American Variseal Corporation Respiratory Protection Program General Company Policy The purpose of this program is to establish that American Variseal is complying with the Respiratory Protection Standard, Title 29 CFR 1910.134. This program applies to all work operations at A.M Variseal where employees are required to wear respiratory protection. The EHS Coordinator is the program administrator, who has overall responsibility for the program. Definitions Airline Respirators are atmosphere-supplying respirators in which breathing air is delivered through a supply hose connected to the wearer’s face-piece or enclosure. Air-purifying Respirators are respirators with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element. End of Service Life Indicator (ESLI) is a system that warns the respirator user that the absorbing material in an air purifying cartridge or canister is saturated and no longer provides adequate protection. Immediately Dangerous to Life or Health (IDLH) is an atmosphere that is an immediate threat to life, would cause irreversible adverse health effects or would impair an individual’s ability to escape from a dangerous atmosphere. Negative Pressure Respirator is a respirator that has pressure in the face piece that is lower than outside air pressure. Breathing resistance is increased. Oxygen Deficiency occurs when the level of oxygen in breathing air is less than 19.5% by volume. Oxygen deficiency can occur in confined spaces by displacement of air by other gases and vapors or due to processes, which consume air such as fire, rusting, aerobic bacteria, etc. Positive Pressure Respirator is a respirator that has breathing air supplied to the face-piece creating a slight positive pressure inside the mask. Breathing resistance is minimal. Pressure Demand Respirator is a positive pressure, atmosphere-supplying respirator that delivers breathing air to the face-piece when the user inhales. Qualitative Fit Test is a pass/fail fit test to check respirator fit that relies on the respirator user’s sensory response to detect a challenge agent. Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 23 American Variseal Corporation Respiratory Protection Program Quantitative Fit Test is a fit test used to measure respirator fit that uses an instrument to measure the challenge agent inside and outside the face piece. Respirator is a device designed to protect the user from inhalation of hazardous atmospheres. This includes air-purifying respirators (e.g. half-mask with filter cartridges and disposable papertype devices) or air-supplied respirators (e.g. SCBA or airline respirators). Self-Contained Breathing Apparatus (SCBA) is an atmosphere-supplying respirator in which the user carries the air supply. Supplied Air Respirator (SAR) is a class of respirators that supplies a respirable atmosphere, independent of the workplace atmosphere (e.g. SCBA or air-line respirator). Special Items Forms Medical Examination Questionnaire Respiratory Protection Medical Evaluation Form Respirator Fit Test Data Form Annual Respirator Clearance Questionnaire Procedure Program Administrator The program shall be administered by a suitably trained program administrator. The program administrator must be knowledgeable of the respiratory hazards at American Variseal, be able to assess those hazards, and determine if and the level of respiratory protection necessary. The program administrator shall oversee the program and conduct the required evaluations of the program effectiveness. Hazard Assessment The EHS Coordinator shall determine, using objective data and process or task knowledge, when respiratory protection is necessary. This evaluation shall include a reasonable estimate of employee exposures to respiratory hazards and identification of the contaminants chemical state and physical form. When identification or a reasonable estimation of the employee’s exposure is uncertain, the atmosphere shall be considered IDLH. Prior to any employee being assigned respiratory protection or wearing a respirator, the EHS Coordinator shall determine, based on the information available and work to be performed, the type of respiratory protection that is necessary. This selection will be based on respiratory hazards to which the worker is exposed under routine and reasonably foreseeable emergency Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 24 American Variseal Corporation Respiratory Protection Program situations, workplace, and user factors that affect respirator performance and reliability. Once the determination that respiratory protection is necessary American Variseal must ensure that the employee has received and completed: A medical evaluation, A respirator fit test, and Appropriate respiratory protection training. Hazard Control Respirators are considered the last line of defense for protecting employee health and should only be used when control techniques are not feasible or completely successful in reducing personal exposures to hazardous atmospheres. The following are examples of control techniques that must be used to reduce airborne contamination as low as practical (listed in order of preference depending on the nature of the hazard): Substitution: Replacing hazardous materials with materials with a lower hazard potential (e.g. substituting a chlorinated solvent with a non-chlorinated solvent). Local exhaust ventilation: Capturing hazardous materials at the point of generation by means of exhaust ventilation (e.g. exhaust ventilation hood). Evaluation for Hazardous Atmospheres American Variseal has an established EHS Program that provides a number of ways to identify potential hazardous atmospheres. Routine work place inspections are conducted on a periodic basis. Industrial hygiene air