Respiratory Protection Standard Inspection procedures -
OSHA Directive CPL 2-0.120

1. Availability of Objective Data: Ascertain if there are sources of objective data for the particular make and model of the respirator cartridge/canister and if this data is sufficient to implement change schedules. Typical sources would include: respirator manufacturers, industry organizations, trade associations, professional societies, chemical manufacturers (MSDS), academic institutions, and ad hoc committees. The CSHO should determine if the employer has access to adequate information to comply with this provision. For a list of some options that employers may use in developing their change schedules, refer to Appendix A.
2. Use of Inappropriate Respirator Cartridge/canister: Determine if the air purifying respirator is appropriate for the contaminant present in the workplace. In some cases, the breakthrough time may be so rapid (minutes) that air purifying respirators are not feasible and supplied air respirators should be used. CSHOs should consult respirator manufacturers and other reference material for this information.
3. Change Schedules For Mixtures: Establishing cartridge service life for mixtures of contaminants is a complex task and one that requires considerable professional judgement to create a reasonable change schedule. Cartridge service life for mixtures is best determined using experimental methods. Change schedules are very difficult to develop for mixtures using predictive mathematical models.

   The change schedule for a mixture should be based on reasonable assumptions that include a margin of safety for the worker wearing the respirator. Where the individual compounds in the mixture have similar breakthrough times (i.e. within one order of magnitude), service life of the cartridge should be established assuming the mixture stream behaves as a pure system of the most rapidly migrating component or compound with the shortest breakthrough time (i.e., sum up the concentration of the components). Where the individual compounds in the mixture vary by 2 orders of magnitude or greater, the service life may be based on the contaminant with the shortest breakthrough time. OSHA believes that an approach such as this reflects good health and safety practice where neither objective or experimental data is available for the mixture.

   OSHA believes that change schedule information will become more available to the respirator user community and will evolve in quality. The CSHO should review the written respiratory protection program to ensure that it describes the information and data relied upon and the basis for the canister and cartridge change schedule and the basis for reliance on the data as required by the standard. Again, CSHOs should exercise judgement in evaluating mathematical models, rules of thumb, experimental data, use of analogous chemical structures, and other reasoned approaches.

4. Chemical Contaminant Migration: CSHO's should be aware that some contaminants have a tendency to migrate through cartridge/canister sorbent material during periods of storage or non-use. This is characteristic of the contaminant-carbon bed interaction for organic chemicals with boiling points below 65 Centigrade and would predictably shorten breakthrough times. In cases where respirators are used for multiple days this could present an additional exposure to the respirator user. Where contaminant migration is possible, respirator cartridges/canisters should be changed after every workshift where exposure occurs unless the employer has specific objective data to the contrary (desorption studies) showing the performance of the cartridge in the conditions and schedule of use/non-use found in the workplace.

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

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

In order to maintain strict confidentiality of the information obtained in the questionnaire, the employer's role is limited to distributing the blank questionnaire to the employee for him or her to fill out, or providing it to the PLHCP, who will administer the questionnaire to the employee. If the employer provides the questionnaire to the employee, an addressed and postage-paid envelope should also be provided for the employee to mail it to the PLHCP. The questionnaire and findings may also be maintained by the employer's medical office, if the health office is administratively separate from the employer's central administration 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 healthcare professional (PLHCP) to perform the medical evaluations. The PLHCP may be a physician, a registered nurse, a nurse practitioner, a physician assistant, or other licensed 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 her professional license to conduct the type of medical evaluation required by the respirator standard. Scope of practice for non-physician PLCHPs will vary from state to state. All PLCHPs who participate in any aspect of the medical evaluation must be practicing within the scope of their license. For assistance in determining which state licensing board or agency to contact to determine a PLCHP's legally permitted scope of practice, the CSHO can contact the Directorate of Technical Support in OSHA's National Office.

The employer must ensure that the questionnaire is administered in such a manner that employees can understand the content and the confidentiality of the record is maintained. Where the employee cannot understand English, the employer must have the questionnaire translated into the employee's language either through a translator or a translated written copy. The questionnaire has been translated into Spanish and is available on OSHA's homepage (www.osha.gov) in the Respirator Q & A Document. In cases where the employee cannot read, the employee can request someone other than the employer to orally read them the questionnaire or the PLHCP may obtain through an interview or examination the same information requested on the medical questionnaire.

