HAZMAT vs. HAZWOPER - What Is The Difference?

OSHA DEFINITIONS: from: http://www.osha-slc.gov/html/faq-hazwoper.html

• HAZARDOUS MATERIAL is defined as: A substance (gas, liquid or solid) capable of creating harm to people, the environment, and property. Examples are: solvents, paints, gasoline, adhesives, and lubricants.
• HAZARDOUS WASTE is a contaminated chemical or by-product of a production process that no longer serves its purpose and needs to be disposed of in accordance with the Environmental Protection Agency. This could include small amounts of chemicals such as parts washing solvents in a machine shop, or large amounts of construction by-products.
• The term HAZMAT is often used when discussing the transport or clean up of hazardous materials, but it actually can mean any aspect of hazardous materials production, transport, use, disposal, cleanup, or emergency response. OSHA and the EPA are major agencies of concern.
• HAZWOPER refers to ALL training that deals with hazardous waste operations and emergency response to chemical spills or releases. For more detail, see the following question/answer.)

Q: Who is covered by OSHA's HAZWOPER Standard?
A: The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. This includes any employees who are exposed or potentially exposed to hazardous substances -- including hazardous waste -- and who are engaged in one of the following operations as specified by 1910.120(a)(1)(i-v) and 1926.65(a)(1)(i-v):

• clean-up operations, required by a governmental body, whether federal, state, local, or other involving hazardous substances, that are conducted at uncontrolled hazardous waste sites;
• corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);
• voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;
• operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by 40 CFR 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and
• emergency response operations for releases of, or substantial threats of release of, hazardous substances regardless of the location of the hazard.

Q: So, what's the difference between a 40-Hour and a 24-Hour Hazardous Waste Operations and the difference between the 24-hour Hazardous Waste Operations and the 24-Hour Emergency Response?
A: 40-Hour or Initial Hazardous Waste Operations training is mandatory for persons engaged in hazardous substance/waste removal or other associated activities (such as equipment operators, drillers, laborers, supervisors, geologists, engineers, environmental managers, safety and health professionals, regulatory personnel and others interested in the environmental field) before they begin work at an uncontrolled hazardous waste site. The standard requires 40 hours of off-site training and 3 days of field experience. Some topics that may be included: Applicable OSHA and EPA regulations, monitoring and sampling equipment, properties of hazardous materials, site safety planning, levels of personal protective clothing (PPE), respiratory protection, decontamination procedures, chemistry of fire, safe work practices, site control, CPR and First Aid.
OSHA 29 CFR 1910.120 (e) (3) (I) states: "General site workers, such as equipment operators, general laborers and supervisory personnel, engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and minimum three days actual field experience under the direct supervision of a trained, experienced supervisor."

24-Hour Hazardous Waste Operations is for technicians, contractors, consultants, supervisors and managers, etc. who are not required to have the 40-Hour training prior to working at a hazardous material/waste site which includes: routine site employees and supervisors/managers who have minimal exposure, non-routine site employees and supervisors/managers of a hazardous waste clean-up site, or general site workers at a hazardous waste treatment, storage, or disposal site. Generally, this training is for persons who might visit a waste site but whose potential for exposure to the hazardous waste is extremely low. Some topics that may be included: the emergency response plan, basic chemical and toxicology terms, levels of Personal Protective Equipment (PPE), hazard and risk assessments, and control and containment techniques.

OSHA 29 CFR 1910.120 (e)(3)(ii) Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours.

OSHA 29 CFR 1910.120 (e)(3)(iii) Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are under the permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency, shall receive a minimum of 24 hours of instruction off site and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor.

24-Hour Emergency Response or Hazardous Materials Technician Level training is for workers and supervisors with the responsibility of responding to hazardous materials releases and spills. This is the minimum level of training required to respond to spills as a member of a hazardous materials emergency response team. Some topics that may be included: the emergency response plan, basic chemical and toxicology terms, site safety and control, hazard and risk assessment, medical monitoring, respiratory protection, Personal protective equipment (PPE) selection, care, and use, monitoring and sampling equipment, confinement, control, and cleanup, decontamination procedures, and incident command.

