Respiratory Protection Program

CSULB Respiratory Protection Program Scope

The Respiratory Protection program at California State University, Long Beach (CSULB) defines how the university complies with the requirements set forth in the California Code of Regulations (CCR), Title 8, section 5144 and elsewhere regarding the use of respiratory protection by university employees. This program follows exactly the hierarchy of controls as detailed in regulation and by recognized industry practice. The order of those controls is as follows:

• Engineering Controls, where the university will seek to confine the process that produces the exposure to an employee in a device that captures the harmful products and completely isolates the employee from the hazard, and;
• Administrative Controls, where the university will seek to use the most benign materials possible so as to not require employees to wear respiratory protection;
• Finally, after both administrative or engineering controls have failed to reduce or eliminate the hazardous exposure, a respirator will be issued to the employee, while the university continues to seek a remedy with either new administrative or engineering controls

Definitions

The following definitions are important terms used in the CSULB Respiratory Protection Program , and by Cal/OSHA's respiratory protection standard, GISO, Title 8, section 5144.

Air-purifying respirator

a respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

Assigned protection factor (APF)

Atmosphere-supplying respirator

a respirator that supplies the respirator user with breathing air from a source independent of the ambient atmosphere, and includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units.

Canister or cartridge

a container with a filter, sorbent, or catalyst, or combination of these items, which removes specific contaminants from the air passed through the container.

Demand respirator

an atmosphere-supplying respirator that admits breathing air to the facepiece only when a negative pressure is created inside the facepiece by inhalation.

Emergency situation

any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant.

Employee exposure

exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection.

End-of-service-life indicator (ESLI)

a system that warns the respirator user of the approach of the end of adequate respiratory protection, for example, that the sorbent is approaching saturation or is no longer effective.

Escape-only respirator

a respirator intended to be used only for emergency exit.

Filter or air purifying element

a component used in respirators to remove solid or liquid aerosols from the inspired air.

Filtering facepiece (single use respirator)

a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium.

Fit factor

a quantitative estimate of the fit of a particular respirator to a specific individual, and typically estimates the ratio of the concentration of a substance in ambient air to its concentration inside the respirator when worn.

Fit test

the use of a protocol to qualitatively or quantitatively evaluate the fit of a respirator on an individual. (See also Qualitative fit test QLFT and Quantitative fit test QNFT.)

Helmet

a rigid respiratory inlet covering that also provides head protection against impact and penetration.

P100

formerly known as High efficiency particulate air (HEPA) filter, a filter that is at least 99.97% efficient in removing monodispersed particles of 0.3 micrometers in diameter.

Hood

a respiratory inlet covering that completely covers the head and neck and may also cover portions of the shoulders and torso.

Immediately dangerous to life or health (IDLH)

an atmosphere that poses an immediate threat to life, would cause irreversible adverse health effects, or would impair an individual's ability to escape from a dangerous atmosphere.

Interior structural firefighting

the physical activity of fire suppression, rescue or both, inside of buildings or enclosed structures which are involved in a fire situation beyond the incipient stage.

Loose-fitting facepiece

a respiratory inlet covering that is designed to form a partial seal with the face.

Maximum use concentration (MUC)

Medical Evaluation

Using a respirator may place a physiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. Accordingly, Cal/OSHA specifies the minimum requirements for medical evaluation that employers must implement to determine the employee's ability to use a respirator. Medical examination components vary according to the type of respirator required.

Negative pressure respirator (tight fitting)

a respirator in which the air pressure inside the facepiece is negative during inhalation with respect to the ambient air pressure outside the respirator.

Oxygen deficient atmosphere

an atmosphere with an oxygen content below 19.5% by volume.

Physician or other licensed health care professional (PLHCP)

an individual whose legally permitted scope or practice (i.e., license, registration, or certification) allows him or her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required by subsection (e) of 5144.

Positive pressure respirator

a respirator in which the pressure inside the respiratory inlet covering exceeds the ambient air pressure outside the respirator.