1. Inspection Guidelines. The CSHO should determine if the requirements of paragraph (e) are being met by interviewing a number of employees and asking if they have been provided with a confidential evaluation of their ability to wear a respirator, either by the administration of the medical questionnaire or by physical examination. Compliance officers should determine what mechanism the employer is using to ensure that the employer does not see the answers to the questionnaire in order to maintain confidentiality. The CSHO can verify that these medical evaluations have in fact been conducted by asking the employer to see the written recommendation of the employee's ability to use a respirator. The employee should have also received a copy. The recommendation must contain only the information required by subparagraph (e)(6).

   The CSHO should determine what supplemental information was given to the PLHCP by the employer. This can be done through interviewing the PLHCP or reviewing documentation from the employer. If the employer is relying on a medical evaluation for the employee from a previous employer (which is allowed only when the employer uses a transient workforce), the CSHO should determine that the work conditions and respirator remained the same.

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

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

   If questions arise regarding the issue of qualifications of the PLHCP, the CSHO should inquire with the state licensing board or the applicable registration or certification agencies in that state to ensure that the PLCHP is acting within the scope of his or her practice.

2. Citation Guidelines: If medical evaluations are not provided, a violation of (e)(1) exists. If the PLHCP designated by the employer is not operating within 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 an inappropriate PLHCP.
   1. If the employer's medical evaluation does not obtain the mandatory information 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 supplemental information, a violation of (e)(5) exists.

The fit test must be performed before the respirator is used in the workplace. It must be repeated at least annually and whenever a different respirator facepiece is used or a change in the employee's physical condition could affect respirator fit. If the respirator subsequently becomes unacceptable (i.e., causes irritation or pain to the employee) to the employee, the employee must be given the opportunity to select 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 times the PEL, since existing evidence only validates the QLFT protocols listed in Appendix A to identify respirators that achieve a fit factor of 100. For greater concentrations, Quantitative Fit-Testing (QNFT) must be used. When quantitative fit-testing is used, all full-facepiece respirators must meet or exceed a fit factor of 500, while quarter - and half-mask respirators must meet or exceed 100. For all positive pressure, atmosphere-supplying respirators, either qualitative or quantitative fit testing may be used. While atmosphere-supplying respirators are fit-tested in the negative pressure mode, these respirators are most often used as positive pressure respirators in the workplace. Positive pressure atmosphere-supplying respirators that pass the QLFT or QNFT fit test may be used at the higher protection factors assigned these respirators. See Table 1 for a summary.

1. Inspection Guidelines. The CSHO should determine which protocol was used for fit testing and if all employees who are wearing tight-fitting respirators have been fit-tested in the last twelve months for the respirator they are wearing. Fit testing procedures should be discussed with the program administrator. If fit testing is being performed, the CSHO should observe the company's procedures and evaluate their adherence to the prescribed protocol.
   1. Where employees move from job to job within the year (e.g., temporary or construction workers), their fit test need not be repeated, if the employer obtains a copy of the original fit test record and the same respirator make, model and size is available and appropriate for use at their new work site.
2. Citation Guidelines . Fit test records should be reviewed. If no fit test record 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 for negative pressure APR's used in atmospheres greater than 10 times the PEL would be cited as (f)(6).
   1. If fit testing was done by a previous employer within the required time, but no fit test record was obtained by the current employer, a citation for (m)(2) should be issued.
   2. If the CSHO determines the fit testing was not appropriate for the present respirator usage, citations for the appropriate requirements of paragraph (f) should be issued.

1. Facepiece Seal Protection (g)(1) :
   1. Inspection Guidelines - The CSHO should be alert for the presence of facial hair (more than one day's growth) that comes between the sealing surface of the respirator and the face as well as other conditions that could result in facepiece seal leakage or interfere with valve function of tight-fitting respirators, such as the presence of facial scars, the wearing of jewelry, or the use of headgear that projects under the facepiece seal. Corrective glasses or goggles or other personal protective equipment (such as faceshields, protective clothing, and helmets) must not interfere with the seal of the facepiece to the face of the user. If employees wear other safety equipment with their respirators, the employee must pass an appropriate fit test while wearing the equipment to determine if it interferes with the seal.