OSHA 29 CFR 1910.120 (q)(6)(iii) Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch, or otherwise stop the release of the hazardous substance.

NOTE: the Technician Level is only one of five levels of training under the standard OSHA 29 CFR 1910.120(q)(6). The 5 levels are:

1. First Responder Awareness or Level 1 training.
1910.120(q)(6)(i) First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release.
2. First Responder Operations Level 2 training.
1910.120(q)(6)(ii) First responder operations level. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. First responders at the operational level shall have received at least eight hours of training.
3. Hazardous Materials Technician or Level 3 training is described above.
4. Hazardous Materials Specialist or Level 4 training.
1910.120(q)(6)(iv) Hazardous materials specialist. Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with Federal, state, local, and other government authorities in regards to site activities. Hazardous materials specialists shall have received at least 24 hours of training.
5. On Scene Incident Commander or Level 5 training.
1910.120(q)(6)(v) On scene incident commander. Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training.

Q: I'm looking into taking a 40-hour HAZWOPER course. Would that qualify me to be an emergency responder for hazmat spills?
A: This is a good question and one that people can confuse easily and for good reason. After all, the acronym HAZWOPER means hazardous waste operations and emergency response. Most people then assume that if they take the popular 40-hour HAZWOPER course that they are qualified in the emergency response portion as well as the operations. The OSHA regulations for HAZWOPER are found in 29 CFR 1910.120. 1910.120(a)(2) defines the application of the standards. The standard points out three types of personnel to which different parts of the regulation apply:

1) Workers at hazardous waste sites;
2) Workers at treatment, storage, and disposal facilities (TSDF); and
3) Hazardous materials emergency responders

To each type of personnel, different sections of the regulation are assigned: to the General Hazardous Waste Site Worker's sections (a) through (o) are applicable; to the TSDF workers only section (p) is applicable; and to the hazmat emergency responders, section (q) is applicable. Each of the three personnel categories have their own regulations regarding operations and training, which makes sense since the knowledge that one would need to work at a hazardous waste cleanup site would be different than a hazmat team would need in responding to an emergency. Although some of the training elements are the same, a person with a 40-hour Hazardous Waste Operations certificate would still need additional hours of training to address the objectives of the HAZMAT Technician course. The number of hours would vary depending on the original course content.

Q: My 8-hour refresher training expired last week but I am scheduled to take that class again in two weeks. Is my training out of compliance?
A: Technically, yes, the worker in this case is out of compliance with the training requirements of 29 CFR 1910.120. The annual training requirement means within 12 months of the last 8-hour refresher course taken. There is no "grace period" for training where you are allowed a window of time to get the training as close to the anniversary date as possible. If you are on a site after the training expires, OSHA has the right to cite your company for non-compliance with the training requirements.

Q: It has been a couple years since I took my 8-hour refresher. Do I need to take the initial training again?
A: If the date for refresher training has lapsed, the need to repeat initial training must be determined based on the employee's familiarity with safety and health procedures used on site. The employee should take the next available refresher training course. There should be a record in the employee's file indicating why the training has been delayed and when the training will be completed.

Q: I just completed the initial HAZWOPER site worker course and was wondering if I need to take an additional DOT course in order to sign hazardous waste manifests for shipment.
A: Unfortunately the answer is yes. You will have to take the additional DOT course in order to comply with 49 CFR 172.704 subpart H. Sometimes multiple agencies have jurisdiction on the activities we do in our business and they may all require specific training for the function they regulate, even if some of the training is redundant. The good news is that you will have an easier time in the DOT class now that you have the background of the HAZWOPER course, as some of the required topics are the same for both courses.

