When was the last time your employees had a fit test? A fit test is the use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. OSHA compliance is more then just following OSHA regulations or protecting your workers. It is also about protecting your company. One accident or injury could literally close your pest management firm’s doors.
Does you company have the necessary documented fit tests, should OSHA pay a visit after one of your employees is hurt on the job? Working in the pest control industry for more than 20 years, I can honestly say I have had only one fit test. This was when I was a branch manager and I requested the fit test for my employees. I worked for six different companies over this time span, so you can see there are quite a few companies that are unaware of OSHA’s standards.
What follows are excerpts of OSHA’s compliance recommendations for respirators. It states that you must give a fit test prior to initial use (new employees) or whenever an employee changes the size, model or make of a respirator, and at least annually after that. Also, whenever an employee reports, or you observe changes in an employee’s physical condition that could affect the respirator’s fit, including an obvious change in body weight. Here’s what OSHA says:
The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter.
The employer shall conduct an additional fit test whenever the employee reports, or the employer, PLHCP (physician or other licensed health-care professional), supervisor, or program administrator makes 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.
YOUR REQUIREMENTS. Aside from the fit test, you are also required to establish and implement a written respiratory protection program with the following provisions, as applicable:
- Procedures for selecting respirators to be used while working.
- Medical evaluations of employees required to use respirators. (How many companies send their potential employees for a physical?)
- Procedures for proper use of respirators. This includes training of employees in the proper use of a respirator including:
a. Putting on and removing the respirator. Your employees must know how to properly wear a respirator to obtain the full benefit of it.
b. Any limitation on respirator use. As silly as it may sound you want your employees to understand the difference between a respirator and self contained breathing apparatus (SCBA).
c. Respirator maintenance, cleaning and storage requirements.
d. Procedures for regularly evaluating the effectiveness of the program.
e. Procedures to ensure respirator cartridges or other filtering components will be replaced according to an established schedule.
Additionally, the pest management firm must establish employee responsibilities, which include:
- Only use respirators for which you have been properly fit tested.
- Use respirator whenever required by the label or MSDS.
- Properly clean, sanitize and maintain the respirator issued to them.
- Store respirator in a clean plastic bag.
- Maintain clean shaven face.
- Immediately report to a company manager any malfunction or damaged respiratory equipment.
The author is loss control manager for Capital Risk Underwriters, an insurance firm tailored for the pest control industry. E-mail him at firstname.lastname@example.org.