Written Respiratory Protection Program Basics
If workers need to wear a respirator for safety, the employer is required by Cal/OSHA §5144(c) to have a written respiratory protection program. To understand more about the requirements for workplace respirator use, please see the article on Cal/OSHA Respiratory Protection Guidelines. A written program is important for ensuring hazards are accurately assessed and controlled, and to have effective and consistent guidelines for how respirators will be used in the workplace.
The two most common mistakes in written respiratory program implementation are generic templates that are not adequately customized to the company, and overly-lengthy programs that can't be easily read or understood. This usually is the result of a company hastily implementing a template they found online, or that was provided as a value added by a fit test vendor. However, they can also be seen in programs created by safety professionals.
Whether a company is thinking of taking a DIY approach, or hiring a consultant, they should be familiar with the required elements for a respirator program. Even if a company outsources the creation of their respirator safety program, it's still important for managers to be familiar with the required elements, since they will have to take ownership of the program when it's completed. This is something we emphasize every time we provide a program proposal to a potential client.
Here's what your program should include:
- Responsibilities
- Who will oversee the program and what will their specific duties be?
- How often will the program be reviewed for effectiveness, and what does that process involve?
- Hazards and Controls
Note: This can be the most complex part of a program, and even companies that write their own program may use a consultant for help with this portion. - What air contaminants to employees have to be protected against? You will have to do some research, and maybe even measurements of contamination levels.
- Are there any steps that can be taken to eliminate or reduce the hazard using a hierarchy of controls approach ? Employers are required by law to make a good faith effort to eliminate or reduce the hazard first.
- What types of respiratory protection is needed? Once you have information about the hazard, you have to select the types of masks that will be appropriate for the type and level of contamination.
- Usage
- When do employees need to use the respirators? This should include both routine use situations, and emergency use (if applicable).
- How should the employees don (put on) and doff (remove) the respirators?
Consider how this will work with other protective equipment the worker may be wearing. - Facial hair requirements for respirator use.
- Equipment
- How and when will the employer provide respirators and related items to employees?
- How will respirators be stored, cleaned, and maintained (and/or replaced)?
- What are the inspection procedures for the respirator?
- If the respirator uses removable filters or cartridges, when should those be changed?
- If the respirator uses an air supply from a hose or tank, what procedures exist to ensure safe and clean air is provided?
- If full face masks are used, how will the employer provide prescription inserts for employees that wear glasses?
- Medical Evaluations
- What methods will be used for employee medical evaluations?
If you have a large company, you will probably want a written procedure for if/when an employee has medical restrictions on respirator use. A small company may want to handle this on a case-by-case basis. - Training
- What methods will be used to provide employee training?
Employees must be provided training on both the respiratory hazards they are exposed to at work, and on safe use of the respirator (including what it is and isn't effective against, how to care for and maintain the respirator, and how to use it correctly). - Fit Testing
- What methods will be used for fit testing the respirators?
Employees required to wear a tight-fitting respirator must be fit tested on the specific size, make, and model of mask they will be using at work. For half face masks, either a qualitative or quantitative fit test method may be used. Most full face mask usage will required quantitative fit testing.
Every workplace will have different needs, but these elements form the basics for a complaint respirator program. If you need additional help creating a written respirator program, or reviewing a program you have created, contact us.



