Respiratory Quantitative Fit Testing

          As mentioned in OSHA 29 CFR 1910.134(f), respiratory fit testing is required for all those who wear respirators.  The reason for fit testing is to ensure proper protection, training, and comfort.  There are many different times when respiratory fit testing is needed: before initially entering the workplace, changing respirators, or changes in physical condition.  After the initial fit testing, retesting should be done each year after.  There are two types of fit testing: quantitative and qualitative. The qualitative aspect involves asking the subject if the respirator feels comfortable and feels like it fits. On the other hand, qualitative fit testing involves measurement with a device, which results in a numerical value, fit factor, of how well the respirator fits the subject. There are advantages and disadvantages to each of the two types of analysis mentioned in Grainger Quick Tips-Safety.  The advantages of qualitative fit testing are low cost, and easy pass/fail results.  The disadvantages are chance of the subject deceiving, as well as the limited protection verification.  The advantages of the quantitative fit testing are documentable numerical results and no chance of subject deception.  The disadvantage of quantitative is that it requires expensive equipment and maintenance.

            The Respiratory Fit Testing 101: Into talks a lot about how the quantitative fit test is able to tell much more about how the respirator fits and what parts of the test cause a break in the seal of the mask.  There are devices that hook up to the respirator to run a quantitative analysis, such as the Portacount Pro.  Once all the tests are run, the device will result in a numerical value called the fit factor. The fit factor is a ratio of the concentration outside the mask and inside the mask, which tells how well the respirator works and fits an individual.  As stated by OSHA, half face respirators must have a fit factor of at least 100, while full face respirators must have a minimum fit factor of 500.

Before a fit test is conducted, the subject must wear the respirator for at least five minutes to ensure that it can be worn and is comfortable.  Mentioned in the TSI Portacount Pro manual, there are eight exercises, lasting 60 seconds each, that are required by OSHA when conducting a quantitative fit test.  As a note, these steps must be completed while the subject is standing. The eight steps are outlined below:

1.     Normal breathing

2.     Deep breathing

3.     Head side to side

4.     Head up and down

5.     Talking

6.     Grimace (15 sec)

7.     Bending over

8.     Normal breathing

Each of the steps above will result in a numerical value that will be formulated into an overall fit factor value.  Even if a respirator does not pass one of the eight steps, the overall fit factor may still be in compliance.  Another important aspect of fit testing is making sure that the subject is comfortable wearing the respirator.  If the subject is not comfortable in a certain respirator, it may be wise to try another one and determine if it is a better fit for that individual by completing another quantitative fit test.

 

Environmental Site Assessment

A typical environmental site assessment includes three main parts: Transaction Screening, Phase I, and Phase II. As mentioned in Chapter 22, each different step is completed in order to determine the overall potential hazardous materials contained within a site or location.  This is important for those who own the property or if an individual is purchasing a new piece of land.  The new owner will want to know the possible hazardous materials within the site in order to take the necessary precautions to make the site safe and reduce clean up costs if needed.

The first step of an environmental site assessment is the transaction screening.  According to Engineering Science Inc., the transaction screening is essentially a shortened version of the phase I step that occurs next.  This initial step includes a visit to the site, document review, and interviews with important personnel. These three topics are covered more in depth in Phase I.  The reason for a transaction screening is to do a quick overview of the site and its possible hazards in order to determine if a more detailed investigation needs to occur. This step is less costly than the phase I due to the fact that it does not have to be done by an environmental professional. 

After the transaction screening is completed, the next step is a phase I.  The phase I will only be done if a hazardous material of concern is noted within the transaction screening and more information is needed to determine the necessary removal of the material. As mentioned briefly above, the phase I will cover a more in depth overview of the records, site visit, interviews, and then complete a report containing the findings. Environmental Assistance Program mentions the importance of allowing time for a phase I investigation.  It may take time to review records that pertain to the site and gather information that is key to determining possible hazardous material.  The site visit is another key component to the phase I.  The environmental professional who completes the phase I will need to make sure to take photos of the site and do a visual inspection, noting any possible hazards. The interviews are done to gather first hand information and experience with those who know and work at the site.  Lastly, a report is completed of all the findings of phase I and any suggestions surrounding the next phase of the process.

As mentioned in Chapter 22,  the phase I identifies any possible contaminants, a phase II will be necessary.  The phase II revolves around the goals set by a work development plan.  This plan describes the purpose for going through with a phase II investigation and what should be accomplished through sampling the site.  The phase II includes sampling and analysis of the site and possible contaminants.  The samples may be of ground water, drums, above ground storage, or geophysical testing for underground tanks.  As with any tests or samples, there will need to be evaluation of the data collected.  Similar to the phase I, the phase II will also need to be completed by an environmental professional.  The phase II will be complete with a report of the findings to determine if the hazardous materials and their concerns were covered adequately.

