Preparing a respiratory protection program for an OSHA inspection

Key concepts OSHA usually does not visit a plant solely to evaluate a respiratory program. However, a review of a company's program may be included within the scope of any OSHA inspection.

By Larry Janssen, Technical Service Specialist, 3M Occupational Health and Environmental Safety Div., St. Paul, MN September 1, 2000

Key concepts

OSHA usually does not visit a plant solely to evaluate a respiratory program. However, a review of a company’s program may be included within the scope of any OSHA inspection.

Being prepared to show documentation of your respiratory protection program is the best way to avoid a citation.

With all of their other responsibilities, plant engineers shouldn’t have to spend time worrying about an OSHA inspection of their respiratory protection program. But it pays to be prepared.

It’s not just a matter of avoiding a citation. “One of my priorities is to guarantee a safe and healthful workplace for all of America’s workers,” said Secretary of Labor Alexis M. Herman, discussing OSHA’s January 1998 revision of the respiratory protection standard 29 CFR 1910.134. “This is a major step forward in improving employee protection against toxic substances. In addition to saving lives and preventing injuries and illnesses, employers will realize up to $94 million a year in savings on injury and illness-related costs.”

Although OSHA rarely visits a facility specifically to evaluate its respiratory protection program, a review of respirator training, fit testing, and documentation may be included within the scope of any inspection. This scenario is particularly true if the inspector is evaluating worker exposures to air contaminants, or discovers that respirators are available for emergency use.

Even though it is the responsibility of the employer to provide appropriate respiratory protection against airborne contaminants and to provide worker training in proper use, employees have a responsibility to comply with the company’s respirator program. That’s why the cornerstones of an effective and OSHA-compliant program are training, education, fit testing, trust, and equitable administration.

Inspection selection

How does OSHA select one plant to inspect out of eight million potential targets its mandate covers? There are four levels of priority assigned by OSHA to determine inspection sites.

  • Top inspection priority is given to emergency situations (also known as imminent danger) that are likely to result in death or serious bodily injury.

    • Next comes catastrophes (three or more employee hospitalizations qualifies under this category) and fatal accidents . Employers are required to report such occurrences to OSHA within 8 hr.

      • Employee complaints are classified as third in importance.

        • Finally, there are programmed inspections . Companies are selected from this final category based on objective criteria, such as high injury rates and previous citation history.

          • When OSHA inspectors visit a facility, they may focus strictly on one work area or broaden the scope of the inspection to other areas of the plant. Preparing for any eventuality is not just a matter of avoiding a citation, it’s an integral part of plant-wide safety for every employee.

            Getting ready

            Management should take specific steps to verify that a respiratory protection program is both functional and compliant. These steps include knowing applicable regulations, preparing written procedures, maintaining good records, and performing evaluations to verify the program’s effectiveness.

            1. Keep up-to-date with the law.

            OSHA regulations are published and easily accessible. Therefore, ignorance of OSHA standards is a poor defense when confronted by OSHA inspectors.

            In addition, plant managers and industrial hygienists must regularly update themselves on any revisions. For example, one change occurred in January 1998 with the issuance of the revised respiratory protection standard, 29 CFR 1910.134. It includes modifications to written respirator program requirements, fit testing, medical evaluation procedures, and criteria for the selection and use of chemical cartridges.

            It is critical that employers recognize the role respiratory protection plays in OSHA’s regulations and in the overall goal of safeguarding workers’ health. Both OSHA and good industrial hygiene practice have always held engineering controls, such as ventilation, enclosure of operation, etc., to be the preferred method of controlling employee exposure to airborne hazards. Respiratory protection is to be used while engineering controls are technically or economically not feasible.

            2. Prepare written procedures and maintain records.

            The revised OSHA respirator standard lists the nine elements of a respirator program. Employers should address, in writing, each of the points as they pertain to their own facility. They must be covered in enough detail that it is clear exactly how each will be accomplished.

            In addition, an administrator qualified by training and/or experience to manage the program must be identified. This individual must have overall responsibility for the program and be capable of evaluating its effectiveness. This person may designate in-house personnel to be responsible for specific elements of the program, or may seek outside assistance, such as an industrial hygiene consultant.

            The standard also mandates that specific records be maintained. These records include fit testing, medical evaluations, and a copy of the written respiratory protection program.

            Although the standard does not specifically require training records, employers are well advised to keep these. Not only do they show concrete evidence of adherence to respiratory protection regulations, they also allow the program administrator to track which employees are due for the annual retraining that OSHA requires.