      Employees should be observed to determine if the seal check procedures are being performed each time the respirator is donned. The procedure used must be one listed in Appendix B-1 or recommended by the manufacturer if the employer demonstrates it is as effective as those listed in Appendix B-1. Alternative seal checks must be based on scientific studies. [The face fit is considered satisfactory if a slight positive pressure can be built up inside the facepiece when the exhalation valve or surface is covered, the user exhales gently, and there is no evidence of outward leakage at the seal. The negative check requires covering the inlet opening or surface, inhaling gently, and having the facepiece remain in a slightly collapsed condition with no inward leakage of air detected.]

   2. Citation Guidelines - CSHO should cite (g)(1)(i)(A) when employees' facial hair comes between the sealing surface of the facepiece 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) when the employee is wearing equipment (e.g., glasses, goggles, helmets, etc.) that affects the face-to-facepiece seal, but was not worn during fit testing; (g)(1)(iii) if user seal checking is not being performed or the employer has not demonstrated that the procedures used are those listed in or as effective as those in Appendix B-1. This paragraph should not be cited in voluntary use situations, 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 regular surveillance of the workplace necessary to evaluate the effectiveness of the respirator program. The surveillance procedures may include continuous or periodic monitoring, on-site observations, and notation of problems. The intensity of the surveillance should be tailored to the hazards present in the workplace. Highly hazardous substances that pose acute respiratory hazards merit a higher degree of surveillance.

      Section (g)(2)(ii) requires that employers ensure that employees leave the respirator-use area to correct certain problems associated with respirator use, including the detection of contaminant breakthrough, and to replace the respirator or its filters or cartridges. Employees should be interviewed [e.g., What do you do if you notice a leak? ] to determine whether there are any policies or actions which would prohibit or impede them from leaving the area should they have significant problems with their respirators or which impede the replacing of filters or cartridges. Paragraph (g)(2)(iii) is designed to prevent employees from reentering a workplace after leaving because of a significant respirator failure without first assuring the proper functioning of the respirator.

   2. Citation Guidelines - The CSHO should cite (c)(1)(ix) if the written procedures are inadequate to identify problems or changes; (g)(2)(i) if the routine surveillance of the work conditions is not performed; the appropriate section of (g)(2)(ii)(A), (B) or (C), if prohibitions to leaving an area are identified or if employees fail to leave the area when the standard requires them to do so; (g)(2)(iii) if employees are allowed back into an area before the employer has replaced or repaired the respirator.
3. Procedures for IDLH Atmospheres (g)(3):
   1. Inspection Guidelines - The employer must be prepared for emergency rescue or respirator failure whenever employee(s) are working inside of an IDLH atmosphere. At least one person must be on standby outside the IDLH atmosphere and maintain communication with the person inside at all times. The standby person(s) must be trained and equipped to provide an effective emergency rescue. Except in emergency situations, environments containing IDLH atmospheres are frequently well enough characterized and controlled that a single standby person can monitor the status of multiple entrants. The need for multiple standbys should be evaluated in context with the ability of the standby personnel to meet all their standby duties, including their ability to monitor the worker(s) in the area and their ability to initiate effective rescue procedures. Planning is critical for effective response to emergency situations through the development of specific emergency procedures. These procedures should address how the employer will be notified when standby person(s) outside of the IDLH atmosphere enter the IDLH atmosphere to provide emergency rescue and what actions will be taken or assistance provided by the employer. Emergency procedures must be developed and included in the employer's written respirator program.

      For work performed outside of visual contact, voice, radio or signal line are permitted. CSHOs should specifically review protocols for communication, rescue, and notification for employees entering IDLH atmospheres. Communication protocols must be established that allow the standby person to monitor entrant status and enable the standby(s) to alert entrants of the need to evacuate the area. It is not sufficient to rely on the employees in the IDLH area to call for help when needed.