Permit-Required Confined Space

            OSHA has a required standard, 29 CRF 1910.146, for all locations that meet the confined space criteria and then also require a permit to enter those areas.  Along with those specifications, there are other steps that need to be taken to ensure safe entry into possibly hazardous confined spaces.  The first step is to determine if the space being entered is a confined space by which a permit will be required.  According to OSHA, a space is designated as a confined space if it meets the following three criteria:

1.     The space is large enough for an employee to enter and complete the assigned responsibilities.

2.     The entry and exit from the space is restricted.

3.     The space is not originally planned for permanent occupancy.

The next step is to inform the employees of the space, along with its location and possible hazards.  Testing and other analysis will need to be done in the space to determine the possible hazards.   Due to the nature of the unsafe space, the employer will need to limit access to that confined space so that unauthorized personnel do not enter the space without proper training and permission. 

The first few steps are the general information on the confined space.  OSHA also then requires a confined space entry program.  This program lays out more of the details that are specific to the facility and the confined spaces being entered.  This program must also be available to employees to access.  The written program must cover the ways that the hazards within the confined space are being controlled for a safe entry.  It will also cover the requirements of the permit needed for entering such a space. The permit is very specific to each confined space.  Tests for hazards and personal protective equipment must be described on the permit.  The permit also designated trained personnel who are authorized to enter the confined space as well as attendants who are a line of safety for those inside the space.  As mentioned briefly above, the personnel and attendants must also be trained on how to safely enter the space.   Another topic the written program has to cover is an emergency plan.  The emergency plan gives information on the necessary steps to be taken in case of a rescue in an emergency.  Many times the fire department is called to assist with rescue, and it is important to coordinate with these services before they are needed to plan for the possible hazards involved. 

Many of the scenarios involving the Permit-Required Confined Space Standard also involve other standards.  One standard that may be referenced during a confined space entry may be the Lock Out Tag Out Standard, 29 CFR 1910.147.  This standard may be necessary if the space being entered involves hazardous energy.  The procedure in this standard covers the precautions that need to be taken to ensure that the hazardous power is shut off during maintenance and will not be able to be turned on while an employee is at risk of injury or death.  Another standard that may be needed during confined space entry is the HazardCommunication Standard, 29CFR 1910.1200.  This standard would be used to communicate the hazards of the confined space to the employees and personnel involved with confined space entry.  There may be engulfment hazards or asphyxiation hazards within the space that personnel need to be aware of and trained to work with.  

              Aside from this lengthy process of permit-required confined space entry, there is an alternative to a full permit for entering a confined space as described by OSHA.  An example where this alternative method would be acceptable is if the employer can show through samples and monitoring that the space is only potential hazardous atmosphere and nothing more, but can be fixed by clearing the space with continuous air ventilation, then they may be exempt from permits and attendants.  The employer must provide tests before entry and continuous air ventilation during the working process to avoid completing a full permit.

 

Risk Management Plans and Process Safety Management

The Risk Management Plan, RMP, was designed by the Environmental Protection Agency, EPA, to be used by facilities that deal with hazardous chemicals in order to prevent chemical accidents from occurring.   According to the EPA, there are three main areas that an RMP must cover.  The first area is that of an assessment of the potential hazards that could occur due to an accidental release of the hazardous chemicals.  Along with that, they must include a history of the accidents in the past 5 years.  Next, they must include safety measures that are in place along with training procedures, and maintenance.  Lastly, the RMP must have an emergency response program in place if an emergency were to occur.  The emergency response program must include emergency protocols involving health care, training procedures, and emergency response.  The RMP must be resubmitted each year to ensure it is up to date.  There are about 250 chemicals that have threshold levels to which a company is responsible for the regulations.  27 of those chemicals are not listed in OSHA’s Process Safety Management. 

            Process Safety Management, PSM, was designed by the Occupational Safety and Health Administration, OSHA, to ensure a safe workplace where hazardous chemicals are used.  As stated in the name, this tool is used to define a ‘process’ that needs to occur in the event of a spill or leak of hazardous chemicals.  This standard has a key focus on the safety of the worker when in the workplace while the RMP has a focus on the environment and the impact of the chemicals on the environment.  According to OSHA, the PSM required written safety information that recognizes the hazards or possible hazards within a workplace to ensure that the workers are aware of their environment.  Each PSM must be updated every 5 years to ensure the most current information.  Similar to the RMP, this standard must also outline emergency procedures in the case of a spill or leak.  The hazards must also be identified in order to determine the best possible way to prevent an emergency from occurring. The details for the PSM are outlined on OSHA’s website and are much more strict that those of the EPA’s RMP.  There are also about 79 chemicals that are listed on the PSM but not on the RMP.  In general, the PSM threshold levels are lower than the RMP threshold levels for responsibility.  

Facilities that store or use highly hazardous chemicals must comply with both the Risk Management Plan and the Process Safety Management.  It is important for facilities to follow both sets of regulations in order to keep the workplace safer for the employees and the environment safer for everyone.  A chemical leak or spill of any sort is dangerous, that it why it is important to have these plans and protocols in place before an emergency was to occur.  In the event of an emergency, the staff and public responders are well informed and have coordinated the appropriate responses for the chemicals involved. Essentially, the RMP deals with spills and leaks that affect outside the workplace, while the PSM handles spills and leaks within the workplace.