There have been significant and important advancements in the field of respiratory protection in recent years, but are these advancements alone enough? Technology has improved, standards and protocols have evolved, but in reality, have organizations and the fire service really fully grasped the fundamental concepts of respiratory protection? This article, offers a broad look at the development and implementation of a respiratory protection program (RPP). It will also attempt to inform organizations and fire officials of applicable standards, procedures and the essential requirements of a solid RPP, based on the comprehensive Respiratory Protection Program of the Department of National Defence, one of the largest in Canada.
For most fire officials, respiratory protection is but one part of the myriad responsibilities addressed every day. Few organizations have resources dedicated exclusively to the health and well being of respirator users, including emergency responders or firefighters.
Other aspects of fire service management such as budgeting, human resources issues or operations often take priority. The reality, however, is that all organizations have a moral and legal responsibility regarding the health and safety of their personnel. A sound, holistic RPP is essential, regardless of the size of the organization.
In Canada, the Canadian Standards Association is a recognized national standards writing agency. CSA Z94.4 “Selection Use and Care of Respirators” and CSA Z180.1 “Compressed Breathing Air and Systems” are consensus standards that focus on respiratory protection. Balanced technical committees representing manufacturers, users, government and organized labour have developed these standards. These standards outline the minimum requirements of a program and form the basis for many RPPs in Canada today. Every program dealing with respiratory protection should be tailored to the needs of the individual organization and should be based on the applicable standards prescribed in legislation. The Canada Labour Code Part II and Canada Occupational Safety and Health regulations refer to these CSA standards as the benchmarks for minimum requirements when protecting personnel from the hazard of airborne hazardous substances or oxygen deficient atmospheres where these are present. It is important to know the provincial legal framework and how it interacts with these standards.
It should be stressed that a respiratory protection program is much more than the management of compressed breathing air quality or the cycling of Self Contained Breathing Apparatus (SCBA) cylinders. It ensures that all aspects of respiratory protection are considered. Let’s start at the beginning.
Part 1 – The science
Hazardous atmospheres (airborne contaminants and oxygen deficiency): Airborne contaminants include particulate matter in the form of discrete particles of solids or liquids, substances in a gas or vapour state, or a combination of gaseous and particulate matter. Particulate matter is measured by size, where generally particles less than 10 micrometers can penetrate into the respiratory system. The presence or concentration of gaseous contaminants is frequently expressed in parts per million and may enter the bloodstream via the respiratory system. Under normal circumstances, the natural cleansing action of the human body can cope with small amounts of these contaminants. But when the levels of contaminants exceed specific values or the oxygen concentration is deficient, respiratory protection is warranted.
Hazard assessment and respirator selection
Hazard assessments are the basis of the RPP. These allow you to better understand the hazards and their relative levels and they assist in determining the type of respiratory protection required. When dealing with hazardous atmospheres that are designated as Immediately Dangerous to Life or Health (IDLH), the most common respiratory protection device (RPD) for fire service personnel is an SCBA. Many instances require a lower level of protection if the atmosphere is not IDLH. To determine the appropriate type of protection, a program requires that qualified personnel perform a hazard assessment. These are professionals who will quantify the level of hazard and determine the appropriate type of respiratory protection required under the circumstances. This resource may be available through specialized consulting firms, private contractors or an organization’s health and safety professionals. These people are an invaluable resource.
Once the specific or expected hazards have been identified, along with the appropriate type of respiratory protection device, the product needs to be purchased and introduced into the organization. Too often, fire services purchase new equipment without considering the impact on the organization in terms of training, maintenance (according to the manufacturer’s recommendations), and end-of-life/replacement elements.
Has the equipment been evaluated to ensure it meets your organization’s requirements, or, has someone simply followed the recommendations of the provider?
One often hears the adage, “If it’s good enough for the city fire department, it’s good enough for us!” This approach is unacceptable. Larger organizations may have a more thorough product evaluation capability, but they evaluate products or tools based on their requirements, not those of others. Care must be taken to ensure that products selected and purchased meet individual organizational needs. Important resources should not be wasted on equipment that far exceeds the needs of the organization and personnel.
Fit testing and health surveillance
RPD users must demonstrate that they can be properly fitted with the correct size and style prior to even considering their use of the device. One cannot compromise on this issue. An improperly fitted RPD will not achieve the required level of protection and jeopardises not only its user, but also all those who depend on that user. Prior to fit testing any RPD user, it must be established that the user has no known medical condition preventing said user from wearing or using such a device.
This all-important facet of a program is too often overlooked, or even misunderstood. Various facial features and sizes can significantly affect fit. Established protection levels for RPDs must be confirmed prior to allowing employees to use RPDs in a hazardous atmosphere. A simple negative or positive pressure seal check by the user is not enough. Qualitative (QLFT) or Quantitative (QNFT) Fit Testing is a requirement in the CSA Z94.4 standard. Quantitative Fit Testing is considered by DND as the practice of choice and must be undertaken for all employees who will potentially wear a respirator. This includes the type of tight-fitting, filtering facepiece devices for particulates frequently worn by first responders during calls.
Quantitative fit tests require specialized equipment depending on the protocol adopted for testing. The equipment and necessary operator training to conduct testing can be purchased and implemented within an organization, or, this work can be contracted out to a qualified firm. As stated in the CSA Z94.4 standard, users must be fit tested at least every two years, when issued a new brand of RPD, or, when important changes to their facial features occur, such as visible weight change or scarring.