Powered air-purifying respirator (PAPR)

an air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.

Pressure demand respirator

a positive pressure atmosphere-supplying respirator that admits breathing air to the facepiece when the positive pressure is reduced inside the facepiece by inhalation.

Qualitative fit test (QLFT)

a pass/fail fit test to assess the adequacy of respirator fit that relies on the individual's response to the test agent.

Quantitative fit test (QNFT)

an assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator.

Respiratory inlet covering

that portion of a respirator that forms the protective barrier between the user's respiratory tract and an air-purifying device or breathing air source, or both. It may be a facepiece, helmet, hood, suit, or a mouthpiece respirator with nose clamp.

Self-contained breathing apparatus (SCBA)

an atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user.

Service life

the period of time that a respirator, filter or sorbent, or other respiratory equipment provides adequate protection to the wearer.

Supplied-air respirator (SAR) or airline respirator

an atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user.

Tight-fitting facepiece

a respiratory inlet covering that forms a complete seal with the face.

User seal check

an action conducted by the respirator user to determine if the respirator is properly seated to the face.

I. Responsibilities

The CSULB Respiratory Protection Program makes all possible arrangements to ensure that engineering and administrative controls are implemented to minimize the use of respiratory protective equipment and exposure to airborne contaminants. When those options are exhausted, or in the case of emergencies, respiratory protection will be used by University employees. The use of that protection is directed and governed by this plan.

Safety and Risk Management (SRMIS) shall:

• Designate a qualified program administrator to conduct the program and required evaluations of program effectiveness.
• Develop, implement and monitor the Respiratory Protection Plan in compliance with California Code of Regulations Title 8, Section 5144.
• Provide guidance and assist departments in complying with program requirements on a consulting basis.
• Review and approve all University purchases of respiratory protective equipment.
• Provide applicable training on the need for respiratory protection, criteria for selecting respirators and respirator fitting/use/maintenance.
• Develop and implement a campus wide medical monitoring program for respirator users.
• Conduct at least annual audits for respiratory equipment usage, maintenance, and storage.
• Maintain records indicating the brand and type of respirator used by each employee, the date the employee was fit tested, and the date the employee received respirator use training.
• Conduct monthly inspections of all Self Contained Breathing Apparatus units.
• Conduct periodic training sessions concerning respirator program elements.
• Conduct at least an annual review of this program.
• Assist departments in selecting appropriate engineering and/or administrative controls prior to determining the applicable respiratory protective equipment.

Departments shall:

• Determine what specific applications require the use of respiratory equipment.
• Provide proper respiratory equipment to meet the needs of each specific application.
• Ensure that appropriate employees are provided with adequate training and instructions on all equipment and that all personnel are completely knowledgeable of the respirator usage requirements for the areas in which they work.
• Ensure that the personnel comply with all elements of the University Respiratory Protection Program, including respirator inspection and maintenance.
• Periodically spot-check field use by staff within their respective department.

Employees shall:

• Use common sense and good judgment at all times.
• Understand the hazards that exist or may be created by the work task(s) and/or the work environment to which they are assigned.
• Comply with all procedures, whether written or oral, while performing assigned duties.
• Inform the supervisor if a procedure or process seems unsafe.
• Utilize respiratory protective equipment in accordance with manufacturer requirements and training provided by the University.
• Inform the supervisor of any personal health problems that could be aggravated by the use of respiratory protective equipment.
• Guard against damage and ensure that respirators are not disassembled, modified, or otherwise altered in any way other than by the changing of the respirator cartridges/ filters and applicable respirator parts (e.g., valve covers).
• Report any observed or suspected malfunctions of the respirator equipment to the supervisor.
• Use only types of respiratory protection equipment that have been approved and training has been provided for.
• Conduct positive and negative pressure fit tests prior to each respirator use.
• Ensure that the issued respirator is inspected, cleaned, disinfected, repaired, and stored in accordance with manufacture requirements and University training.

