Safety Failure's Top Non-Followed Safety Requirement.

“The most non-followed safety requirement!” “Period….”

?Reason and Reasoning; This would require another entire written topic; New letter.

?“Yet, everyone knows the Truth of and for the reason’s and reasonings.” “Period….”

In many facilities while there may be vast understanding and acknowledgement as to the do’s and don’t’ when handling any types of Hazardous Chemicals; The true proper educating, trainings, and greater insurances that “all” employee’ and staffing not only have been trained, but that they are ensuring their very own safe and safety trainings for themselves and any/all others working within the ratio distance where acknowledged and regulated requirements have been provided.

The ”Employer,” not the employee’s alone have this responsibility, of ensuring that all of the guidelines and regulations along with simply self-concerns in and through true passions of wanting to maintain the safety of each and every individual, who “may” even come into contact within their facilities, to include the local surrounding areas when the performance, storage, or transportation of any hazardous situation, may be. “Period….”

Technologies, soft-wares, and computer trainings, can not ever provide proper training within each situation, (Noting) that there are millions of different operations, with even greater applications, daily which require hands on safety assurances.

?The below suggested “Hands-ON,” education materials, as well as, adopted training materials may/can be of value when and only when delivered and performed properly to any/all staffing and employee’ within “all” placements where the performance of hazardous situations are being performed.

“No Matter the Size of the Operation!”

Note to “ALL” In most all cases where failure of protection which means failure within the entire program, is due to simply not being concerned with the safety of others. “Period….” To include individual power seeking management which openly knows and or demands that safety becomes the second or third, even possibly removed totally, to ensure time frames and work performances because of costs associated. “Period….”

?The purpose of this respirator program is to establish standard operating procedures to ensure the protection of all employees from respiratory hazards through proper selection and use of respirators.?? This program applies to all employees who are required to wear respirators during normal operations, non-routine tasks, or emergency operations such as a spill of a hazardous substance.

?RESPONSIBILITIES

?Program Employer’ Responsibilities, with or without an Administrator

?Every performance and operation being performed which requires the usage of any type of Respirator or type of protection from hazardous materials. First and foremost, every performance and operation must have a safety professional, educated and well advanced with a designated program oversight of required respiratory protection program during each individual operation. The duties of the safety professional, can be that of the performance provider as well, as long as, if there is more than one operator of the performances being performed; has both the authority and the allowed time frame to ensure all performers are educated and performing 100% themselves to the assigned work detail.

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Duties of the Safety Professional “on site”:

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NOTE: Technology, software, computer education and training cannot perform the required hands-on regulations. “Period….” And the true only reason why an attorney may be needed.”

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·???????? Identifying work areas, processes or tasks that require workers to wear respirators, and evaluating hazards

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·???????? Selection of respiratory protection options

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·???????? Monitoring respirator use to ensure that respirators are used in accordance with their certifications

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·???????? Arranging for and/or conducting training

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·???????? Ensuring proper storage and maintenance of respiratory protection equipment

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·???????? Conducting or arranging for fit testing

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·???????? Administering the medical surveillance program

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·???????? Maintaining records required by the program

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·???????? Evaluating the program

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·???????? Updating written program as needed

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Supervisors Duties

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Supervisors are responsible for ensuring that the respiratory protection program is implemented in their particular areas. “This Supervisor must also, have and be able to show proof is required, of all such professional certification, In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their charge.? Duties of the supervisor include, but are not limited to:

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·???????? Ensuring that employees under their supervision (including new hires) have received appropriate training, fit testing, and medical evaluation

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·???????? Ensuring the availability of appropriate respirators and accessories

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·???????? Being aware of tasks requiring the use of respiratory protection

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·???????? Enforcing the proper use of respiratory protection when necessary

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·???????? Ensuring that respirators are properly cleaned, maintained, and stored according to the respiratory protection plan

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·???????? Ensuring that respirators fit well and do not cause discomfort

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·???????? Continually monitoring work areas and operations to identify respiratory hazards

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·???????? Coordinating with the program administrator on how to address respiratory hazards or other concerns regarding the program

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Employees Duties

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Each employee has the responsibility to wear his or her respirator when and where required and in the manner in which they were trained.? Employees must also:

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·???????? Care for and maintain their respirators as instructed and store them in a clean sanitary location

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·???????? Inform their supervisor if the respirator no longer fits well, and request a new one that fits properly

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·???????? Inform their supervisor or the Program administrator of any respiratory hazards that they feel may not be adequately addressed in the workplace and of any other concerns that they have regarding the program

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PROGRAM ELEMENTS

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Respirator Selection

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Respirators are selected on the basis of the hazards to which the employees are exposed and in accordance with OSHA requirements.? Only NIOSH certified respirators will be selected and used.

