GENERAL MOTORS COMPANY
UAW-GM Safety System Audit Performance Standard
RESPIRATORY PROTECTION
Document N°
UAW-GM SS APS 3.4-190
Authorized By:
Rick O’Donnell, UAW Assistant Director
Ken Glass, GM Assistant Director
Revision 1
Effective Date: May 6, 2016
1.0 Purpose
The purpose of this standard is to establish minimum requirements for the identification,
evaluation, use and maintenance of respiratory protection equipment in order to drive
aggressively towards the elimination of incidents.
2.0 Scope
This standard applies to sites that perform tasks that can potentially create respiratory hazards
as identified in element 2.0 of the UAW-GM Safety System. These requirements apply to sites
outlined in section 3.0 Scope in the General Requirements of the UAW-GM Safety System.
This standard does not apply to contractors. Where the nature of the construction or
maintenance work requires that contractor employees work in proximity to UAW-GM
employees, GM will require, as a condition of the construction or maintenance contract, the
contractor’s commitment to abide by UAW-GM plant/site Health and Safety work practices.
Construction/installation/demolition, service providers, blanket purchase order, spot buy, and
production contractors must meet or exceed regulatory requirements and contractual
agreements.
3.0 Definitions
Action Level: The level of a contaminant at which specified actions or counter measures must
be taken. The action level is generally set at 50% of the Occupational Exposure Limit (OEL).
Air-Purifying Respirator: A respirator with an air-purifying filter, cartridge, or canister that
removes specific air contaminants by passing ambient air through the air-purifying element.
Assigned Protection Factor (APF): The workplace level of respiratory protection that a
respirator or class of respirators is expected to provide to workers when the employer
implements a continuing, effective respiratory protection program. Examples of APFs are found
in the OSHA Respiratory Protection Standard.
Canister or Cartridge: A container with a filter, sorbent, catalyst, or combination of these items,
which removes specific contaminants from the air passed through the container.
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Atmosphere-Supplying Respirators: A respirator that supplies the respirator user with
breathing air from a source independent of the ambient atmosphere. They include supplied-air
respirators (SARs), airline respirators, and self-contained breathing apparatus (SCBA) units.
Emergency Situation: Any occurrence such as, but not limited to, equipment failure, rupture of
containers, or failure of control equipment, that may or does result in an uncontrolled significant
release of an airborne contaminant.
End-of-Service-Life Indicator (ESLI): A system that warns the respirator user of the approach
of the end of adequate respiratory protection, e.g., he sorbent is approaching saturation or is no
longer effective.
Filtering Face-piece Respirator: A negative pressure particulate air respirator with a filter as
an integral part of the face piece or with the entire face piece composed of the filtering medium
(e.g. N, R and P series respirators). This does not include pollen masks (one strap) and
surgical masks or any other “mask” that does not have an assigned protection factor (APF) of at
least 10.
Fit Factor: A quantitative estimate of the fit of a particular respirator to a specific individual. It
typically estimates the ratio of the concentration of a substance in ambient air to its
concentration inside the respirator when worn.
Fit Test: The use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on
an individual.
Immediately Dangerous to Life or Health (IDLH): An atmosphere that poses an immediate
threat to life, would cause irreversible adverse health effects, or would impair an individual's
ability to escape from a dangerous atmosphere.
Maximum Use Concentration (MUC): The maximum atmospheric concentration of a
hazardous substance from which a worker can be expected to be protected when wearing a
respirator. It is determined by the assigned protection factor (APF) of the respirator or class of
respirators and the OEL of the hazardous substance. The MUC can be calculated by multiplying
the assigned protection factor specified for a respirator by the OEL. When no OEL is available
for a hazardous substance, the RPC must determine a MUC on the basis of relevant available
information and informed professional judgment.
Negative Pressure Respirator (Tight Fitting): A respirator in which the air pressure inside the
face piece is negative during inhalation with respect to the ambient air pressure outside the
respirator.