II. Medical Monitoring

A complete medical monitoring system is in place for all University employees whose position requires use of a respirator.

The medical monitoring program:

• Identifies the employees that may require periodic medical monitoring because of their routine assignments.
  • Employees should not be assigned to tasks requiring the use of respirators unless it has been determined that they are physically able to perform the work while using the respiratory equipment. These assessments and /or examinations will be conducted by the Physician or other Licensed Health Care Provider (PLHCP) charged with this duty.
  • Complies with federal and state programs designed to use administrative and engineering controls to minimize exposures.
  • Failure or refusal to comply with or to submit to a confidential medical evaluation as required by regulation and University policy shall constitute a failure or refusal to perform a normal and reasonable duty of the employee's assigned position.
  • CSULB shall provide a confidential medical evaluation to determine the employee's ability to use a respirator. This shall be completed before the employee is fit tested or required to use the respirator. CSULB may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.
  • The cost of the program and medical evaluation is assumed by the University.
• Administration of the medical questionnaire and examinations shall be implemented as follows:
  • The medical questionnaire and examinations shall be administered confidentially during the employee's normal working hours or at a time and place convenient to the employee.
  • The medical questionnaire shall be administered in a manner that ensures that the employee understands its content.
  • A copy of the questionnaire shall be provided by CSULB to the employee, to be completed and sent directly to the PLHCP (Address and cover letter are provided with each questionnaire).
• Medical evaluation procedures are as follows:
  • CSULB shall identify a PLHCP to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.
  • CSULB shall provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP.
  • The medical evaluation shall obtain the information requested by the questionnaire in accordance with the provisions of CCR Title 8 Section 5144, Appendix C. (Attached and highlighted) need?
  • CSULB will ensure that a follow-up medical examination is provided for an employee who gives a positive response to any question among questions 1 through 8 in Section 2, Part A of Appendix C (Highlighted gray section of the form) or whose initial medical examination demonstrates the need for a follow-up medical examination at no cost to the employee. This process will be initiated by the PLHCP after the questionnaire has been reviewed.
  • The follow-up medical examination shall include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.
  • Results of the questionnaire and any follow-up examinations will be confidential between the PLHCP and the employee.
• CSULB will provide the PLHCP with the following information as part of the evaluation related to an employee's ability to use a respirator:
  • The type and weight of the respirator to be used by the employee;
  • The duration and frequency of respirator use (including use for rescue and escape);
  • The expected physical work effort;
  • Additional protective clothing and equipment to be worn; and
  • Temperature and humidity extremes that may be encountered.
  • Any supplemental information provided previously to the PLHCP regarding an employee need not be provided for a subsequent medical evaluation if the information and the PLHCP remain the same. Additionally, a copy of the University's current Respiratory Protection Program will be provided to the PLHCP.

  NOTE: When the employer replaces a PLHCP, the employer must ensure that the new PLHCP obtains this information, either by providing the documents directly to the PLHCP or having the documents transferred from the former PLHCP to the new PLHCP. Also, Cal/OSHA does not expect employers to have employees medically reevaluated solely because a new PLHCP has been selected.

• CSULB will receive the following medical determination provided directly from the PLHCP:
  • A written opinion regarding the employee's ability to use the respirator from the. The written opinion shall provide only the following information:
  • Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;
  • The need, if any, for follow-up medical evaluations; and
  • A statement that the PLHCP has provided the employee with a copy of the PLHCP's written recommendation.

  NOTE: If the respirator is a negative pressure respirator and the PLHCP finds a medical condition that may place the employee's health at increased risk if the respirator is used, the employer shall provide a (Powered Air Purifying Respirator (PAPR) if the PLHCP's medical evaluation finds that the employee can use such a respirator. If a subsequent medical evaluation finds that the employee is medically able to use a negative pressure respirator, then the employer is no longer required to provide a PAPR.

