Written Program

A written respiratory protection program* is a core component of ensuring safety in your workplace. Not only is it required by the Occupational Safety and Health Administration (OSHA), it’s valuable to employers because:
 

• OSHA compliance officers use it to confirm that all parts of your program are up to par.
• Supervisors and workers can refer to the policies and procedures contained in it, so they know their responsibilities.
• It’s a single resource for keeping records of past training and testing so you know what needs updating and when.
• Insurance adjusters may view it when investigating claims.

So as an employer, how do you put together a written respiratory protection program and keep it current?

First, describe the general policies the workplace follows to comply with OSHA regulations, including everyone’s responsibilities, from management to employees. Then provide the specific procedures for the various parts of the safety program, including:
 

• Exposure assessment. The methods used to determine what hazards are present and if the levels are unacceptable, i.e. require respiratory protection.
• Respirator selection. The information used to select respirators.
• Medical evaluation. Copies of the evaluation and questionnaires used.
• Fit testing. A description of the procedures used, as well as records of fit tests performed.
• Respirator training. The documentation used when training new employees and performing annual training for the entire workforce.
• Respirator maintenance. Detailed procedures for inspecting and cleaning respirators, and the schedule used for cartridge changes.
• Program evaluation. The criteria used to audit the program at least annually, and a summary of findings.

Every time an aspect of the program is implemented or updated, keep a record of each test and assessment performed, and copies of the procedures and information used to determine what was required.

Review the entire written program at least once a year to make sure everything is up to date, and add a record of the review.

*Although it’s called a “written” program, electronic files are acceptable to OSHA. So you can scan documents and save the program electronically, as long as those who may need to see it can access it on request.