A BREATH OF FRESH AIR - OSHA Implements Respirator Maintenance Rule

Collision shops using respirators to protect employees from sprays, fumes or vapors should now have filter replacement schedules in place for that equipment. As of October 5, those without canister and cartridge change routines are violating a revised Occupational Safety and Health Administration (OSHA) regulation.

"What happens is people use the cartridges beyond their actual service life. They don't notice the odor. The chemicals have now penetrated the cartridge," says John Steelnack, project officer for the respirator standard and an industrial hygienist for OSHA. "They think the respirator is protecting them when, in reality, it isn't anymore. It's the equivalent of not wearing a respirator because the cartridge has ceased doing its job of removing that contaminant." This can lead to asthma, cancer, respiratory conditions and liver diseases.

Although OSHA updated the entire Respiratory Protection Standard (1910.134) to reflect today's respirator technology, collision repairers need to be primarily concerned with the section requiring respirator filter changes, Steelnack says. According to that portion of the regulation, employers must purchase respirators equipped with end-of-service-life indicators (ESLI) or they must implement a schedule to replace canisters and cartridges before they deteriorate. Maintenance routines will vary from shop to shop, just as the number of vehicles being painted does. Owners and managers need to evaluate their operations and then consult published service life criteria to determine how long their respirators' filters can last, Steelnack says, adding that daily replacements will often be necessary.

Replacement schedule guidelines should now be available from OSHA, including the agency's web site; equipment manufacturers; and trade associations, including the Chemical Manufacturers Association, Industrial Safety Equipment Association and the American Petroleum Institute. Once schedules are devised, employers must detail them in a written shop record to meet OSHA requirements. They must also explain which data was used to determine the change frequencies and why that data is considered accurate.

Regulation 1910.134 was originally drafted in the early 1970s. This is the second time OSHA has updated it. According to the rule, employers must first try to prevent hazardous dusts, fogs, fumes, gases, sprays and vapors from entering the work environment. When that is not possible, respirators must be used to protect employees' health. Shop owners then become responsible for establishing and maintaining a written respiratory-protection program, which must consist of:

* medical evaluations (including a medical questionnaire) for all employees who use respirators;

* criteria for selecting respirators to be used in the workplace;

* procedures for proper use of respirators;

* schedules for cleaning, maintaining and storing equipment;

* informing employees of the hazards to which they are exposed;

* procedures for evaluating the effectiveness of the program. *