Q: Is a land surveyor working on a capped landfill required to have completed a 40-Hour Hazardous Waste Operations training course? And what if the surveyor is on an uncapped landfill?
A: The employer must demonstrate that the operation being performed, in this case surveying, does not involve employee exposure or the potential for exposure to the safety and health hazards of the site. As OSHA stipulates in a letter of interpretation for 29 CFR 1910.120 dated 2/12/92, 29 CFR 1910.120 does not apply to workers where there is no potential for exposure to hazardous substances found at the clean-up site or, in this case, the landfill. With this noted, if the surveyor is performing non-invasive work and is in controlled areas of the site where potential hazards have been abated, Hazardous Waste Operations training may not be necessary. Hazard Communication or the "Right to Know" training would be required as outlined in 29 CFR 1910.1200.
On an uncapped landfill, more-than-likely hazards exist and have the potential to expose the surveyor. In this case, the surveyor would need 40-hour training. Each site and employee needs to be evaluated properly since there is no blanket solution for every individual performing tasks on different sites. Employers need to ensure they have adequate documentation, (such as site characterization data and air monitoring logs), for why an employee does or does not have 40-hour training on hazardous waste sites.

Confined Space Entry

Q: What is the definition of a confined space for general industry?
A: A confined space is defined as a space that:

(1) is large enough that an employee can bodily enter and perform assigned work,
(2) has limited or restricted means to enter or exit (e.g. tanks, vessels, silos, storage bins, vaults, pits, etc.), and
(3) is not designed for continuous employee occupancy.

Note: Construction standards for confined space (29 CFR 1926.21) are different.

Q: What is the difference between the "non-permit" and the "permit-required" confined space:
A: "non-permit" confined space is a confined space that does not contain or have the potential to contain atmospheric hazards capable of causing death or serious physical harm.
"permit-required" confined space has one or more of the following characteristics:

(1) contains or has the potential to contain a hazardous atmosphere,
(2) contains a material that has the potential to engulf an entrant (e.g. grain, water, sewage, etc.),
(3) the space has a configuration whereby an entrant could get trapped or asphyxiated by inwardly converging walls or a floor that slopes downward and tapers to a smaller cross-section, or
(4) contains any other recognized serious safety or health hazards.

Applying these regulations to a work site is sometimes confusing. Upon entrance into a confined space, the employer should assume that the employees will be working in a "permit-required" confined space based on the above definition. To remain in compliance with the standard, "permit-required" confined space entry procedures are mandatory until there is enough evidence to classify the space as a "non-permit" confined space (following paragraphs (d) through (k) of the standard).
If the employer can prove and document the numbered steps listed below, then the employer can reclassify the permit space.

1. The employer must prove that the only hazard posed is an actual or potentially hazardous atmosphere.
2. The employer needs to demonstrate that continuous forced air ventilation alone is sufficient to maintain the space safe for entry.
3. The employer has sufficient monitoring and inspection data to support the abated hazards above.

After all hazards have been eliminated in the space, the standard allows for the employer to reclassify the permit space (see paragraph (c)(7) of the regulation). The following procedures must then be followed. If you can abate all of the hazards and the permit space poses no actual or potential atmospheric hazards without initially entering into the space at all, then the permit space can be reclassified as a non-permit confined space, as long as the non-atmospheric hazards remain abated. As mentioned, if entrance into the permit space is required to eliminate the hazards, such entry must be performed under paragraphs (d) through (k) in the standard, referencing the permit required confined space program and procedures.
The employer must document the basis for determining that all hazards in a permit space have been eliminated. The documentation includes the date, location of the space, and signature of the person making the determination. As feasible as it is to reclassify a permit space to a non-permit space, if hazards arise within the space, the employees must exit immediately and the employer is then responsible for re-evaluating the space to determine whether it must then be reclassified to a permit required confined space. Through the entire work phase while working in permit or non-permit spaces, documentation to support all decisions made with regards to a space's classification must be complete, current, and available to all employees and site visitors. As with many OSHA standards, companies working with confined spaces need a written document for procedures and a training schedule for all employees involved in this type of work.
Training: Before permit space work begins, the employer must train workers who work in permit spaces (authorized entrants). Rescue team members must also receive training, including training on CPR and first aid. In addition, employers must train attendants and entry supervisors on their duties.

