Long term care (LTC) centers must adhere to specific requirements for compliance with the Occupational Health and Safety Administration (OSHA) Respiratory Protection Standard (29 CFR 1910.134). The nature of airborne hazards, the presence of respiratory threats, the specific respiratory protection program, and the resulting compliance requirements will vary between organizations. Employers must recognize that once a Respiratory Protection Program (RPP) is established, ongoing maintenance is necessary to ensure compliance with the OSHA standard.
The following are areas of a Respiratory Protection Program that likely require regular action by the organization:
- Training and Retraining:
- Section 1910.134(k) outlines comprehensive training requirements for employees using respirators in the workplace. Training should be easily understandable and recurrent, with an annual frequency and more frequent sessions as needed.
- Recommendations:
- Conduct initial training before the employee must wear a respirator to cover respiratory hazards and proper respirator usage.
- Conduct annual training sessions covering respiratory hazards, proper respirator usage, and changes in the workplace affecting respirator use.
- Retrain employees as necessary, particularly in response to workplace changes or if deficiencies in understanding or skills are identified.
- Fit Testing:
- Section 1910.134(f) addresses fit testing procedures and specifies the methods to assess the effectiveness of a respirator's seal.
- Recommendations:
- Conduct fit testing before employees are required to use respirators.
- Conduct fit testing annually for each employee required to wear a respirator.
- Perform fit testing whenever there are changes in facial characteristics, respirator model or size, or other conditions impacting the respirator's fit.
- Medical Evaluations:
- Section 1910.134(e)(1) mandates medical evaluations to determine an employee's ability to use a respirator before fit testing or respirator use.
- Recommendations:
- Complete medical questionnaires and obtain clearance for employees before they are required to wear a respirator.
- Ensure medical clearance whenever there is a significant change in an employee's health status.
- NOTE: OSHA does not require annual medical evaluation or clearance.
- Program Evaluation:
- Section 1910.134(c)(1) underscores the importance of regularly reassessing the effectiveness of the respiratory protection program.
- Recommendations:
- Conduct an annual review and evaluation of the respiratory protection program to ensure ongoing effectiveness.
- Assess incidents or near-misses related to respiratory protection and implement corrective actions.
- Recordkeeping:
- Section 1910.134(m) mandates the maintenance of specific records related to the respiratory protection program.
- Recommendations:
- Conduct an annual review of all records related to medical evaluations, fit testing, training, and other pertinent information.
- Review and update the Respiratory Protection Plan annually.
- Communication of Changes:
- Communicate any changes in the workplace affecting the respiratory protection program to employees.
- Update written procedures and documentation as necessary to reflect changes.
A strong RPP in LTC centers requires regular maintenance and attention to OSHA standards. As shown above, these actions include consistent training, fit testing, medical evaluations, thorough program assessments, recordkeeping, and communication. Employers should actively review and update their programs to continuously meet compliance requirements and encourage employee safety amid changing workplace conditions.