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

   2. Citation Guidelines - If an IDLH area meets the definition of a confined space, then the requirements of 1910.146 would apply and the appropriate section of 1910.146 should be cited where deficiencies are noted. If the IDLH is a result of an uncontrolled release of a hazardous substance, then the appropriate section of the 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 the entrants 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): This section applies to private sector workers engaged in firefighting, including those working in industrial fire brigades and private incorporated fire companies, and to Federal employees under Section 19 of the Act. These or equivalent provisions apply to State and local government firefighters only in the 25 States that operate OSHA-approved State plans which are required to adopt an identical or "at least as effective" standard and extend its coverage to public employees. (Coverage of volunteer firefighters in these States varies by State and depends on State law.) The following guidance will have applicability primarily in the State Plan States and in responding to general inquiries.

   The provision is limited to workers performing an interior attack on an interior structural fire. In Subpart L ( 1910.155), OSHA has defined "interior structural fire fighting" to mean: "the physical activity of fire suppression, rescue or both, inside of buildings or enclosed structures which are beyond the incipient stage." This is firefighting to control or extinguish a fire in an advanced stage of burning, producing large amounts of smoke, heat and toxic products of combustion. Firefighter exposure during this activity is extremely hazardous. The atmosphere is considered IDLH and the use of Self Contained Breathing Apparatus is required. By contrast, incipient stage fire fighting involves the control or extinguishment of a fire in the initial or beginning stage, using portable fire extinguishers or small hose lines without the need for personal protective equipment. It is the incident commander's responsibility, based on training and experience, to judge whether a fire is an interior structural fire, 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. must always be at least two firefighters stationed outside during interior structural firefighting, and they must be trained, equipped and prepared to enter if necessary to rescue the firefighters inside. However, the incident commander has the responsibility and flexibility to determine when more than two outside firefighters are necessary given the circumstances of the fire. The two-in/two-out rule does not require an arithmetic progression for every firefighter inside, i.e. the rule should not be interpreted as 4-in-4-out, 8-in-8-out, etc. is important that the CSHO recognize that life-saving activities in interior structural fire fighting are not precluded by the standard. There is an explicit exemption in the standard that if life is in jeopardy, firefighters have the discretion to perform the rescue, and the "two-in/two-out" requirement is waived. There is no violation of the standard under such life-saving rescue circumstances. two-in/two-out provision is not intended as a staffing requirement. It does not require fire departments to hire additional firefighters; it does not require four-person fire companies; it does not require four persons on a fire truck. Most fire departments have more than four firefighters and can assemble the numbers required on the scene by waiting for others to arrive. During this time the fire may be attacked only from the outside, sizing-up operations may occur, and emergency rescue necessary to save lives may take place as discussed above. The "two-in/two-out" rule is a worker safety practice requirement, not a staffing requirement. standard allows one of the standby firefighters to have other duties such as serving as the incident commander, safety officer, or operator of fire apparatus. However, one of the outside firefighters must actively monitor the status of the inside firefighters and may not be assigned additional duties. The second outside firefighter may be involved in a wide variety of activities. Both of the outside personnel must be able to provide support and assistance to the two interior firefighters; any assignment of additional duties for one of the outside firefighters must be weighed against the potential for interference with this requirement. Proper assignment of firefighting activities at an interior structural fire must be determined on a case-by-case basis and is dependent on the existing firefighting situation. Compliance will always depend on consideration of all the worksite variables and conditions, and the judgement of the incident commander is critical in meeting this performance standard. two firefighters (buddies) entering an IDLH atmosphere to perform interior structural firefighting must maintain visual or voice communication at all times. Electronic methods of communication such as the use of radios shall not be substituted for direct visual contact between the team members in the danger area. However, reliable electronic communication devices are not prohibited and certainly have value in augmenting communication and may be used to communicate between inside team members and outside standby personnel. further explanation refer to the preamble of the Respiratory Protection standard (vol. 63, No. 5, 1245-1248) and the Respirator Question and Answer document (August 3, 1998). Both documents 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 employers response using the two-in/two-out rule is to determine if there was interior structural fire fighting activity. This determination will require consideration of the factors existing at the time of the firefighting action and the basis for the Incident Commander's finding. CSHO should seek expert opinion from other authorities such as a state or local fire Marshall or other fire protection professionals and should thoroughly interview affected personnel to document the violation.
   3. Citation Guidelines - If the CSHO's investigation reveals that the two-in/two-out rule was not followed during the interior attack of an interior structural fire and there was no reasonable expectation that someone was in jeopardy inside the building, the CSHO should cite (g)(4)(i) or (g)(4)(ii) as a serious violation. If adequate communication is not maintained between the team inside and the standby personnel located outside the IDLH, (g)(3)(ii) should be cited.

