A Voluntary Respiratory Protection Program

 In 2022, Tip of the Week

One of the remnants of COVID-19 is the use of respirators, info linked below:


Understanding Compliance with OSHA’s Respiratory Protection Standard During COVID

 

In most cases, the use of tight-fitting respirators is to be offered to employees when they ask for them on a voluntary basis. When employees use respirators voluntarily, a Voluntary Respiratory Protection Program (VRPP) is required.


What is a VRPP and how do you put one into place?

1.  OSHA specifies the requirements of a VRPP in 29 CFR Part 1910.134(c)(2) “Where respirator use is not required….” However, to ensure that atmospheric conditions in the workplace are safe so that respirators are not required, we need to go back to paragraph (a)(1) of the regulation, which stipulates that respirators are required when there are atmospheric or inhalation hazards that cannot be controlled to a safe or permissible level by engineering or other controls. So, the first thing that must be done is to establish (a) whether there are atmospheric hazards, and (b) whether those hazards cannot be controlled through ventilation or other engineering controls.

How do you establish whether the atmospheric hazards, which could be infectious diseases or any type of hazard such as dust, vapors, smoke, etc.? This is commonly accomplished through an industrial hygiene study of the area, where the atmosphere or area with the potential for hazards is sampled and then analyzed most often in a laboratory. The results of that study will give us the information as to whether a respirator is required or whether the use of the respirator would be voluntary at the request of employees.

2. Because we are discussing voluntary respirator use, we are going to assume that there are no known inhalation hazards in the area where employees are working. These employees can still request to wear a respirator. At that point there are a few things that must be done to meet OSHA requirements.

The first thing is that the employer must make sure that using a respirator will not cause the employee any harm by providing the employee a medical evaluation at no charge to the employee. Wearing respirators can be hot, is sometimes uncomfortable, and could possibly exacerbate preexisting conditions, like asthma, for example. So, the same medical evaluation that would be provided for mandatory respirator use must be provided for voluntary use of the respirator.

It is important to note here that fit testing for voluntary respirator use is not required. Employees could have facial hair, the respirator could be loose-fitting, and pressure checks do not have to be conducted. Because the use of the respirator is at the request of the employee, and it has been proven that there is not an inhalation hazard, we don’t need to make sure respirator is protecting the employee.

3. Employees who voluntarily wear respirators at their request must be given a copy of Appendix D to the regulation (linked here: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134AppD) The regulation does not mandate that employees be trained, just that they receive a copy of this Appendix. SCM disagrees with the regulation about training. Even though training is not required, we believe it is a good idea.

4. Like most other safety things, if it is not in writing, it may not exist in OSHA’s eyes. The VRPP should be in writing. If the organization or company has a written respiratory protection program for other areas or operations, the VRPP can be included in. the written program. Or, if the only use at the company is voluntarily, then a written VRPP should be developed. The one exception to having a written VRPP is when only dust masks are being used by employees.

A VRPP is not complicated, or difficult to maintain. If you have further questions, let us know. We’d be happy to help you.

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