The Possible Need for Respirator Protection

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Introduction

The subject of respirators is not a hot topic in the JCC world, but it is one that may need to be considered. The vast majority of JCC employees have no exposure to hazardous gases, vapors, dusts, or mists that require or even suggest the use of a respirator. Some employees may be benefited by the use of a particulate mask while doing certain temporary dusty tasks, but there is a significant difference between OSHA requirements with regard to particulate masks and respirators.

The few employees who do work with hazardous gases or vapors that may reach dangerous levels are mostly aquatic staff or maintenance people who work with aquatic chemicals. Some facility or grounds staff may apply pesticides – many of those chemicals require respirator or particulate mask protection. However, since such activity is generally not the task of employees it will not be included in this discussion. Others who are potentially exposed include childcare workers (or anyone, for that matter) who use a sodium hypochlorite based cleaner (i.e., common bleach), especially if it is used in a relatively confined space. For this latter group, unless the jurisdiction having authority over childcare mandates a bleach-based cleaner, the cleaner should be changed to a chlorine-free product because engineering controls (i.e., removal of the hazard) is preferable to using personal protective equipment (i.e., respirators).

The Chemicals

Liquid chlorinating products (sodium hypochlorite) in the strengths (10-12%) used for antimicrobial pool protection should not generally need respirators. The most dangerous exposure with this product is mist at the point of use, an exposure not present in pool chlorination. Individuals who work with or around this chemical should wear goggles (not just safety glasses). Goggle use is critical if the individual is wearing contact lenses – in fact, contact lens wearers would be wise to use regular glasses whenever they work around chemicals capable of producing dust, vapors, or mists. OSHA-approved eyewash stations should be in the immediate work areas and gloves and apron are highly recommended.

Those who use tablet or pellet forms of antimicrobial pesticides (calcium hypochlorite, lithium hypochlorite, or bromine compounds) would be wise to use a properly fitted respirator (full-face or half-face plus goggles) as a precautionary measure. Although the tablets half-face respirator themselves emit no vapors, they may be dusty and the product may produce vapors if it gets damp. Should moisture unintentionally be introduced into a storage container or should a malfunction or other event cause premature moistening of the tablets in a chlorinator’s hopper, then opening that container or removing the lid from that hopper could release a significant chlorine cloud. Though not a common occurrence, it has happened often enough that prudence highly suggests wearing a respirator every time a pellet or tablet chlorine storage container is opened and every time the lid is removed from a pellet or tablet chlorinator. Most chlorinators of this type require periodic cleaning of the grating upon which the tablets sit. This generally involves using muriatic (hydrochloric) acid and the process generates chlorine gas. Unless done in a completely open air situation (and preferably even then) a respirator should be used.

The use of granular products for pool shocking or other purposes should also not require the use of a respirator as long as they are stored in a sealed container in a dry location (including ambient atmosphere). However, if the area in which the product is stored is moist or has high humidity, the use of a properly fitted respirator is highly suggested whenever opening a container of granulated pool sterilizers. Because of the high potential for dust with granular product, goggles and a particulate mask should always be worn when handling or working with this type of product.

Users of gaseous chlorine are familiar with respirators. There is no doubt that respirators are needed, and thus that a respirator policy is necessary. While a respirator can be used for most typical activity, a self-contained breathing apparatus (SCBA) should be maintained for emergencies, especially if the tank or any of the equipment is in an enclosed space.

The Procedures

OSHA regulations require that employers with employees who are exposed to harmful levels of hazardous gases or vapors must implement respirator protocols and procedures applicable to the hazards encountered. Should an employer elect to provide respirators apart from OSHA requirements, that employer does have certain responsibilities, but a full respirator program is not required.

To determine whether respirator protocols are necessary, an examination of the Safety Data Sheets (SDS) of the chemicals used by the facility is necessary. Each of them will indicate whether or not respiratory protection may be needed, the circumstances that mandate protection, and what type(s) of respirator will provide adequate protection for the exposed employees. (For a summary of typical SDS requirements for common pool chemicals and a brief discussion of respirator protection, please see Fact Sheet: Antimicrobial Pesticides, Chemicals, and Respirators.)

If consultation with the SDSs reveals that a respirator program may be necessary, contacting the local OSHA office for a consultative visit can provide clarity. If necessary, the following work-site specific items need to be addressed:

  • medical evaluations for all employees required to use respirators
  • naming a suitably trained program administrator
  • procedures for selecting respirators used at the location
  • fit-testing procedures for tight-fitting respirators
  • procedures for proper respirator use during routine and reasonably foreseeable emergency situations
  • training of involved employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and maintenance of the respirators
  • procedures for cleaning, disinfecting, storing, inspecting, repairing, discarding, or otherwise maintaining respirators
  • procedures for regularly evaluating the program’s effectiveness

Summary

As can be seen, a respirator program is not a simple task, especially if the JCC does not have the expertise to evaluate all of the influencing factors. However, it is an important task if the exposure to employees exists. It is perhaps best addressed for most by consulting the regional OSHA office or by using local, qualified vendors who can assist in the selection and fitting of respirators as well as in establishing appropriate respirator-related procedures and protocols.

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