Oxygen Deficient Atmosphere: An atmosphere with an oxygen content below 19.5% by
volume.
Positive Pressure Respirator: A respirator in which the pressure inside the respiratory inlet
covering exceeds the ambient air pressure outside the respirator.
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UAW-GM Safety System Audit Performance Standard
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Powered Air-Purifying Respirator (PAPR): An air-purifying respirator that uses a blower to
force the ambient air through air-purifying elements to the inlet covering.
Pressure Demand Respirator: A positive pressure atmosphere-supplying respirator that
admits breathing air to the face piece when the positive pressure is reduced inside the face
piece by inhalation.
Qualitative Fit Test (QLFT): A pass/fail fit test to assess the adequacy of respirator fit that
relies on the individual's response to the test agent.
Quantitative Fit Test (QNFT): An assessment of the adequacy of respirator fit by numerically
measuring the amount of leakage into the respirator.
Self-Contained Breathing Apparatus (SCBA): An atmosphere-supplying respirator for which
the breathing air source is designed to be carried by the user.
Service Life: The period of time that a respirator, filter or sorbent, or other respiratory
equipment provides adequate protection to the wearer.
Supplied-Air Respirator (SAR) or Airline Respirator: An atmosphere-supplying respirator for
which the source of breathing air is not designed to be carried by the user.
Respirator (Respiratory Protection Equipment, RPE): An approved device (e.g. NIOSH)
used to protect the respiratory system from the inhalation of hazardous atmospheres.
Respirators provide protection by either removing contaminants from the air before they are
inhaled or by supplying an independent source of respirable air.
Respirator Program Coordinator (RPC): A site designated person with sufficient knowledge
in respiratory protection and overall authority to coordinate all aspects of the program, with
assistance as needed.
Tight-Fitting Face piece: A respirator inlet covering that forms a complete seal with the face.
User Seal Check: An action performed by the respirator user to determine if the respirator is
properly seated on their face.
4.0 Requirements
4.1 Planning
4.1.1
Regulatory Compliance
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Each site must identify and comply with all applicable federal and state requirements
related to respiratory protection. These requirements must be part of the Regulatory
Inventory as described in section 2.1.1 of the UAW-GM Safety System.
4.1.2
Hazard Identification & Risk Assessment
Each site must conduct an exposure assessment where potentially hazardous
atmospheres exist to identify the hazardous chemicals/processes to which workers may
be exposed as described in the Chemical Exposure Assessment Audit Performance
Standard (UAW-GM APS 3.4-150), hazard identification and risk assessment processes
(section 4.1.2 of the standard).
If the monitoring results indicate there is a risk of exceeding the Action Level during
normal operations, as well as during hazardous materials emergency response releases,
the site must develop and implement a Corrective Action Plan of Controls, following the
hierarchy of controls.
When effective engineering controls are not feasible, or while they are being instituted,
appropriate respirators must be used. The following are the minimum requirements that
must be applied when approving use of respirators:
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The use of PPE is the least effective method of control because its success in
protection relies heavily on the practices of the individual wearer. The long-term
goal of the respiratory protection program is to eliminate, where possible, the use
of respiratory protection.
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Respirator use is required or mandatory when:
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There is a potential for overexposure to a contaminant
The contaminant exposure is difficult to measure and control due to
process variability
An oxygen deficient atmosphere or other IDLH atmosphere is present
An exposure assessment has not been conducted
The RPC determines respirator use is required
All activities in which respirators are required to be used must be identified as Tasks
and be included on the site’s Tasks inventory as described in section 4.1.2 of the
Personal Protective Equipment (PPE) Audit Performance Standard (UAW-GM APS 3.4180).
For all Tasks identified, a SOP or standardized work must be developed as described in
the Personal Protective Equipment (PPE) Audit Performance Standard (UAW-GM APS
3.4-180) in section 4.1.2.