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The Program Administrator will conduct a hazard evaluation for each operation process, or work area where airborne contaminants may be present in routine operations or during an emergency.? The hazard evaluation will include:

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·???????? Identification of the hazardous substances used in the workplace, department or work process;

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·???????? Review of work processes to determine where potential exposures to these hazardous substances may occur; and

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·???????? Exposure monitoring to quantify potential hazardous exposures.

The results of the hazard evaluation are to be located in an area for all employee’ and staffing review.

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The program administrator will revise and update the hazard assessment as needed (i.e., any time work process changes which may potentially affect exposure).

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General requirements

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·???????? The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.

·???????? The employer shall select a NIOSH-certified respirator. The respirator shall be used in compliance with the conditions of its certification.

·???????? The employer shall identify and evaluate the respiratory hazard(s) in the workplace; this evaluation shall include a reasonable estimate of employee exposures to respiratory hazard(s) and an identification of the contaminant's chemical state and physical form. Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.

·???????? The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.

Respirators for Immediately Dangerous to Life and Health (IDLH) atmospheres

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• In the event of any new work assignments or change of work assignment where Chemicals are brought in for the performance of such work or change. The Administer will evaluate the Chemicals before they are allowed to be brought into the work site.
• If the evaluation proves the must for IDLH, The Administer will work closely with any/all department to ensure a professional is brought in or the chemical requiring IDLH will not be allow to be brought into the work site. “Period….”
• The Administer will perform a site visit and evaluation of the third party site to ensure all required OSHA & IDLH requirements are being performed.
• The below will be the evaluation;

1.??? A full face piece pressure demand SCBA certified by NIOSH for a minimum service life of thirty minutes, or

2.??? A combination full face piece pressure demand supplied-air respirator (SAR) with auxiliary self-contained air supply.

3.??? Respirators provided only for escape from IDLH atmospheres shall be NIOSH-certified for escape from the atmosphere in which they will be used.

4.??? All oxygen-deficient atmospheres shall be considered IDLH. Exception: If the employer demonstrates that, under all foreseeable conditions, the oxygen concentration can be maintained within the ranges specified in Table II of this section [29 CFR 1910.134(d), i.e., for the altitudes set out in the table], then any atmosphere-supplying respirator may be used.

Respirators for atmospheres that are not IDLH

·???????? The employer shall provide a respirator that is adequate to protect the health of the employee and ensure compliance with all other OSHA statutory and regulatory requirements, under routine and reasonably foreseeable emergency situations.

NIOSH Certification

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All respirators must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification.? Also, all filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval label.? The label must not be removed or defaced while it is in use.

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Voluntary Respirator Usage

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Decide if your company will not provide (or allow employee-owned) respirators to employees for voluntary usage. Ensuring that the proper written program is performed, educated and trained before any implementation is allowed. “Period….”

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Respirator Filter & Canister Replacement/Change Schedule

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An important part of the Respiratory Protection Program includes identifying the useful life of canisters and filters used on air purifying respirators.? Each filter and canister shall be equipped with an end-of-service-life indicator (ESLI) certified by NIOSH for the contaminant; or

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If there is no ESLI appropriate for conditions a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters and cartridges are changed before the end of their service life.

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Cartridges/Filters shall be changed based on the most limiting factor below:

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1.??? After each daily use

2.??? When requested by employee

3.??? When restriction to air flow has occurred as evidenced by increased effort by user to breathe normally

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Medical Evaluation

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Employees who are required to wear respirators must be medically evaluated before being permitted to wear a respirator on the job.? Employees are not permitted to wear respirators until a physician has determined that they are medically able to do so.?