Q: We have some confusion about entry ways to confined spaces. Would you offer some clarification on such things as trap doors and other small openings?
A: If an employee must bend down to avoid striking the top of an opening or step over a raised threshold, as might be the case with a trap door or access panel, OSHA would consider this opening as restrictive to entry or exit. The intent of the standard is to ensure quick exit in the event of an emergency situation. This could lead to the classification of a confined space. For example, heating and ventilating equipment spaces, such as fan chambers and return air shafts, would likely not be considered a confined space if there is a standard door as entry/exit. However, access through other than a standard door would reclassify the space as confined space. This would be due to the restriction to entry and exit to a space that could contain mechanical hazards such as fan blades, chain and belt drives. The same test would apply if there were a chemical hazard.

The Universal Waste Rule

Q: What is this thing called the Universal Waste Rule and, what do I need to know about it?
A: The Universal Waste Rule (UWR), promulgated by the Environmental Protection Agency (EPA) on May 11, 1995 as an amendment to the Resource Conservation and Recovery Act (RCRA) regulations, applies to hazardous waste batteries, thermostats, pesticides, and lamps. It was developed to reduce the regulatory burden on businesses that generate these wastes, to promote the proper recycling or disposal of these items and reduce the amount of hazardous waste items in the municipal solid waste system, and to provide for collection opportunities for communities and businesses. Prior to the UWR, hazardous waste batteries and other items were managed by transporting the materials to treatment, storage, and disposal facilities (TSDF) regulated by 40 CFR Parts 264 and 265. Under the UWR (40 CFR Part 273) the TSDFs are now designated as Destination Facilities and universal wastes are handled by Universal Waste Handlers. Your business benefits from the UWR in that the rule streamlines the requirements related to notification, labeling, marking, prohibitions, time limits, employee training, response to releases, offsite shipments, tracking, exports, and transportation of hazardous waste. For example, the rule extends the amount of time that a business can accumulate these materials on site, it also allows companies to transport them with a common carrier instead of with a hazardous waste transporter, and the rule no longer requires companies to obtain a manifest. However, UWR does not apply to businesses that generate less than 100 kilograms of universal wastes per month (Conditionally Exempt Small Quantity Generators). The EPA encourages these businesses to participate voluntarily in collection and recycling programs by bringing these wastes to collection centers for proper treatment and disposal. If your business is in Maine, the Maine Department of Environmental Protection (DEP) recently incorporated changes in their UWRs to coincide with the EPA's UWRs. These changes can be seen in Chapters 850, 851, 853, and 857. Maine has also added automotive mercury switches to the rule. Sources: www.epa.gov, keyword search "Universal Waste Rules"; www.maine.gov/dep

Q: How does EPA define "hazardous" (according to RCRA) as opposed to OSHA?
A: The EPA applies the term "hazardous" to solid wastes (according to the Resource Conservation and Recovery Act [RCRA]) that, based on their quantity concentration or toxicity, pose a significant threat to human health or the environment. The EPA focuses on minimizing the public's exposure to these substances. OSHA defines the term "hazardous" to include all substances for which exposure results in or may result in adverse health effects for employees. For example, the EPA does not regulate nuisance dust unless there is a listed or characteristic chemical attached to the dust levels that exceed RCRA guidelines. OSHA does regulate nuisance dust to the extent that the dust itself has the potential to expose workers to adverse health effects when exceeding permissible exposure limits.

Hazard Communication

Q: Why was the Hazard Communication Standard promulgated?
A: OSHA promulgated the Hazard Communication Standard to ensure that all employers receive the information they need to inform and train their employees properly on the hazardous substances they work with and to help design and put in place employee protection programs. It also provides necessary hazard information to employees, so they can participate in and support the protective measures at their workplaces.

Q: Is there a list of substances regulated by the Hazard Communication Standard?
A: No. The rule requires chemical manufacturers and importers to evaluate the hazards of the chemicals they produce or import and to prepare appropriate labels and material safety data sheets to convey the hazards and precautionary measures to users of the chemicals. As a user, you can rely on the suppliers to provide you with appropriate information to comply with the Hazard Communication Standard.