• Medical Re-Evaluation
  • If a re-evaluation is deemed necessary by the PLHCP, that evaluation will be provided for by the employer at no charge to the employee.
  • Each CSULB employee covered by this program, shall receive an annual medical re-evaluation to ascertain their ability to wear a respirator. The examination will be completed at no charge to the employee and it will be performed during normal business hours or at the convenience of the employee.
• Biological Monitoring:
  • Biological monitoring in the form of blood, tissue and/ or urinary analysis will be conducted as determined by the PLHCP.

  Note: Complete medical testing parameters, including medical evaluation of cardiac status, pulmonary status, physical ability (bending at waist, bending at knees, etc.), and any laboratory tests either required by regulation or recommended by the PLHCP can be found in the University Medical Monitoring Program.

III. Employee Training

SRMIS will train employees to identify hazards and work areas that may require the use of respiratory protection and how to use respiratory protection to mitigate any potential exposure.

Education and training will consist of:

• Procedures for use of job specific respiratory equipment provided by the University.
• Descriptions for the need of respiratory protection.
• The proper use of respirators, including normal use and use during foreseeable and unforeseen emergencies.
• The limitations of respirators.
• The care and maintenance of the applicable respirator(s).
• The conditions under which employees may use respirators when none are required by regulation, and when they may use their own respiratory equipment.
• When training is required as detailed in CCR, T8, 5144.
• Where, when and who conducts respirator fit testing as required by CCR, T8, 5144.

IV. Respirator Selection, Approval and Procurement

SRMIS will assist all departments in determining and purchasing the appropriate respiratory protective equipment. The following procedures shall apply:

• Proper selection of respirators shall be made by each department in consultation with SRMIS.
• Only respirators certified by NIOSH shall be used to comply with the requirements of this program.
• Only parts approved by the manufacturer for the specific respirator system shall be used for replacement.
• Departments are responsible for insuring that an adequate stock of respirators, filters and/or cartridges is maintained.
• All University departments seeking to purchase respirators for employee use shall complete a departmental requisition and forward it to the University Purchasing office. Purchasing will consult with SRMIS regarding approval. If SRMIS has not been previously consulted regarding the department requisition, purchase approval will be delayed until SRMIS can complete a determination that administrative or engineering control options have been explored and respiratory protective equipment is required.

V. Non-mandated Respirator Use

An employer may provide respirators at the request of employees or permit the employees to use their own respirators, if the employer determines that such respirator use will not in itself create a hazard. If the University determines that any voluntary respirator use is permissible, it shall provide the respirator users with the information contained in Appendix D of CCR; T8 5144 of this highlighted section below ("Information for Employees Using Respirators When Not Required Under the Standard.").

VI.  Operating Procedures

The operating instructions for each type of respirator and information on the limits of each must be followed carefully to gain the maximum benefit and protection.

• Filtering Facepiece (aka dust mask or single use disposable respirator: negative pressure)

  There are various types of filtering facepieces including disposable dust masks that have been approved for exposures to low concentrations of certain dusts.

  There are limitations on filtering facepieces and they cannot be used in oxygen deficient atmospheres. Nor can they be worn for protection in toxic environments.

  Donning Instructions:

  • Ensure that the skin around the sealing area of the mask is clean and for males, clean shaven.
  • Select a respirator of the appropriate size for the face.
  • Place the respirator against the face, with the straps on the outside of the mask
  • With one hand, expand the upper strap and stretch it over the crown of the head, placing it so the strap holds the mask from the back of the head.
  • With one hand, expand the lower strap and stretch it to a position of comfort below the first strap position (this is usually around the base of the neck).
  • Both straps must be in place for the mask to provide the designed protection.
  • Ensure that, if equipped, the adjustable nose clip is pinched so that a tight seal is achieved.
  • Perform a user seal check to ensure proper fit. If the respirator fails the seal check, discard it and select another type, and complete the above steps in order.
  • Wear the respirator for one full 8 hour shift. Do not reuse the respirator if the need extends beyond one shift.
  • If breathing through the respirator becomes difficult, or if the respirator becomes contaminated, or if the respirator fails in any way, exit the area of use, discard the non-functioning respirator, and inform your supervisor regarding the incident.
• Tight Fitting Respirators (Negative Pressure)

  Employees using tight fitting respirators will perform the following checks prior to completing tasks requiring the use of tight fitting respirators.