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A licensed health care professional will provide the medical evaluation to employees.? Medical evaluation procedures are as follows:

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·???????? The medical evaluation will be conducted using medical questionnaire provided in Appendix C of 29 CFR 1910.134 Respiratory Protection Standard, and will provide a copy of this questionnaire to all employees requiring medical evaluation.

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·???????? To the extent feasible, the company will assist employees who are unable to read the questionnaire.? When this is not possible the employee will be sent directly to the health care professional for assistance and medical evaluation.

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·???????? Employees will be permitted to fill out the questionnaire on company time.

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·???????? Follow up medical exams will be provided to employees as required by the OSHA standard, and/or as deemed necessary by the health care professional.

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·???????? All employees will be allowed the opportunity to speak with the health care professional about their medical evaluation if they so request.

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·???????? The program administrator will provide the health care professional with a copy of this program and a copy of OSHA’s respiratory protection standard.? For each employee requiring evaluation, the health care professional will be provided with information regarding the employee’s work area or job title, proposed respirator type and weight, length of time required to wear the respirator, expected physical work load (light, moderate, or heavy), potential temperature and humidity extremes, and any additional protective clothing required.

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·???????? After an employee has received clearance to wear a respirator, additional medical evaluations will be provided under any of the following circumstances:

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·???????????????????? The employee reports signs and/or symptoms related to their ability to use a respirator, such as shortness of breath, dizziness, chest pains, or wheezing;

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·???????????????????? Supervisor informs the Program Administrator that the employees need to be reevaluated;

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·???????????????????? Information from this program, including observations made during fit testing and program evaluation, indicates a need for reevaluation; and

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·???????????????????? A change occurs in workplace conditions that may result in an increased physiological burden on the employee.

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NOTE:??????????? All examinations and questionnaires are to remain confidential between the employee, employer and the physician.

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Fit Testing Procedures

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Must ensure that fit-test will be administered using an OSHA-accepted qualitative fit test (QLFT) or quantitative fit test (QNFT) protocol.? The OSHA-accepted QLFT and QNFT protocols are contained in Appendix A of the Respiratory Standard (1910.134)

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All employees are required to be fit tested at the following times and with the same make, model, style, and size of respirator that they will be using.

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·???????? Before being allowed to wear any respirator with a tight-fitting face piece and at least annually thereafter;

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·???????? Whenever a different respirator face piece (size, style, model, or make) is used;

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·???????? Whenever visual observations of changes in the employee’s physical condition that could affect respirator fit.? Such conditions include, but are not limited to, facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight; and

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·???????? Upon employee notification that the fit of the respirator is unacceptable.

The Safety Professional has established a record of the fit tests administered to employees including:

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·???????? The name or identification of the employee tested;

·???????? Type of fit test performed;

·???????? Specific make, model, style, and size of respirator tested;

·???????? Date of test; and

·???????? The pass/fail results

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Use of Respirators

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General Use Procedures

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Employees will use their respirators under conditions specified by this program, and in accordance with the training they receive on the use of each particular model.? In addition, the respirator shall not be used in a manner for which it is not certified by NIOSH or its manufacturer.

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All employees shall conduct user seal checks each time that they wear their respirator.? Employees shall use either the positive or negative pressure check (depending on which test works best for them) specified in Appendix B-1 of the Respiratory Protection Standard.

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All employees shall be permitted to leave the work area to maintain their respirator for the following reasons: to clean their respirator if the respirator is impeding their ability to work, change filters or cartridges, replace parts, or to inspect respirator if it stops functioning as intended.? Employees should notify their supervisor before leaving the area.

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Employees are not permitted to wear tight fitting respirators if they have any condition, such as facial hair, facial scars, or missing dentures that prevents them from achieving a good seal.? Employees are not permitted to wear headphones, jewelry, or other articles that may interfere with the face piece to face seal.

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Emergency Procedures

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In the event of any new job assignments or changes to job assignments requiring the change to be such as IDLH the Administer will perform first an evaluation to ensure no IDLH is required.

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Respirator Malfunction

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For any malfunction of a respirator (e.g., such a breakthrough, face piece leakage, or improperly working valve), the respirator wearer should inform his or her supervisor that the respirator no longer functions as intended, and go to a safe area to maintain the respirator.? The supervisor must ensure that the employee receives the needed parts to repair the respirator, or is provided with a new respirator.