Q: What are the associated benefits of implementing the Hazard Communication Standard?
A: The Hazard Communication Standard provides workers exposed to hazardous chemicals with the right to know the identities and hazards of those materials, as well as appropriate protective measures. When workers have such information, they are able to take steps to protect themselves from experiencing adverse health effects from exposure. In addition, providing such information to employers helps them to design better protective programs for exposed employees.
There are significant benefits associated with the implementation of the hazard communication standard in the workplace. Employers have used the information provided to select personal protective equipment, design engineering controls, and substitute less hazardous chemicals. All of these actions will improve protection of workers. In addition, the written information can be used to train workers to properly handle the chemicals.

Q: A new format for Material Safety Data Sheets (MSDS) has been developed by the American National Standards Institute (ANSI). Am I required by OSHA to comply with this standardized format?
A: No, it is a voluntary standard. OSHA allows any format as long as it includes the information stated in CFR 1910.1200 (g). The purpose of the new format is to make it easier to find information regardless of the MSDS supplier. The new format is intended to be user-friendly to a wide range of educational levels. The MSDS is divided into 16 sections and prioritized according to the information's usefulness. The new categories, in order, are: Chemical Product and Company ID; Composition; Hazard Identification; First Aid Measures; Fire-Fighting; Accidental Release; Handling and Storage; Exposure Controls and Personal Protection; Physical and Chemical Properties; Stability and Reactivity; Toxicology; Ecological Information; Disposal; Transport; Regulations; and Other Pertinent Information. Users can readily access the category they need at the moment.

Q: On a hazardous waste site, are heat stress symptoms recordable as an illness on the OSHA 300 log (formerly the OSHA 200 log)?
A: You are required to record nonfatal occupational illnesses or injuries which involve one or more of the following: loss of consciousness, restriction of work or motion, transfer to another job, or medical treatment (other than first aid). In the case of heat stress, medical treatment by a health care provider is possible. If professional medical treatment for the heat stress is provided, the case must be recorded as an illness.

Q: What is the most common workplace injury reported to OSHA, and how much is it costing the economy?
A: According to a recent Bureau of Labor Statistics report, carpal tunnel syndrome is the most common workplace affliction with half of those workers so afflicted missing 30 days or more of work. Women were nearly three times as likely to develop carpal tunnel syndrome and were just as likely to receive those injuries on an assembly line as on a keyboard. Cumulative trauma disorders cost the American economy more than $100 billion annually and take the most severe toll on working women. The Bureau of Labor Statistics reported in 2003 that nursing homes and other personal care facilities are the third most hazardous workplaces in the country. More than 82,000 workers lost time due to injuries and illnesses. Nursing homes ranked first in the frequency of overexertion injuries with a rate of four to five times the national rate. Nurses' aides who lift and move patients accounted for a large portion of those injuries.

Q: How long must we retain MSDSs after we have stopped using a specific chemical?
A: The time period over which you must retain the MSDSs is addressed in two ways. Both are based on the ability of a worker to go back over time to determine what an occupational exposure could have been. Basically, MSDSs must be maintained by an employer for at least 30 years as required under 1910.1020 (d) (1) (ii). There is an alternative to this standard [1910.1020 (d) (1) (ii) (B)] that can reduce the extent of paper storage required. MSDSs and records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity of the substance, where it was used, and when it was used is retained for at least 30 years. Therefore, employers may discard the original data sheet and retain only the new sheet if they retain a list with chemical name, where and when used, and maintain that list for 30 years.

Q: What purpose do Action Levels serve in relation to chemical vapor exposure?
A: Action Levels are one-half of the Permissible Exposure Limit (PEL) and represent the level at which employers take action to protect the worker and reduce exposure. OSHA identifies three means of reducing employee exposure when action levels are detected through air-monitoring. They are:

1) installing engineering controls;
2) implementing work practice modifications;
3) assigning personal protective equipment (PPE).

These are listed in order of the most effective approach and OSHA preference. While it is oftentimes easy to use PPE to reduce exposure, please note that this is the last method of action to be taken. Engineering controls should be implemented before either of the other options.

Q: Do I need a certified first aider on a hazardous waste site?
A: According to 29 CFR 1910.151, the Medical Services and First Aid Standard, if the workplace is not in close proximity to an infirmary, clinic, or hospital, a person adequately trained to render first aid must be on site. OSHA further defines "close proximity," in an interpretation letter dated November 19, 1992, to be three or four minutes for response if a life threatening injury or illness could occur. In other circumstances where a life threatening injury is unlikely, response time of 15 minutes is acceptable. This standard applies to all industrial workplaces as well.