All respirators and respirator accessories (e.g. filters, storage bags, etc.) must be
identified as Equipment and included on the site’s Equipment Inventory as described in
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3.4-190
UAW-GM Safety System Audit Performance Standard
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section 4.1.2 of the Personal Protective Equipment (PPE) Audit Performance Standard
(UAW-GM APS 3.4-180).
4.2 Implementation
4.2.1
Documented Program
A Respiratory Protection Program must be developed and implemented for the selection,
use, and maintenance of respiratory protection equipment that is used in daily
operations and in foreseeable emergency situations. It provides for medical
examinations, training, and fit testing of respirator users, as well as establishing a
program evaluation means to monitor the effectiveness of the program. The program
must address the following, as a minimum:
 Roles & Responsibilities
 Hazard identification and risk assessment documentation
 RPE selection process
 Medical evaluation for workers who wear respirators
 User seal checking and fit testing
 Inspection, maintenance, and storage of RPE
 RPE wearer training
 Program evaluation method
4.2.2
Roles & Responsibilities
Each site must designate a single qualified person, a Respirator Program Coordinator
(RPC), to be ultimately responsible for administering the respiratory protection program.
The RPC must have sufficient knowledge in respiratory protection and overall authority
to coordinate all aspects of the program. This knowledge may be gained through
attendance at an initial Respiratory Protection Course. . They will be assisted as needed
by designated personnel.
4.2.3
Respirator Selection
The site must follow a systematic process for the selection of RPE and ensure that
selection is completed by a qualified RPC. Selected RPE must conform to performance
criteria established by NIOSH. RPE will only be specified for use if the elimination of the
worker exposure is not feasible, during the installation of engineering controls, and if
engineering and administrative controls do not adequately control the exposure to below
the applicable occupational exposure limit (OEL). Selection criteria must be based on
the following:
 The nature of the hazard(s)
 The nature of the task
 Duration of use
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4.2.4
The capability of the available RPE technology
The use of other PPE along with the RPE and the acceptability for use by the
wearer.
The site must provide RPE capable of minimizing exposures to a level at or
below the OELs. Procedures must clearly define the specific RPE requirements,
the circumstance(s) when it must be used, and its use limitations.
The selection of specialized RPE to support emergency response actions, such
as confined space rescue operations, must be reviewed and approved by an
occupational safety or industrial hygiene professional.
Atmospheric-supplying respirators (i.e. supplied air or SCBAs) must be equipped
with pressure-demand regulators.
Filtering face-piece respirators must have a filter efficiency that conforms to the
NIOSH certification requirements.
The selection of RPE must meet the recommended levels of protection required
in the applicable chemical-specific standards.
Breathing air delivered by approved compressed air or self-contained sources
must meet the Grade D air specifications published in the U.S. Compressed Gas
Association Standard for breathing air (CGA G-1.1, Commodity Specification for
Air, current version).
Medical Evaluation and Surveillance
Each site must have a medical evaluation and surveillance process that meets the
following minimum requirements:
 GM Medical Surveillance policy applies to all locations globally. This policy is set
by the GM Health Services organization to protect our employees from
occupational related injury and illness.
 At locations where local or state regulatory requirements are more stringent than
GM policy, the local or state requirements will be followed.
 Evaluations are conducted to ensure the use of RPE will not pose any additional
hazards to the wearer, as well as ensuring the continued health of the RPE
wearer, through the identification of any potential disease outcomes as a result of
the program or RPE deficiencies.
4.2.5
User Seal Check and Fit Test
Each site must have a user seal check and fit test process that meets the following
minimum requirements:
 Prior to the donning of a negative or positive pressure tight-fitting face piece
respirator, the wearer must complete a user seal check to determine if the RPE is
properly fitted to their face and in accordance with the manufacturer’s
instructions.
 When tight-fitting respiratory protection is required to be worn, each wearer must
be fit tested for the respirator prior to use to ensure that the make, model, and
size will provide an acceptable face to face-piece fit. The fit test method used and
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UAW-GM Safety System Audit Performance Standard
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4.2.6
the periodic update (e.g. annually) must follow either the federal, state or local
regulatory requirements, or the manufacturer’s recommendation, whichever is
more stringent.