1. Inspection Guidelines. To ensure that respirators are clean and in good working order, the employer can have respirators cleaned and repaired in a centralized operation where respirators are passed out to employees OR the employer may require the respirator user to perform all cleaning and respirator maintenance functions. The CSHO should verify that the procedures in the mandatory Appendix B-2 or an equivalent method specified by the manufacturer are being followed and are performed by employees who are adequately trained in the proper respirator care procedures. Respirators issued to more than one employee must be cleaned and disinfected before being worn by another user. The use of individually-wrapped cleaning towelettes may be used as an interim method in the cleaning schedule for individually assigned respirators, but they must not be the only method in place. During fit-testing, towelettes may also be used between employees being tested, however these respirators must be thoroughly cleaned at the end of each day, using the procedures in Appendix B-2.

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

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

   The CSHO should also observe how respirators are stored in the workplace. Respirators must be properly stored to protect them against physical damage, contamination, excessive moisture, extreme temperatures, sunlight, and damaging chemicals. Emergency use respirators must be stored in compartments OR in covers, both of which must be clearly marked as containing the emergency respirators.

2. Respirators That Are Available for Emergency Use : An inspection must be conducted monthly for all emergency use respirators. The employer must certify in writing that an inspection was performed. The certification must include the name (or signature) of the person who made the inspection, the findings of the inspection, any remedial action, and a serial number or other means of identifying the inspected respirator. The respirator must also be checked before and after each use.
   1. Emergency escape-only respirators carried by employees must be inspected before being taken into the workplace for potential use.
3. Section (h)(4) Repairs : Defective respirators must be removed from service. A respirator is defective if one or more of its components is missing, damaged, or visibly deteriorated. The employer must develop some means to ensure defective respirators are not used in the workplace. The employer can comply by placing an "out of service" tag on the respirator to help ensure that the defective respirator is not inadvertently used or by removing the respirator from the work area. An "appropriately trained" person must be responsible for performing repairs or adjustments to respirators.
4. Inspection Guidelines . The CSHO must interview the employee(s) at the worksite who repair respirators, and determine what training they have received. An appropriately trained person is an individual who has received training from the manufacturer or otherwise has demonstrated that he or she has the skills to return the respirator to its original state of effectiveness. The training is performance-oriented, so it is acceptable for the employee to have acquired the skills through practice rather than by attending a formal training course. Repairs to reducing and admission valves, regulators, and alarms must be done by a technician trained by the manufacturer.
   1. Only the respirator manufacturer's NIOSH-approved parts that are designed for the particular respirator being repaired can be used to repair a respirator.
   2. CSHOs should cite for defective respirators not effectively being removed from service.

1. Inspection Guidelines. If compressors are used to supply breathing air, the CSHO should note the location of the compressor intake and ensure it is located in an area uncontaminated by either combustion exhaust gases produced by vehicles or the compressor itself (if applicable), or by other exhaust gases ventilated from plant processes. A tag containing the signature of the person authorized by the employer to change the in-line sorbent beds and filters and the date of the latest change must be maintained 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 levels in the breathing air do not exceed 10 ppm. Some practical methods for ensuring that the carbon monoxide level does not exceed 10 ppm include; placing the air intake for the compressor in an area that the employer knows is free from contaminants; frequent or continuous monitoring of the breathing air supply; the use of carbon monoxide filters; or the use of a high temperature alarm or shut off devices.

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

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

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

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

1. Inspection Guidelines. The CSHO should verify that properly labeled filters and canisters are being used, and that the labels remain legible.
2. Citation Guidelines . Date and time labels applied to the filters/cartridges should not be considered violations, but the employer must obscure as little as possible of the label to allow ready identification.

1. Inspection Guidelines. The effectiveness of the training program can be evaluated by determining how well employees understand how to use their respirators. If respirators are improperly worn, missing parts, dirty, improperly stored, or the wrong cartridges are being used, the compliance officer should interview the employee for knowledge of the respirator requirements.