Once fit tested, the user must be trained on how to use his or her protective device as well as in its limitations. The program must contain a comprehensive training package meeting the manufacturer’s recommendations and tailored to the individual organization’s applications. Training instils confidence and understanding when using RPDs. This is crucial to any person who is expected to enter an environment containing airborne contaminants or is deficient in oxygen. Users must also understand maintenance and inspection requirements necessary to ensure that the equipment will provide the desired level of protection. They should also be encouraged to raise concerns or have the equipment checked when they suspect it is not performing properly for any reason.
The CSA Z180.1 standard contains the requirements for compressed breathing systems including air quality. The respiratory protection program must ensure that RPDs providing air to personnel working in hazardous atmospheres or in an IDLH environment conform to this standard. Breathing air produced by the organization or purchased from an outside supplier should meet the CSA Z180.1 standard. Failing to meet the air quality standard could also nullify the certification of the RPD. The program must contain a means of verifying air quality conformance from the source to recipient. Organizations that produce breathing air using compressed breathing air systems must send samples to an accredited laboratory for analysis every six months, or when major maintenance of the compressed breathing system is conducted (this does not include minor maintenance such as filter changes). It may be simpler or more effective to purchase the breathing air from a reputable supplier, however, the RPP must contain provisions for ensuring and monitoring air quality. Upon request, suppliers of breathing air should provide records of the analytical reports produced by the accredited laboratories.
Part 2 – The administration
The first part of this article outlined and discussed the key components of a holistic respiratory protection program. In this second part, we will delve into the administrative aspects with the goal of clearly outlining all elements of the program.
Program administration: As part of a larger organization, municipal fire departments have typically done a good job of administering an RPP for their own specific requirements. However, how does the RPP compare for employees in public works, ambulance services or even the police department? At the municipal level, amalgamating all aspects of the organization’s RPP, can have very positive effects. Although individual components of the RPP can be specific to one department, the program in itself can be managed at the municipal level covering all users of RPDs. It would be highly desirable to have one Respiratory Protection Program Administrator (RPPA) overseeing the RPP at the corporate level. Guidance or leadership from fire service personnel would likely be well received in establishing such a co-ordinated program. After all, the essence of an established uniform program is to enhance the health and well being of all municipal personnel, and to reduce potential harm. It is under this premise that the following information is offered for establishing a program.
Role of designated personnel
To ensure that all aspects of the RPP requirements meet accepted standards and to achieve an efficient and effective RPP, the organization must designate an individual to undertake the role of RPPA. Depending on the size of the organization or size of the program, this role may be the primary or secondary duty of the designated individual. In addition to being directly responsible for the program, the RPPA is responsible to ensure the implementation of each element of the program including monitoring fit testing, hazard assessments, health surveillance, training for all personnel who are required to wear RPDs, record keeping, etc., in accordance with the CSA Z94.4 standard. The RPPA must also oversee all aspects of the compressed breathing air produced or purchased by the organization in accordance with the CSA Z180.1 standard. This could also include a program for the provision of other personal protective equipment, clothing, equipment or materials. The RPPA can serve as advisor on these topics to the policy committee, the workplace health and safety committee or the health and safety representatives as required.
The missing link
Having identified the RPPA, assigned roles and responsibilities for each element of the RPP, performed the hazard assessments, purchased the appropriate RPDs, fit tested and trained personnel, validated air quality, and essentially created a respiratory protection program customized to the needs of the organization, one critical element remains missing. In order for an RPP to be truly effective, senior management in the organization must demonstrate their commitment to having an RPP. This is normally achieved through a written policy stating such a commitment and providing sufficient detail about the overall program objectives. The ultimate success or failure of a program rests on this written policy statement produced by the organization, which delegates the authority to implement this activity.
In any program, the importance of a communication strategy must be highlighted. An RPP is a living entity subject to ongoing changes that must be captured and reflected by modifying the program as required. Changes or concerns regarding exposure conditions and contaminants, equipment performance, workplace practices and procedures, evolving technology, as well as health and safety regulations that may have an impact on the program must somehow be communicated effectively. Relevant informal verbal communication at all levels within the organization, as well as more formal written communication, must be brought to the attention of the appropriate level of responsibility, noted and addressed. Sources of information include minutes of health and safety committee meetings, reports from supervisors and observations noted during inspections or audits.
The focal point for taking the appropriate action to initiate co-ordinated changes to the program is the RPPA. The RPPA must be abreast of all matters that can affect the program. Failure to inform the RPPA of these changes can be detrimental to the health and safety of the workers. Conversely, the RPPA must inform RPP personnel at various responsibility levels in the organization of relevant matters that could have an impact on their span of control. The sharing of information between organizations at the RPPA level can be extremely beneficial to all.
In brief, this article has attempted to convey the main elements of an effective respiratory protection program and its implementation. These are minimum standards and best practices in the area of respiratory protection. It can be a complex undertaking for those who do not already have a program in place; therefore a comprehensive approach to the creation of a program can reduce the burden on organizations or the fire officials. Respiratory protection is required not only for the firefighters, but all employees who may work in hazardous atmospheres. Respiratory protection is more than the requirement of the organizations to provide RPDs to the users; the overall program is a tool or even a mindset that increases the users’ effectiveness and allows them to do a better job knowing they have the suitable protection.
Pierre Voisine is the Canadian Forces Deputy Fire Marshal. He is also the Respiratory Protection Program manager for the Department of National Defence, as well as the resources manager for DND’s fire service. Voisine is a graduate of the Ontario Fire College, and has extensive fire and project/administration management related training, including the Fire Administration Degree program from the University of Cincinnati.
Working in hazardous atmospheres
Does your respiratory protection program have it?
Does your respiratory protection program have what it takes?
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