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Maintenance and Care Procedures

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In order to ensure continuing protection from the respirators being use, it is necessary to establish and implement proper maintenance and care procedures and schedules.? A lax attitude toward maintenance and care will negate successful selection and fit because the devices will not deliver the assumed protection unless they are kept in good working order.

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Cleaning & Disinfecting

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Each company must provide each respirator user with a respirator that is clean, sanitary, and in good working order. ?We ensure that respirators are cleaned and disinfected at least daily or as often as necessary to be maintained in a sanitary condition.? Respirators are cleaned and disinfected using the below procedures

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Respirators are cleaned and disinfected:

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·???????????????????? As often as necessary when issued for the exclusive use of one employee;

·???????????????????? After each use for emergency use respirators; and

·???????????????????? After each use for respirators used for fit testing and training.

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Storage

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Storage of respirators must be done properly to ensure that the equipment is protected and not subject to environmental conditions that may cause deterioration. Ensuring that respirators are stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals.? They are packed and stored in accordance with any applicable manufacturer’s instructions.

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Respirator Inspection

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All respirators will be inspected after each use and at least monthly.? Should any defects be noted, the respirators will be taken to the program administrator or supervisor.? Damaged respirators will be either repaired or replaced.

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Respirators shall be inspected as follows:

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·???????????????????? All respirators used in routine situations shall be inspected before each use and during cleaning;

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·???????????????????? All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with manufacturer’s recommendations, and shall be checked for proper function before and after each use; and

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·???????????????????? Emergency escape-only respirators shall be inspected before being carried into the workplace for use.

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Respirator inspections shall include the following:

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·???????????????????? A check of respirator function, tightness of connections, and the condition of the various parts including, but not limited to, the face piece, head straps, valves, connecting tube, and cartridges, canisters or filters; and

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·???????????????????? Check of elastomeric parts for pliability and signs of deterioration.

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The following checklist will be used when inspecting respirators:

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·???????????????????? Face piece:

·???????????????????? cracks, tears, or holes

·???????????????????? facemask distortion

·???????????????????? cracked or loose lenses/face shield

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·???????????????????? Head straps:

·???????????????????? breaks or tears

·???????????????????? broken buckles

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·???????????????????? Valves:

·???????????????????? residue or dirt

·???????????????????? cracks or tears in valve material

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·???????????????????? Filters/Cartridges:

·???????????????????? approval designation

·???????????????????? gaskets

·???????????????????? cracks or dents in housing

·???????????????????? proper cartridge for hazard

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·???????????????????? Air Supply Systems:

·???????????????????? breathing air quality/grade

·???????????????????? condition of supply hoses

·???????????????????? hose connections

·???????????????????? settings on regulators and valves

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Training

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The HSE will be responsible to provide training respirator users or their supervisors on the contents of the Respiratory Protection Program and their responsibilities under it, and on the OSHA Respiratory Protection Standard.? Workers will be trained prior to using a respirator in the workplace.? Supervisors will also be trained prior to using a respirator in the workplace or prior to supervision of employees that must wear respirators.

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The training will cover the following topics:

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·???????? The Respiratory Protection Program

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·???????? The OSHA Respiratory Protection Standard

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·???????? Respiratory hazards encountered and their health effects

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·???????? Proper selection and use of respirators

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·???????? Limitations of respirators

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·???????? Respirator donning and user seal (fit) checks

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·???????? Fit testing

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·???????? Emergency use procedures

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·???????? Maintenance and storage

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·???????? Medical signs and symptoms limiting the effective use of respirators

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Employees will be retrained annually or as needed (e.g., if they need to use a different respirator).? Employees must demonstrate their understanding of the topics covered in the training utilizing a hands-on exercise and a written test.? Respirator training will be documented by the Program Administrator and the documentation will include the type, model, and size of respirator for which each employee has been trained and fit tested.

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Program Evaluation

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The program administrator will conduct periodic evaluations of the workplace to ensure that the provisions of this program are being implemented.? The evaluation will include regular consultations with employees who use respirators and their supervisors, site inspections, air monitoring and review of records.

