Respiratory Protection Standard Chapter 296-62 Part E
(A
Summary of Key Differences with OSHA's 1910.134)
Scope
Agricultural respiratory hazards and tuberculosis
respiratory hazards will continue to be covered by the revised Part E.
Public sector firefighters use of respirators will
continue to be covered as referenced in WAC 296-305.
Definitions
Kept some WISHA specific definitions (e.g., APF, Helmet).
Respirator Program
Kept SOP requirement for non-routine tasks since OSHA only
mentions SOPs for routine and emergency tasks. This helps make it clear that infrequent
tasks (i.e., cleaning out a bag filter system, etc.) are clearly addressed.
Cost responsibility for employer- or standard-required use
is clarified to include wages and travel expenses. This is consistent with OSHAs
enforcement policy.
Selection
Kept and updated APF table based on ANSI Z88.2-1992 as
indicated by employer survey results (April 1998). These values will be applied until OSHA
completes its rule making on this issue.
Kept requirement for an analysis of emergency and rescue
uses of respirator since it clarifies what criteria must be followed.
Medical Evaluation
Added verbiage that emphasizes a questionnaire-initiated
approach, making it clearer that exams are not a necessary first step in the process.
Included an overview of how a questionnaire-initiated
process works for clarification purposes.
Added verbiage emphasizing that employers cannot review an
employee's completed questionnaire.
Added allowance for portability of medical evaluations if
the current employer can show that the respirator, types of work and use parameters are
substantially similar to those of a previous employer. The current employer assumes any
follow-up responsibilities indicated by a previous medical evaluation. This is consistent
with OSHAs enforcement policy.
Excluded loose-fitting (e.g., ELSAs) and mouthpiece,
escape-only respirators from medical evaluations. This is consistent with OSHA enforcement
policy.
Fit-Testing
Added allowance for portability of fit-testing if the
employer is provided with written documentation of a current fit-test and all other
fit-testing requirements are considered (such as the QL-fit-test restriction mentioned
above, and other triggers for additional fit-tests). This is consistent with OSHAs
enforcement policy.
Use of Respirators
Clarified when a single standby is permitted in general IDLH
situations. The focus is on a well characterized IDLH where the employer can show that one
employee can handle all standby requirements for communication and rescue initiation. The
criteria selected are based on OSHAs rationale presented in the preamble to its
final rule (1910.134).
Kept allowance for employees to leave respirator use area if
severe discomfort or symptoms of illness are experienced.
Moved "2-in/2-out" requirement for interior
structural firefighting to the Fire Brigade Standard.
Maintenance and Care
Kept requirement to provide an adequate number of emergency
respirators for each work area.
ID of Filters, Cartridges
and Canisters
Kept old table for informational purposes at the request of
the advisory committee.
Training and Information
Kept requirement for supervisors and persons issuing
respirators to be trained.
Program Evaluation
Kept requirement for periodic supervisory monitoring of
respirator use.