  • Fit Check
    • Negative Pressure Fit Check: the employee closes off the respirator inlet and inhales. A vacuum and partial inward collapse of the mask should result. If a vacuum can not be maintained for at least ten seconds, readjust the face piece and try again.
    • Positive Pressure Fit Check: the employee closes off the exhalation valve and breathes out gently. Air should escape through any gaps in the seal. If a slight positive pressure cannot be maintained with out escape of the air for at least ten seconds, readjust the face piece and try again.
• Air Purifying Half - Face Respirators (negative pressure)
  • Half - face respirators can be used with a High Efficiency Particulate Air (HEPA) filters. Other cartridges are available that protect against organic and other chemical contaminants.
  • Since this type of respirator does not supply air, it cannot be used in oxygen deficient atmospheres, Immediately Dangerous to Life or Health (IDLH) atmospheres or in confined spaces. It can only be used for contaminants listed on the canister. The employee must leave an area when they detect a taste or smell inside the mask or when breathing resistance increases. The procedures to don the respirator are:
    • Ensure that the skin around the sealing area of the mask is clean and for males, clean shaven.
    • Hold the mask so the narrow nose clip points upward.
    • Grasp both lower mask straps and hook them behind the neck.
    • Grasp both top straps and hook them behind the head and above the ears for proper fit.
    • Adjust the straps so the fit is snug but comfortable
    • Check for leaks with a fit check, positive and negative.
  • Change the filters or cartridges on the half mask respirator when the ESLI (end of service life indicator) on the cartridge changes. If there is no ESLI, change the filter/cartridge after each completed task requiring a respirator, or every 8 hours, or whenever the employee tastes or smells the contaminant inside the mask.
• Air Purifying Full - face respirators (negative pressure)
  • Like half –face respirators, these respirators do not supply air and cannot be used in oxygen deficient atmospheres, IDLH atmospheres or confined spaces. The employee must leave an area in which they detect a tast or smell inside the mask or when breathing resistance increases.
  • Full –face respirators provide more protection than half – face respirators because their shape allows a better mask to face seal. They also protect the eyes from irritating vapors/dusts and physical impacts.
  • Full - face respirators also come with selective types of filters and canisters that are effective against a singular or general category of contaminants. Full – face respirators have the similar limitations to half – face respirators. Additionally, standard eyeglasses interfere with the mask to face seal and therefore manufacturer-specific spectical kits must be provided for employees requiring corrective eyewear to use such a respirator. This must communicated to the employee's supervisor prior to use. SRMIS may assist the supervisor in this regard.
  • To don a full – face respirator:
    • Loosen all straps, pull the harness over the head, and place the chin in the chin cup.
    • Pull the head harness will down on the back of the head.
    • Tighten the harness gently, starting with the bottom straps and then the middle straps and last the top straps.
    • Check the fit by completing a positive/negative fit check:
    • Positive fit check: close off the inhalation grids on the front of the filter(s)/canister(s) and gently inhaling. The mask should slightly collapse in toward the user. The employee should hold their breath for a few seconds to maintain a collapsed mask during this time. If the mask dose not collapse inward, remove, readjust, and re-position the mask on the face and retest.
    • Negative fit check: close off the exhalation port on the mask and exhale gently. The mask should inflate slightly but evenly in all directions. If the mask does not inflate equally, remove, readjust, and reposition the mask and retest.
  • Change the filters or cartridges on the half mask respirator when the ESLI (end of service life indicator) on the cartridge changes. If there is no ESLI, change the filter/cartridge after each completed task requiring a respirator, or every 8 hours, or whenever the employee tastes or smells the contaminant inside the mask.

