When Change is Necessary – 11/11/13

Number 4 of OSHA’s top 10 cited violations for 2013 (now found on the OSHA website at https://www.osha.gov/Top_Ten_Standards.html), is Respiratory Protection. While we don’t have exact data as to why these citations were issued, we can offer some safety tips that might help you to not be part of the statistic for next year.

One component of a comprehensive respiratory protection is something called a “change-out schedule.” This is something we occasionally find overlooked at workplaces. A change-out schedule is simply something that can tell the person wearing a respirator an appropriate time to change the cartridge on their respirator. A cartridge can, over time and with extended use, become ineffective in protecting the wearer from the harmful contaminant in the atmosphere. Because you don’t want to take a chance on becoming exposed to something that could damage your ability to breathe properly – your respiratory protection – you want to do something before the cartridge becomes ineffective. In the past, the need for change was detected when the user of the cartridge detected breakthrough of the material into the mask. This was often noted by a smell, taste, or irritation. However waiting until the unit failed is no longer acceptable.

So how do you know when to implement a change? OSHA requires that you institute a system of changing out the cartridge before it is a real problem with what is called a “change-out schedule.” You schedule to change the cartridge based on a number of factors, including how fast and/or hard the worker is breathing, temperature and/or other environmental factors, the ability of the cartridge to filter the contaminant, and the amount of contaminant that is present.

How do you develop a change-out schedule? You can conduct experimental tests, and then develop your own schedule. You can use your own math. Or, you can use other, reliable sources for change-out schedules. Who else might have a reliable schedule for you? The manufacturers of most respirator cartridges have change-out schedules for those cartridges. OSHA acknowledges that using the manufacturer’s schedule is acceptable. Here’s a link to OSHA’s guidelines on change-out schedules: https://www.osha.gov/SLTC/etools/respiratory/change_schedule.html.

And then you build in a safety factor. What’s a safety factor? If you are using the manufacturer’s software, calculate it based on the worst case conditions. Assume that you are at the highest level where you will allow cartridge use. Assume that the person is working in the most physically challenging environment. If you do that you will come up with conservative numbers that are clearly protective and defensible should you be challenged.

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