When respiratory protection is required, tight-fitting respirators may not be used
when conditions prevent a proper seal of the RPE to the wearer or cause
interference with the valves.
Such conditions include: facial hair that comes between the sealing surface of
the face-piece and face or that interferes with valve function; any spectacle with
temple bars or straps; and a head covering, goggles, face shield, welding helmet,
or other PPE device which pass between the sealing surface of the RPE and the
wearer’s face. In addition, the following requirements must apply:
– The site’s position on tight-fitting respirator use with facial hair must be
clearly defined and include when facial hair is and is not acceptable.
– Facial features which prevent a good seal of the RPE tight-fitting facepiece to a wearer’s face may disqualify the person from wearing a
respirator.
Personnel that conduct fit testing must be evaluated annually and retrained if
necessary. This training must be provided by the fit test system manufacturing
representative or personnel trained by the representatives.
Equipment Inspection, Maintenance, and Storage
Each site must implement a process for the inspection, maintenance, and storage for all
respiratory equipment (e.g. respirators and respirator accessories) identified in section
4.1.2 of this standard, that meets the following minimum requirements:
 Prior to each use, respirators must be inspected according to the manufacturer’s
instructions or federal/state/local regulatory requirements, whichever is more
stringent.
 In order to be maintained in a sanitary condition, each respirator should be
washed according to the manufacturer’s instructions.
 Repairs to respirators may only be performed by qualified personnel using only
replacement parts approved by the manufacturer.
 Respirators must be stored when not in use in a manner that protects them from
damage, contamination, dust, sunlight, extreme temperatures, excessive
moisture, and damaging chemicals, as well as to prevent any deformities of the
face-piece and valves. The original respirator storage bags may be used for this
purpose.
4.2.7
Respirator Change Schedule
Each site must implement a respirator change schedule process that meets the following
minimum requirements:
 An air purifying respirator must be equipped with a certified (e.g. NIOSH) end-ofservice-life indicator (ESLI) for the contaminant.
 If there is no ESLI appropriate for conditions in the site, a change schedule must
be implemented for canisters and cartridges that is based on objective
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4.2.8
information or data that will ensure that canisters and cartridges are changed
before the end of their service life.
The change schedule should be posted in the affected areas.
The respirator wearer is responsible to determine when to change their filters and
cartridges.
A description of the information and data relied upon, the basis for the canister
and cartridge change schedule, and the basis for reliance on the data must be
included in the respirator program.
Voluntary Use of Respirators
When air sampling demonstrates the potential for overexposure as compared to the
action level or an oxygen deficiency is unlikely, use of respirators is considered
voluntary. To use voluntary respirators, the following conditions must be met:
 A respirator medical evaluation has determined the worker is physically capable
of wearing a respirator. This includes filtering face piece respirators.
 Training must be conducted for the voluntary use of elastomeric face-piece
respirators or PAPRs (e.g. half- or full face-piece filter or cartridge air purifying
respirators or supplied air respirators). Note: No fit testing is required with
filtering face piece respirators.
 Appendix D of the OSHA Respiratory Protection Standard must be provided to all
Voluntary Users of Respiratory Protection, including those who wear filtering
face-piece respirators.
Note: if employees are not required to wear a respirator, and voluntarily choose instead
to purchase and wear a “mask” for comfort that does not have an applied protection
factor (APF) of at least 10, (e.g. pollen mask, surgical mask), then there is no
requirement for a medical evaluation, training, fit testing or providing Appendix D from
the OSHA Respiratory Protection Standard as these are not considered filtering face
piece respirators.
4.2.9
Training
Each site must have a documented training program for respirators that meets the
following minimum requirements:
 The Respirator Program Coordinator (RPC) must ensure that respirator wearers
receive appropriate training on the proper and safe use of respirators.
 The RPC must establish and implement more frequent training requirements for
workers who use more complex RPE types, such as self-contained breathing
apparatus (SCBA) and powered-air purifying respirators (PAPR).