            Software programs are available to assist companies with program administration. The programs usually outline a basic respiratory protection program structure that can be tailored to each site. Recordkeeping is simplified, as well as the tracking of fit testing and medical evaluations.

            3. Evaluate the program.

            Developing and implementing a written respiratory protection program is effective in helping protect workers against respiratory hazards. Evaluating the program allows deficiencies to be identified and corrected. It is also required by OSHA regulation.

            It’s important that the program evaluation emphasizes observation of actual practices rather than a review of records. For example, are respirators always used where they’re supposed to be? Are they worn correctly?

            It is also important to listen to employees: Do they know the limitations of their respirator equipment? When was the last time they were fit tested? What training have they had? It is often surprising what discrepancies can emerge from the written program.

            Whenever an evaluation is conducted, document it, noting the deficiencies found and, most importantly, actions taken to correct them.

            Mistakes to avoid

            Again and again, the same mistakes are made with regard to respiratory protection programs. The most common one is a lack of written procedures. Many companies simply haven’t taken the time to write the necessary training and implementation programs-a sure sign of an ineffective program and likely target for an OSHA citation.

            The second most common error is to mistake policy statements for written procedures. Such programs simply restate OSHA requirements, such as, “We will do fit testing annually.” The respiratory protection standard calls for work site-specific procedures. Therefore, written procedures must spell out exactly how the company intends to implement each element of the respiratory protection program in each work site: Who will do the fit testing? Where will it be done? What protocol will be used?

            Another frequent mistake is to adopt a generic or corporate program, without tailoring it to a specific work site. These can often serve as useful starting points, but nearly always require at least some modification for each site. For example, where will respirators be stored in this particular facility? The point is not to issue a program to satisfy a regulation, but to use it as a tool to enhance worker protection.


            No matter how good a program some companies have and how well they try to follow it, it is still possible to be cited. But when a plant has a well-documented respiratory protection program, all training is current, and an honest effort is made to control respiratory hazards, the risk of citation is greatly lowered.

            More importantly, worker exposures to air contaminants are minimized.

            Edited by Cheryl Firestone, Senior Editor,


            Elements of a respiratory protection program

            In any workplace where respirators are necessary to help protect the health of the employee or whenever respirators are required by the employer, the employer shall establish and implement a written respiratory protection program with worksite specific procedures. The program shall be updated as necessary to reflect those changes in workplace conditions that affect respirator use. The employer shall include in the program the following provisions, as applicable:

          • Procedures for selecting respirators for use in the workplace

            • Medical evaluations of employees required to use respirators

              • Fit testing procedures for tight-fitting respirators

                • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations

                  • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators

                    • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators

                      • Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations

                        • Training of employees in the proper use of respirators, including donning and removal, any limitations on their use, and their maintenance

                          • Procedures for regularly evaluating the effectiveness of the program.

                            • Source: OSHA Standard 29 CFR 1910.134

                              Checklist for OSHA inspection preparation

                              1. Be current on all relevant OSHA standards, including the requirements for training and written programs.

                              2. Document all training and safety/health related programs and procedures.

                              3. Prepare for the possibility of an inspection.

                              a. Conduct regular program evaluations.

                              b. Be able to quickly locate all administrative records, such as written procedures, training records, etc.

                              c. Appoint specific people to accompany the inspector, including alternates in case one is absent at the time of the inspection.

                              d. Have all relevant contact names and numbers available so that those assigned can be immediately called together at the time of the inspection. Don’t keep an inspector waiting.

                              4. Perform evaluations.

                              a. Are existing respiratory protection programs up-to-date?

                              b. Has air monitoring been conducted to determine employee exposure levels?

                              c. Evaluate plant engineering controls. Are adequate steps being taken to reduce exposures?

                              d. Are employees following proper procedures concerning storage, selection, use, maintenance, and fit testing of respirators?

                              e. Do employees understand the training they have received? Ask questions (OSHA inspectors always do).

                              f. Inspect the plant for any general health or safety hazards. Ask staff if they are aware of any that should be reported.

                              g. Locate recently hired employees to see if they are actively being trained on respirator use and plant safety procedures.

                              More info

                              The author is available to answer questions about this article. Mr. Janssen can be reached at 651-736-6647.

                              Details about the OSHA respiratory protection standard 29 CFR 1910.134 can be found on the OSHA web site at For general information and online tools, visit the 3M web site at