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Identified problems will be noted and addressed by the Program Administrator.? These findings will be reported to management, and the report will list plans to correct deficiencies in the respirator program and target dates for the implementations of those corrections.

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Documentation and Recordkeeping

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A written copy of this program and the OSHA standard is kept in the Program Administrator’s office and is available to all employees who wish to review it.

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Also maintained in the Program Administrator’s office are copies of training and fit test records.? These records will be updated as new employees are trained, as existing employees receive refresher training, and as new fit tests are conducted.

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The Program Administrator will also maintain copies of the medical records for all employees covered under the respirator program.? The completed medical questionnaire and the physician’s documented findings are confidential and will remain at The performing medical facility.? The company will only retain the physician’s written recommendation regarding each employee’s ability to wear a respirator.

No employee or any person will be allowed to be assigned to a job task which requires the use of a respirator, or supplied air without, the person first being advised of the reason for required usage of such respirator. Ensuring that the person/employee, has had all the proper education, knowledge, and training on the chemicals they will be using, i.e. HazMat training must first be given.

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Must adapted to have each employee/person who will be required to work at any time with a respirator or supplied air, to be sent to a third party training, fitting, medical testing facility to conduct the proper training and usage of same. The company will pay for the above, the employee will have to once returning to work after training, go to the safety department and be advised of all company policies relating to usage of respirators and Air Supplies, before that employee/person will be allowed to perform job functions using respirators or supplied air.

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Only after an employee, has been medically evaluated will the person/employee be fit tested for the proper size respirator needed.

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The company will supply all needed PPE to include all respirator’ types and filtering systems. Only OSHA Approved respirators will be supplied.

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Once an employee/person has undergone all the above will he/she is allowed to conduct work in an environment which requires the usage of a respirator.

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The employee will ensure the following daily. Yet, if the employer allows the employee to perform these tasks, it in no way or manner relieves the total safety responsibility from the employer.

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·???????? The respirator assigned to the employee/person, no other employee/person will be allowed to use the same respirator for any reason at any time.

·???????? The employee/person using the respirator will at all times ensure that proper usage is conducted when using the respirator.

·???????? The proper amount of time limits allowed to him/her by the medical evaluation they under-went is never allowed to perform beyond that time frame, i.e. the lead person/supervisor in the assigned area where the employee/person is working with the respirator will perform checks at different time frames to ensure all employee/person’ using respirators are performing to company standards.

·???????? After each use of the assigned respirator an employee/person is using, the employee/person will ensure the respirator is cleaned and filters changed daily to ensure the proper protection and sanitary condition of the respirator is kept. The employee/person will place the respirator in a zip-lock bag with his/her name on the bag after cleaning to ensure when the respirator is to be used the next time it is fully clean and ready to be used.

·???????? An employee/person using a respirator will check the respirator each time before usage, ensuring that the respirator is in good working order, if found not to be, the employee/person will not perform any work using that respirator, but will go to his/her supervisor who will assist in getting a new respirator for that person. NOTE: The employee is responsible for the care of their respirator. A company cabinet/locker will be provided to employee’/person’ required to use respirators, ensure a safe environment is provided to store the employee’/person’ respirator in, till that employee/person needs the respiration again.

·???????? No employee at any time shall not use a respirator they feel might have been damaged, clogged, or not working properly.

·???????? The employee must change both the dust collector part of the respirator, as well as, the charcoal filters as directed by manufacture.

·???????? It is the same requirements as above for the employee/person required to us supplied air, as with respirator usage.

·???????? An employee, performing a job task which requires the usage of supplied air, will have a second employee on stand by at all times, to ensure the employee using the supplied air hood/tank is at all time safe and fully knowledgeable of what he/she is doing, i.e. persons using supplied air can become over taken so quickly that they would not even be aware they were in danger. No employee at any time will be allowed to work with supplied air without a second person to watch and ensure the well-being of the person using supplied air.

·???????? At any time an employee feels they are having a problem/concern while using a respirator/air supply with they health, that employee/person should advise their team supervisor at once. Note: the Team Supervisor will at once advise management who will assist in ensuring that employee is given the proper medical attention needed at once.

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Violation of any part or parts of this written policy/procedure can and will be subject to disciplinary action being taken on the person/persons found to be not following this company policy/procedure at all time.