monitoring is conducted to determine where respiratory protection is required. This monitoring will usually consist of air sampling and analysis. Where air monitoring is not possible, appropriate calculations will be completed to determine potential exposure to the respiratory hazard in question. Chemical Hazard Communication and Respiratory Protection training provides employees with knowledge about identification and control of respiratory hazards. Medical Evaluation Prior to the employee being issued a respirator, or being fit tested, the employee must complete the questionnaire provided in Appendix C of the OSHA standard or undergo a medical evaluation to determine the his/her ability to wear a respirator. All medical evaluations must be provided by a physician or other licensed health care professional (PLHCP) or Health Services. If the questionnaire is used the employee must be provided with a mechanism to send it to the PLHCP for confidential review. This may be accomplished by providing the questionnaire to the employee with a pre-paid, pre-addressed, envelope. Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 25 American Variseal Corporation Respiratory Protection Program If the employee gives a positive response to any question among questions 1-8 in Section 2, Part A of the questionnaire a medical examination is required. If the employee responds negatively to these questions no examination is required. The medical questionnaire and examinations shall be administered confidentially during the employee’s normal working hours or at a time and place convenient to the employee. The medical questionnaire shall be administered in a manner that ensures the employee understands its content. The Human Resources Department will coordinate any needed medical examinations. The employee will be provided an opportunity to discuss the questionnaire and examination results with the PLHCP. Any needed medical examinations will be provided on an annual basis and will be coordinated through the Human Resources Department. Examinations will be provided at no cost to the employee and be conducted by: Arbor Medical Center 303-460-9339 The EHS Coordinator will provide the following information to the PLHCP before the PLHCP makes a recommendation concerning an employee’s ability to use a respirator. The type and weight of the respirator to be used by the employee. The duration and frequency of the respirator use. The expected physical work effort. Additional protective clothing and equipment to be worn. Temperature and humidity extremes that may be encountered. A copy of this written program and a copy of the OSHA respirator standard. The PLHCP will provide a written recommendation regarding the employee’s ability to use the respirator. A follow-up evaluation may be required if an employee gives a response to any question that may indicate the users inability to safely wear a respirator or whose initial examination demonstrates the need for a follow-up medical examination. Respirator Selection Upon completing the medical examination and acquiring approval for the use of a respirator, an appropriate respirator shall be selected depending upon the hazards present in the work area. The type of respiratory protection necessary will be based on the respiratory hazards to which the employee is exposed. There are two general types of respirators, air-purifying and air-supplied. Air-purifying respirators filter and/or absorb contaminants from the air, and include half mask, full face-piece and disposable respirators. Air-supplied respirators supply a respirable Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 26 American Variseal Corporation Respiratory Protection Program atmosphere and include SCBAs and air-line respirators. Only NIOSH approved respirators shall be used and the protective device must be used in compliance with the conditions of its certification. Air-purifying respirators shall not be worn for protection against airborne chemicals that have poor warning properties, low IDLHs, or in an oxygen deficient atmosphere. Respirators, air-purifying and air-supplied, will not be worn if facial hair comes between the sealing surface of the face-piece and the face or if facial hair interferes with the valve function. The respirator will not be worn with any obstructions that may interfere with the seal of the respirator to the face. Respirator selection shall be appropriate for the chemical state and physical form of the contaminant. For protection against gases and vapors, the Company will provide: supplied air respirators (SAR) or an air-purifying respirator equipped with an end of service life indicator (ESLI) cartridge. If the respirator does not have an ESLI, EHS will develop a change schedule for canisters and cartridges that is based on objective information or data that will ensure that canisters or cartridges are changed before the end of service life. If no data exists, EHS will limit cartridge or canister use to completion of task or one shift. Chemical cartridges shall be changed upon detection of an odor. For protection against particulate matter, American Variseal will provide SARs or and APR equipped with HEPA filters. Filters shall be changed if increased breathing resistance is encountered. The issuance and use of disposable respirators will only be permitted for protection against nonhazardous or nuisance dust conditions (e.g. mowing grass, sweeping floors). Respirator Fit Testing If the physical examination indicates that the employee is fit for respirator use, a fit test shall be performed utilizing appropriate fit test methodologies. The EHS Coordinator will conduct a quantitative or qualitative respirator fit test to determine the ability of the individual to obtain a satisfactory fit. The results of the fit test shall be recorded on the respirator fit test data form. Initial Fit Testing Before any employee may be required to wear a respirator, the employee must be fit tested with the same make, model, style, and size of respirator that will be used. The fit test shall be conducted using an OSHA accepted fit test protocol (see Appendix A of the OSHA standard). Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 27 American Variseal Corporation Respiratory Protection Program If, after passing the fit test, the employee notifies the EHS Coordinator that the fit of the respirator is unacceptable, the employee shall be given a reasonable opportunity to select a different respirator face-piece and must be re-tested. Periodic Fit Testing Fit testing shall be repeated whenever a different respirator is used and at least annually. Fit testing shall also be conducted whenever the employee reports, or a nurse, supervisor or program administrator makes visual observations of changes in the employees’ 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. Inspection, Cleaning, Maintenance and Storage Air-purifying Respirators Each air-purifying respirator issued will be inspected prior and following each use. All defects noted shall be reported to the EHS Coordinator. Defective respiratory protection shall not be used. Employees shall use only those respirators that are appropriate for the hazards present and they have been trained to use. Each respirator user will perform a positive-negative pressure fit test to check for adequate face seal. Conditions that can interfere with the seal include: facial hair, facial scars, missing dentures, or corrective glasses or other personal protective equipment. Respirators shall be cleaned and disinfected periodically by the employee to provide sanitary protection for the wearer. Respirators used by more than one person must be cleaned and disinfected before being used by different personnel. Respirators maintained for use in emergencies must be cleaned and disinfected following each use. Respirators can be cleaned in warm water with a mild cleaner. The use of alcohol for cleaning shall be limited due to alcohol’s ability to deteriorate face seals with repeated use. Respirators shall be stored in a bag or appropriate container to protect it from dust, sunlight, heat, extreme cold, excessive moisture or damaging chemicals. The respirator shall be stored in a manner that will not distort the original shape of the respirator or the valves. Respirator Maintenance Only individuals specifically trained in respiratory protection repair shall repair respiratory protective equipment. Replacement parts supplied by the manufacturer shall be used to repair the product. Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 28 American Variseal Corporation Respiratory Protection Program Training Before an employee is assigned a respirator, mandatory training on proper use is required. The training must be comprehensive, understandable, and recur annually. After completion of the training the employee must be able to demonstrate knowledge of the following: Why the respirator is necessary and how improper fit, use, or maintenance can compromise the protective effect of the respirator. What the limitations and capabilities of the respirator are. How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions. How to inspect, put on and remove, use, and check the seals of the respirator. How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators. The general requirements of the standard. Required Respiratory Protection Air-purifying respirators required in the spray booth & blending operations. Add specifics: make, model, and cartridge type Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation 29 American Variseal Corporation Respiratory Protection Program EMPLOYEE TRAINING AND INFORMATION VERIFICATION FORM (Group Training) This is to certify that on ____/____/_____ the following employees have been provided information and training in accordance with the Respiratory Protection Standard regarding the following subjects: General requirements of the respiratory protection standard Why the respirator is necessary How improper fit, use, and maintenance can compromise protection Capabilities and limitations Use in emergency situations How to inspect, put on, remove, use, and check the seals on the respirator Procedures for maintenance and storage Medical signs and symptoms that may limit effective use Questions Employee Name (print) Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation Employee Signature 30 Department American Variseal Corporation Respiratory Protection Program Instructor_________________ Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation Date___________ 31 American Variseal Corporation Respiratory Protection Program EMPLOYEE TRAINING AND INFORMATION VERIFICATION FORM (New Employee or Individual Training) This is to certify that on ___/___/___ I have been provided information and training in accordance with the Respiratory Protection Standard regarding the following subjects: General requirements of the respiratory protection standard Why the respirator is necessary How improper fit, use, and maintenance can compromise protection Capabilities and limitations Use in emergency situations How to inspect, put on, remove, use, and check the seals on the respirator Procedures for maintenance and storage Medical signs and symptoms that may limit effective use Questions _______________________________________________________________ Instructor Date ______________________________ Employee Name (print) Rev. 1.0 Revision Date: 3/8/2016 American Variseal Corporation ___________________________ Employee Signature 32