DPR Respiratory Protection-TBA

Appendix B
California State Parks Guidelines for Respirator Use


Under current DPR policy and now federal standards, respirator use falls into two categories:  a VOLUNTARY USE PROGRAM  and the TRADITIONAL USE PROGRAM.

Voluntary Use Respirator Activities and Programs

LEVEL I


The voluntary use program offers a less intrusive and less costly alternative, if certain conditions are met. It may be appropriate when material being filtered is a dust or similiar substance not listed in the standard or not present in significant concentrations. Examples might be dust and organic matter generated by using a weed eating machine or dust generated by a road sweeper. If the voluntary respirator use is a part of a park's operation, employees must be trained to fully understand the limitations.

Employees may request, or employers may provide, filtering face pieces, listed or not, when the use of these devices is determined, by the employer, not to create a hazard in the use. The following conditions must be met:
  1. a) The materials in the breathing zone have been assessed by the supervisor (or at the supervisor’s order) and they are not a listed material or a material that exists in excess of the limits set forth in the Standard and  b) an adequate amount of oxygen is available in the atmosphere. This assessment is a part of the Job Hazard Analysis process. Some form of supervised testing of the work environment may be necessary to establish the facts of the work situation.
  2. Once the material or its concentration is established and meets the exception criteria, employees can be trained. Appendix D of the Standard is provided to each employee.
  3. Respirator selection is then possible. Whether it an unlisted dust mask or a listed filtering face piece the units need to be controlled. Replaceable cartridge respirators are not a part of the voluntary program.
  4. The filtering units are to be used for a maximum of one work shift and then thrown away. The supervisor is responsible for assuring  that this is done.
  5. Although no medical evaluation is required for this use, the supervisor must still assess the individual's condition. If a person appears to be at risk for respiratory stress, the supervisor's duty to provide a safe workspace must prevail.
This program could result in employee injury if not monitored and managed properly. The limits of use must be adhered to.  Individuals using respirators in this program are not a part of a "written respirator program."

LEVEL II


This voluntary use of respirators may be in response to an employee's sensitivity or allergy to a material that is not listed in the Standard. The person may not know that they have this condition. They may go to their doctor as a result of a condition and the doctor decides that they are allergic to a material. The material could be pollen, mold spores, animal dander or some other material or organism found in nature and in a park location. The doctor may prescribe a respirator if the person cannot avoid the material. The doctor would most likely investigate and decide that the respirator can be utilized by the individual with no ill effects from just using the unit and obviously restricting free breathing. Under this program :
  1. The need for a respirator has nothing to do with Occupational Safety and Health Agency (OSHA) Standards.
  2. The individual provides his/her supervisor a medical fitness document from his/her doctor.
  3. The individual brings the respirator into the workplace.
  4. The supervisor provides him/her with information about respirator use, care and maintenance.
  5. The respirator is or could be a filtering face piece, cartridge respirator of some type, powered air unit or some other type of unit that allows the individual to do his/her work. This unit would not affect the wearer’s vision. No full-face units are included in this program level.
  6. This program is considered a "written program" and the employee's medical evaluation, training and cleaning, the storing and maintaining of the respirator must all be documented, in writing.


Traditional Use Program

Conditions hat require full written respirator programs come into play when the utilization of engineering or administrative controls cannot render the work place outside the Standard or the exceptions are not met as described in the Voluntary Activities and Programs. The Task Hazard Analysis process documents the need for special work methods and knowledge to safely accomplish a given task. Examples of these activities include changing out a chlorine gas cylinder in a water treatment plant, entering a wet well in a sewage lift station to retrieve or repair some component of that system, entering a burning building to effect a rescue or extinguish a fire, or using chemicals that require protective actions based on the Material Safety Data Sheet (MSDS) for the product.

Department policy or district administrative controls may dictate that all such work be contracted out and department employees would need to enter work sites that are covered in the Standard. Exhaust fans and atmosphere monitoring may provide a means to bring a work site to a condition that is not under the Standard. These are generally a form of permit required confined space activities. The conditions of the work site are controlled by engineering solutions and administrative controls. These provide a method of accomplishing the work without exposing department personnel to conditions that require written respirator programs. These designed solutions must have a documented history of successful use on the site the work is taking place. Procedures must document how and when these processes are to be used. Individuals must be trained in the process. Equipment needed to assess the conditions must be available and calibrated.

Only when these methods, engineering controls and administrative controls, cannot provide a work site that is not under the Standard is a Respirator Program mandatory.

For further information please contact:

Mike August
Senior Industrial Hygienist
maugu@parks.ca.gov
Draft as of 12/2003