 Annual training must address the following:
– The potential and actual hazards for which respiratory protection may be
used
– The adverse effects of exposure if the respirator is not properly used,
including signs and symptoms of exposure
– Tasks and areas for which respiratory protection use is required
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3.4-190
UAW-GM Safety System Audit Performance Standard
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Why the respirator is necessary and how improper fit, usage, or maintenance
can compromise the protective effect of the respirator
What the limitations and capabilities of the respirator are, including the
replacement requirements for filters and cartridges
How to put on (don) and remove (doff), use, and conduct the user seal
checks and fit test of the respirator
How to use the respirator effectively in emergency situations, including
situations in which the respirator malfunctions, and the use of emergency
escape devices, including limited use SCBAs and mouthpiece devices
How to inspect, maintain, and store respirators
How to recognize medical signs and symptoms that may limit or prevent the
effective use of respirators
Site specific work rules, such as facial hair policies
Specialized training for workers who wear air-supplying respirators, including
SCBAs and airline respirators
4.2.10 Emergency Response
Each site must include in the emergency response process the following minimum
respirator related requirements:
 Each site must identify and address specialized training needs for emergency
response situations which involve the use of emergency RPE.
 SCBA wearers must receive specific training and demonstrate proficiency
through planned drills, in accordance with the site’s emergency response plan.
 A frequency of initial and refresher training must be established to meet
proficiency and federal/state/local regulatory requirements.
 Sites that use SCBA equipment for emergency response must complete a
documented needs assessment that includes the minimum number of supplied
air systems required.
4.2.11 Documentation
Documents and records related to respirators must be included in the site’s document
control program as outlined in section 3.3 of the UAW-GM Safety System, and retained
in accordance with ILM requirements. At a minimum, these include the following:
 Hazard identification and risk assessment documentation
 A log of all required use and voluntary respirators issued
 Worker training records
 Planned inspection documentation
 Program evaluation documentation
4.2.12 Management of Change
The site must have a documented process to identify, and control all new respiratory
protection related hazards associated with people, equipment, or process changes,
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UAW-GM Safety System Audit Performance Standard
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which is consistent with requirements outlined in the Management of Change Audit
Performance Standard UAW-GM SS APS 3.5-010.
Hazard Identification Inventories and Risk Assessments outlined in section 4.1.2 of this
standard must be updated to reflect any changes.
5.0 Checking and Corrective Action
5.1
Planned Inspection
The site Planned Inspection Program must include Task observations and Equipment
inspections associated with respirator use in order to monitor whether the rules and
procedures are being followed.
5.2
Program Evaluation
The Respirator Program Coordinator (RPC) must conduct an annual program review to
evaluate implementation effectiveness. At a minimum, this review must include the
following:
 Investigation of reports of hazardous atmospheric exposure incidents, including nearmisses and fatalities
 Related corrective and preventative actions to ensure timely completion and
evaluation trends
 Fit testing records
 Inspection, maintenance, and storage of respirators
 Planned inspection records and employee feedback
 Work procedures which specify the use of RPE
 Training effectiveness
 Assessment of the program against the long-term objective of eliminating the need to
wear RPE
The results of this program evaluation must be reviewed during the Leadership Review process
as outlined in section 5.0 of the UAW-GM Safety System.
6.0 Related Documents
UAW-GM SS APS 2.4-180 – Personal Protective Equipment Performance Standard
OSHA Standard 29 CFR 1910.134 Respiratory Protection
UAW-GM SS GD 2.4-180 – Respiratory Protection
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Document N°:
UAW-GM SS APS
3.4-190
UAW-GM Safety System Audit Performance Standard
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Revision History
Date
8/17/2015
Rev #
0
3/29/2016
1
Change Made
Initial Version based off GMS & Revisions of Purpose
and Scope; added definition & references to the term
Action Level
UAW-GM version, first version.
Author(s)
E. Bolden
B. Chapman
T. Cobb