3.1 The nine elements of the written program
Paragraph (c)(1) does something unusual for an OSHA standard: it lists exactly what the written program must contain, in nine numbered items, and every one of them maps to a later paragraph that fills in the detail. Learn the nine and you have the table of contents of the whole standard.
1 When the program is required
Paragraph (c)(1): In any workplace where respirators are necessary to 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.
Three things to take from that sentence. There are two triggers — necessity or employer requirement.mdash; necessity or employer requirement. The procedures must be worksite-specific, which rules out a template with the company name changed. And the program is updated as necessary rather than annually: the maintenance trigger is a change in workplace conditions affecting respirator use, not a date.
Paragraph (c)(3) adds the person: the employer shall designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program, to administer or oversee it and conduct the required evaluations of program effectiveness. The standard sets no certificate and no job title — it sets a match between the person's background and how complex your program is.
2 The nine elements
| ¶ | Element | Detail in |
|---|---|---|
| (c)(1)(i) | Procedures for selecting respirators for use in the workplace | (d) |
| (c)(1)(ii) | Medical evaluations of employees required to use respirators | (e) |
| (c)(1)(iii) | Fit testing procedures for tight-fitting respirators | (f) |
| (c)(1)(iv) | Procedures for proper use in routine and reasonably foreseeable emergency situations | (g) |
| (c)(1)(v) | Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding and otherwise maintaining respirators | (h) |
| (c)(1)(vi) | Procedures to ensure adequate air quality, quantity and flow of breathing air for atmosphere-supplying respirators | (i) |
| (c)(1)(vii) | Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations | (k) |
| (c)(1)(viii) | Training of employees in the proper use of respirators, including putting them on and removing them, any limitations on their use, and their maintenance | (k) |
| (c)(1)(ix) | Procedures for regularly evaluating the effectiveness of the program | (l) |
Notice that training appears twice, as two separate elements. (c)(1)(vii) is training on the hazards — what is in the air and what it does. (c)(1)(viii) is training on the equipment — donning, doffing, limitations, maintenance. A program that covers only the second is missing an element.
Notice also that element (c)(1)(vi) applies only as applicable: the opening of (c)(1) says the employer shall include the provisions as applicable, so a site with no atmosphere-supplying respirators writes that section short and says why.
3 Worksite-specific procedures
The phrase is the difference between a compliant program and a downloaded one, and the test is simple: could this sentence have been written by someone who has never visited your site?
“Respirators will be cleaned in accordance with manufacturer instructions” passes that test, which means it fails the standard. “Half masks are washed at the trailer sink at the end of each shift with the supplied wipes, air-dried on the rack, and stored in a sealed bag in each worker's locker” names a place, a time, a method and a storage location. That is a procedure.
The same applies element by element. Selection names your tasks and your respirators. Medical evaluation names your PLHCP. Fit testing names who administers it and when. Cleaning names the sink and the schedule. Breathing air names the compressor or says there is none. Training names the deliverer and the trigger. Program evaluation names the walk and the people consulted.
4 Program evaluation
Element (c)(1)(ix) points to paragraph (l), and paragraph (l) is short and often ignored.
(l)(1): the employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective.
(l)(2): the employer shall regularly consult employees required to use respirators to assess the employees' views on program effectiveness and to identify any problems. Any problems that are identified during this assessment shall be corrected. The factors to be assessed include, but are not limited to: respirator fit, including the ability to use the respirator without interfering with effective workplace performance ((l)(2)(i)); appropriate respirator selection for the hazards to which the employee is exposed ((l)(2)(ii)); proper respirator use under the workplace conditions the employee encounters ((l)(2)(iii)); and proper respirator maintenance ((l)(2)(iv)).
That first factor is unusually candid for a regulation. It acknowledges that a respirator which makes the job impossible will not be worn, and it makes that a program defect rather than a discipline problem. If workers are lifting facepieces to talk, or taking them off to see, the standard says fix the selection.
5 Records
Paragraph (m) requires three things to be retained.
- 1(m)(1) Medical evaluation records — retained and made available in accordance with 29 CFR 1910.1020, the records access standard.
- 2(m)(2) Fit test records — a record of the qualitative and quantitative fit tests administered to an employee, containing the five items at (m)(2)(i)(A) through (E): the name or identification of the employee tested; the type of fit test performed; the specific make, model, style and size of respirator tested; the date of the test; and the pass/fail result for a QLFT, or the fit factor and strip chart recording or other recording for a QNFT. Under (m)(2)(ii), fit test records are retained for respirator users until the next fit test is administered.
- 3(m)(3) A written copy of the current respirator program, retained by the employer.
Paragraph (m)(4) sets the access rule: written materials required to be retained under the paragraph shall be made available upon request to affected employees and to the Assistant Secretary or designee for examination and copying.
6 Writing the program in the right order
Programs written from the top of the standard down tend to be thin at the front and thick at the back. Written in the order the work happens, they come out balanced.
- 1The hazard table first — tasks, contaminants, physical form, basis for the estimate, respirator, cartridge, change schedule. Everything else refers to it.
- 2Then the people — who administers the program and how they are qualified, which PLHCP does the medical evaluations, who administers fit tests.
- 3Then the sequence — medical evaluation, fit test, training, issue. In that order, because (e)(1) requires it.
- 4Then the daily reality — seal checks, when to leave the area, cleaning, inspection, storage, and breathing air if you have it.
- 5Then the loop — how you evaluate the program, who you consult, and where the three record sets live.
A free template that follows the nine elements of (c)(1) in the CFR's own order is at the respiratory protection program generator.
- A written program is required where respirators are necessary or wherever the employer requires them, with worksite-specific procedures.
- The nine elements of (c)(1)(i)-(ix) are the table of contents for the whole standard.
- Training appears twice: on the hazards, and on the equipment.
- The program administrator must be qualified by training or experience commensurate with the program's complexity.
- Program evaluation requires consulting the wearers, and treats a respirator that interferes with the work as a defect to correct.
- Fit test records carry five items and are kept until the next fit test; a copy of the current program is retained.
Free educational content — not OSHA-authorized training, no certificate or card issued. Follow your employer's program and the standards cited.