Many of the hazards that CSHO's may encounter are already regulated by themedical surveillance requirements in other OSHA standards. CSHOs who arerequired to wear any respiratory protection and Level A or B PPE must bemedically cleared via the CSHO Physical Examination procedures.
13. Protection of OSHA Personnel. The paramount concern addressed in this section is theprotection of the CSHO. Compliance Officers are reminded about Agency policy thatrequires that appropriate personal protective equipment be used when exposed to ahazard. When and if a CSHO is not adequately protected by the use of appropriate PPE,the CSHO should stay out of the contaminated area to avoid being overexposed to anyhazardous substance.

1. Personal Protective Equipment (PPE).

1. Regional Administrators and Area Directors must ensure that appropriatePPE is available for the CSHO.

1. Respirators must be selected in accordance with 1910.134.
2. Eye and face protection must meet the requirements of 29 CFR1910.133.

A brief description of some currently available approaches or methods for respirator cartridgechange schedules is presented below. The CSHO should assess the "Good Faith" efforts of theemployer on a case by case basis and contact appropriate regional OR National office staff forguidance, as necessary. This is not intended to be an exhaustive list, but a summary of somereasonable methods that an employer may take in creating a change schedule. No matter whichmethod is used, the employer must maintain any data used in making their decision as part oftheir program.

Manufacturers Objective Data: Respirator cartridge model-specific objective data that isavailable from the manufacturer or through a distributor may be used to establish changeschedules. Objective data may be presented in tabular or graphical format or simply providedverbally over a manufacturer's telephone help line. Some manufacturers have developedelaborate computer programs available on the Internet that provide the necessary objective datato the user.

Experimental Methods: Experimental breakthrough-time data from a laboratory based onworst case testing of simulated workplace conditions. This method can provide fairly accurateservice life data compared to other available methods.

Mathematical Predictive Modeling: One tool that has demonstrated value is the use ofmathematical modeling based on predictive equations. These models are typically complex andrequire considerable expertise to apply. They also require some proprietary information from therespirator manufacturer. OSHA fully supports the further development and validation of thesemodels. The agency believes that respirator manufacturers may be in the best position to applythem to their products.

Analogous Chemical Structures: Employer would rely on service life values from otherchemicals having analogous chemical structure to the contaminant under evaluation forbreakthrough. Or in some cases a chemical with known migration may reasonably be anticipatedto act as a surrogate for a similar chemical that would have less rapid migration (e.g., anemployer could assume that a heavier, less volatile compound than another in the same chemicalseries that had been tested for breakthrough would breakthrough no faster than the lattercompound, such as benzene versus toluene.) The use of this method requires a substantialamount of judgement and assumption of similar chemical properties. The use of analogouschemical structures should be infallible as long as objective data or information for lowermolecular weight compounds is used to predict the breakthrough times for higher molecularweight analogues containing only additional methyl or phenyl groups. Data from highermolecular weight groups should not be used to predict the behavior of analogous substances withlower molecular weight. This approach relies heavily on experimental data and expert analysis.This method may be less accurate than others and should be used only when better information isnot available.

Workplace Simulations: Unvalidated methods exist or are under development where therespirator cartridge is tested in the workplace in "real time" and under actual conditions of use.Simple designs have been informally described to the agency. Workplace air duringrepresentative conditions is drawn over the cartridge at a rate approximating normal breathing ata higher work rate. An air sampling/analytic device would be placed on the other side of thefilter to measure the time of breakthrough. Employers could incorporate this type of testing intotheir air monitoring program using sampling strategies established in their workplace. Intheory, these approaches should be an accurate method for determining change schedules andcould accommodate fluctuating conditions of humidity, concentration, etc., to allow lessconservative schedules that utilize a larger fraction of the true service life.

Rules of Thumb: Generalized rules or guidance can be generated from experimental work.Presented below is a rule of thumb for estimating organic vapor service life found in Chapter 36of the American Industrial Hygiene Association publication

"The Occupational Environment Evaluation and Control".

*If a chemical's boiling point is >70 C and the concentration is less than 200 ppm youcan expect a service life of 8 hours at a normal work rate.
Note: This first rule of thumb needs further review.

* Service life is inversely proportional to work rate.

* Reducing concentration by a factor of ten will increase service life by a factor of five.

* Humidity above 85% will reduce service life by 50%.

These generalizations should only be used in concert with one of the other methods of predictingservice life for specific contaminants.

5(a)(1)

administrative controls

air compressor

air-purifying

Appendix C

Appendix D

appropriate

carbon monoxide

cartridge

change schedule

confidentiality

construction

cost

elastomeric

emergency

engineering

escape

examination

exposure limit

facial hair

filtering facepiece

firefighting

fit

fit test

gases

Grade D

HEPA

IDLH

incipient

licensing board

maintenance

medical

N95

NIOSH

objective data

oil

oxygen deficient

PAPR

particulate

permissible exposure

physician

PLCHP

program administrator

protocols

QLFT

quantitative

questionnaire

rescue

SCBA

scope

seal check

training

tuberculosis

two-in/two-out

user seal

vapors

voluntary use

warning properties

written program