Q: What can I do to reduce heat stress for my employees in the summer?
A: Common sense dictates the most effective means to reducing heat stress. Provide adequate drinking water and make it readily available so workers can stay adequately hydrated. Dehydration is accelerated with heat and sun. Encourage workers to wear T-shirts and long pants or other coverings to limit exposure to the sun. Encourage the use of sunscreen with protective SPF levels and encourage workers to wear hats to both keep the sun off their heads as well as shade their faces. If you have employees who must work in direct sun, rotate them to other positions to minimize the amount of time they are continually exposed to the sun. Provide shade, if possible, and work during cooler hours, i.e., the early morning or later afternoon.

Q: What is the noise level in an open cab excavator and should I be requiring hearing protection?
A: The best way to measure noise levels is through noise hazard evaluation and measuring an 8-hour time weighted average (TWA) for noise to ensure levels are below 85 decibels of noise. OSHA regulates noise at 85 and 90 decibels, according to 29 CFR 1910.95. 85 dB represents the point at which an employer must provide audiometric (hearing) testing and offer hearing protection to employees. Audiometric testing, hearing protection, a company written program, and training are required at 90 decibels. For more information on hearing conservation requirements, refer to 29 CFR 1910.95. The National Institute of Occupational Safety and Health (NIOSH) has published some examples of noise levels that would require hearing conservation programs. Here are some facts about the levels of noise. Are you protecting your workers hearing adequately?
Common Workplace Noise Sound Meter in Decibels (dB)

Bulldozer 105 dB
Spray Painter 105 dB
Chain Saw 110 dB
Tractor 96 dB
Hand Drill 98 dBv

(As a point of comparison, normal conversation = 60 dB, ringing telephone = 80 dB.)

Q: If an employee has already left our company and we did not offer him or her an exit medical surveillance exam, what should we, as the employer, do when we have recognized this error several months later?
A: According to OSHA, the best course of action at this point is to send a certified letter to the employee offering an exam. If the employee chooses to decline, the employer's obligation is satisfied. If the employee chooses to have the exit exam, the employer will be obliged to pay for such services.

RESPIRATOR PROTECTION

Some Common Acronyms:

Qualitative Fit Test, (QLFT)
Physician or Other Licensed Health Care Professional (PLHCP)
High Efficiency Particulate Air (HEPA)
Immediately Dangerous to Life or Health (IDLH)
Short Term Exposure Limits (STELs),
Self-Contained Breathing Apparatus (SCBA)

Q: When does the standard require respirators to be worn?
A: Whenever it is necessary to protect the health of the employee from contaminated or oxygen deficient air. This includes situations where respirators are necessary to protect employees in an emergency.

Q: Which respirator use requires fit testing?
A: Fit testing is required when OSHA or the employer requires employees to wear tight fitting respirators. The employee must pass a fit test prior to the initial use of the respirator. Additional fit tests are required whenever the employee reports, or the employer, Physician or other Licensed Health Care Professional (PLHCP), Supervisor, or Program Administrator observes changes in the employee's physical condition that could affect respirator fit. If the employee changes to a different fitting face piece a new fit test is required. An annual fit test is required after the initial fit test.

Q: How long must fit test records be maintained?
A: For one year, until the next fit test is completed and recorded.

Q: How extensively must the employees be trained concerning the maintenance and storage of respirators?
A: Where employees perform some or all respirator maintenance and store respirators while not in use, detailed training in maintenance and storage procedures may be necessary. In other facilities, where specific personnel or central repair facilities are assigned to perform these activities, most employees may need only to be informed of the maintenance and storage procedures without having to learn significant technical information.

Q: How frequently should the written respiratory protection program be updated?
A: The standard requires that employers revise the program as necessary to reflect changes in the workplace or in respirator use. The written program shall be updated whenever the change occurs. Changes would include different respirator choices, changes in fit testing, and work operations that change.