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Clearing the Air on Respirator Compliance

Silica dust from sandblasted concrete. Vapors from adhesives, paints and solvents. Fumes from gasoline.

Exposures to these common construction site hazards can cause cancer, lung impairment or, sometimes, death. This is why, when engineering and administrative controls are not sufficient, OSHA requires employers to provide a comprehensive respiratory protection program and the respirators that construction workers must wear. This standard is among those most frequently cited when OSHA inspectors visit worksites.

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LIUNA General President Terry O’Sullivan

“Wearing a respirator – correctly – reduces the likelihood of becoming sick from inhaling toxins,” says LIUNA General President Terry O’ Sullivan. “However, respirators are not one-size-fits-all. They also are not particularly comfortable or always reliable in the degree of protection they provide. For these reasons and more, compliance is a challenge for both employers who provide respirators and for workers who wear them.”

The plethora of government-certified respirators on the market – more than 9,000, according to a recent New York Times article – can make selecting the respirator that is most appropriate for a particular work situation overwhelming. For example, disposable masks – such as lightweight, inexpensive N95s that filter the air of contaminants – may be adequate for protecting against silica dust provided they are fit tested properly by each worker wearing them.  But they are not sufficient when the task involves lead or asbestos remediation or when working with adhesives, paints and solvents. In these situations, reusable respirators with replaceable filters are necessary.

Fit is also an issue. Facial hair can cause problems with respirator seals. Furthermore, today’s workforce is not predominantly one race or gender. Race and gender affect facial measurements, but only recently have designers of respirators started taking these factors into consideration.

On top of everything else, respirators make it hard to speak. Workers do not like to wear personal protective equipment (PPE) that makes it difficult to communicate with their colleagues. Because of this, when exposure is intermittent, workers can be tempted to not use their respirators.

Even when the best respirator for the task has been selected and workers understand the importance of compliance, the problems do not go away. To get the maximum safety benefit, a worker must know how to wear the respirator, how to clean it and how to store it. This is why OSHA requires employers to provide free annual respirator training to the workers who wear them. Training must include:

  • Why workers need to use the respirator
  • What the respirator can and cannot do to protect them
  • How to properly inspect, put on and take off and use the respirator
  • How to check the seal of the respirator (also called a “user seal check”)
  • How to use the respirator effectively in emergency situations, including situations in which the respirator does not work properly
  • How to recognize medical signs and symptoms that may limit or prevent the worker from using a respirator
  • How improper fit, usage and maintenance can reduce the respirator’s ability to protect
  • What the procedures are for maintenance and storage of the respirator
  • What the requirements are for federal OSHA or State OSHA Respiratory Protection Standards

“Depending on circumstances,” says O’Sullivan, “the way respirators are used can determine whether a project is safe for workers or is hazardous to their health. We urge members and employers to fully implement all of OSHA’s respirator guidance.”


Your program must contain written procedures for:

  • Your specific workplace
  • Selecting respirators
  • Medical evaluations of employees required to wear respirators
  • Fit testing
  • Routine and emergency respirator use
  • Schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and maintaining respirators
  • Ensuring adequate air quality for supplied-air respirators
  • Training in respiratory hazards
  • Training in proper use and maintenance of respirators o Program evaluation
  • Ensuring that employees who voluntarily wear respirators (excluding filtering facepieces) comply with the medical evaluation and cleaning, storing and maintenance requirements of the standard
  • A designated program administrator who is qualified to administer the program
  • Updating the written program as necessary to account for changes in the workplace affecting respirator use
  • Providing equipment, training and medical evaluations at no cost to employees

If you did not check all of the above, your respiratory protection program does not meet OSHA standards.

The LHSFNA Occupational Safety and Health Division publishes a guide to assist contractors in establishing an effective respirator training program. Face It: A Laborers’ Guide to Respiratory Protection is available through the Fund’s Publications Catalogue. For more information, call the Division at 202-628-5465.

[Janet Lubman Rathner]

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