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

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

2. Citation Guidelines. Lack of training should be cited. Citations for insufficient training should usually be based on several interviews that reveal a lack of understanding of the respirator program. Lack of knowledge about the hazards for which the respirator is being used, could also indicate a deficiency in the employer's Hazard Communication training [1910.1200(h)].

1. Inspection Guidelines. The CSHO should evaluate how well the written respiratory program is being implemented in the workplace. Observed deficiencies in the program and evaluation procedures should be discussed with the program administrator to determine what previous efforts she or he may have made to evaluate how well their program was working. Deficiencies should also be discussed with employees to determine how long any deficiency has existed and what requests or complaints about the respirator program if any they have made to the program administrator. If the program administrator keeps a written assessment, implemented changes may be considered as efforts toward improvement. Recent changes in the workplace such as new processes should have been evaluated for necessary respiratory program changes.
2. Citation Guidelines. Multiple deficiencies found during the inspection, especially long term deficiencies, could indicate inadequate program evaluation.

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

   Fit test records must be kept until the next fit test is administered. Each fit test record must contain the employee identification, type of fit test, date last tested, the results of the test, and the make, model and size of the respirator tested. The CSHO should review these records to verify that fit-testing is being done annually and confirm that the fit-tested respirators are the 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, it must be determined whether the record was not maintained or the evaluation was not performed. If not maintained, (m)(1) would normally be cited. If no record can be found and the employee confirms an evaluation 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 be cited under (m)(2). If an employee is wearing a respirator different from that found in his fit test records then (f)(2) should be cited. Improper fit testing procedures would similarly be cited under the appropriate subparagraph in (f).

1. Appendix A details fit testing protocols [see paragraph (f)(5)].
2. Appendix B-1 details User Seal Check Procedures [see paragraph g(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 Not Required Under the Standard. This appendix must be provided to all employees who voluntarily use respirators. [see paragraph (c)(2), (k)(6)]

1. PEL Overexposures. Overexposures to Permissible Exposure Limits will usually be linked to compliance with the respirator standard. Most of these PEL's are listed in Tables Z1- Z3 in 1910.1000 and Appendix A in 1926.55.
2. Standards Regulating Toxic Substance Exposure. A number of industry-specific standards and substance-specific standards regulating exposure to toxic substances have been affected by the new respirator revisions. Many paragraphs from these standards that addressed respirator use, selection, and fit testing were deleted and now refer to the provisions in 1910.134. Violations will now be cited under the appropriate paragraphs of 1910.134.
3. Medical Records Access. The Access to Employee Exposure and Medical Records Standard (29 CFR 1910.1020 ) requires that employees have access to all medical and exposure records generated under this standard.

1. CSHO Experience. For all inspections on a site where respirators are used and the exposures are expected to be above the 8-hour TWA or the STEL, only experienced 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 use PPE must be trained in the proper care, use, and limitations of the PPE.

      Instructions for the use of respiratory protection by CSHO's are contained in OSHA Instruction CPL 2-2.54. The CSHO should closely review and examine all the data available on site concerning the exposures or potential exposures in this particular location. If the employer cannot supply adequate data to support the selection of the types of respirators that are in use, the CSHO must not enter the areas where respirators are in use. If the hazard determination performed by the employer has been completed in accordance with the standard, the CSHO must don the appropriate respirator required in that work-site prior to the walkaround in areas where respirators are required.

2. Emergency Procedures. For all inspections on a site where OSHA personnel are investigating an emergency that involves hazardous substances, the CSHO must be knowledgeable of:
   1. Appropriate training required by 29 CFR 1910.120, or any applicable annual refresher training;
   2. The ARA for Technical Support must be consulted for assistance in determining the appropriateness of SCBA use by CSHOs.

1. Regional Administrators and Area Directors are responsible for implementing the CSHO Medical Examination program in accordance with OSHA Instruction, PER 8-2.5. This medical evaluation is more stringent than what is required by the revised Respiratory Protection Standard.
2. Many of the hazards that CSHO's may encounter are already regulated by the medical surveillance requirements in other OSHA standards. CSHOs who are required to wear any respiratory protection and Level A or B PPE must be medically cleared via the CSHO Physical Examination procedures.

1. Personal Protective Equipment (PPE) .
   1. Regional Administrators and Area Directors must ensure that appropriate PPE 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 CFR 1910.133.