Supplied Air Respirators

Supplied air respirators are defined as respirators that provide the atmosphere to the user. The two types of supplied respirator systems are either a self-contained breathing apparatus (air source carried by the user) or an air line respirator (air source supplied to the user by an air line).

• Self-Contained Breathing Apparatus (SCBA)
  • SCBA units provide the user with a pure supply of grade "D" breathing air regardless of external conditions. They must be used in atmospheres unsuitable for air purifying respirators. This includes IDLH atmospheres, confined spaces where positive ventilation cannot remove or reduce the contaminant, and emergencies where airborne hazards are known to exist but cannot be quantified.
  • The air supply in a SCBA is usually 30 or 60 minutes depending on the bottle capacity. Heavy exertion and stress will significantly reduce this amount of time. An alarm bell sounds when five minutes of oxygen air remaining in the bottle and the wearer must leave the area immediately. If SCBA equipment must be used for entry, assessment, or emergency mitigation, two persons shall be equipped with SCBA units, and the appropriate level of protective clothing. Two persons will be on standby outside the work area to assist or recover the two entry personnel.
• Specialized Respiratory Protective Equipment (Type C Supplied Air Respirators)
  • Use of a pressure demand, Type C airline system may be permitted in an IDLH atmosphere under certain circumstances.

All supplied air respirator use requires written approval by the Respiratory Program Administrator prior to purchase (See Appendix C).

VII. Maintenance and Care

Degradation of the effectiveness and possible contamination of respirators can occur if proper care and maintenance are neglected.

Inspection

• Examine the conditions of the mask, straps, valves (inhalation and exhalation), and filter elements before and after each use and during cleaning.
• Examine the condition of the air hose, hose clamps and gaskets before and after each use and document the findings.
• Examine the face piece, closely evaluate the condition of the rubber and/or the condition of the clear lens (if a full face or SCBA mask).
• Inspect for cleanliness, document findings.
• Inspect the face piece and respirator cartridges for a NIOSH designation.
• Remove any equipment from service until it is repaired and certified for use.

Cleaning and storing

• After removing the filter and or straps, immerse the respirator in a mild bleach solution or immerse the respirator in a sanitary solution recommended by the manufacturer for at least two minutes.
• After washing or immersing the respirator, rinse it thoroughly in clean water to prevent dermatitis from residue on the mask.
• Allow the mask to air dry.

Storage

• Respirators can be permanently damaged if they are not stored properly. After use, clean, sanitize, and store respirators in re-sealable plastic bags.
• Protect respirators from sunlight, dust, chemicals, latent moisture and extreme temperatures.
• Do not store the respirator in a manner that forces it out of it's natural shape. Stuffing a respirator into a space or container too small for the mask will distort the mask, and will effect the fit of the unit to the wearer.

Repair

• Report all mal-functioning respirators to your supervisor and SRMIS.
• Do not attempt to repair a respirator if you have not been trained to do so.
• If repair is required, use only replacement parts from the same manufactured brand and type of equipment.
• Repair parts for university respiratory equipment are maintained by SRMIS.
• Repair of SCBA equipment should only be performed by the manufacturer.

VIII. Emergency Use of Respirators

An emergency as defined in Cal – OSHA is "an unforeseen combination of circumstances that calls for immediate action." An "Emergency situation means any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that may or does result in an uncontrolled significant release of an airborne contaminant."

Emergency Situations

Respiratory hazards often occur during emergencies when police or other emergency service personnel need immediate entry into a fire or accident scene. Other types of breathing hazards may occur when personnel are exposed to hazardous substances while trapped by an accident or escaping from the scene of a fire or accident, or when they are exposed to hazardous material spills. An unforeseen chemical reaction may also result in an over exposure to hazardous substances.

Acceptable Types of Equipment During Emergencies

Each respiratory device has a limited ability to protect health. During emergency entry, when there is usually neither time nor opportunity to evaluate the degree of exposure, only SCBA operating in the pressure demand mode should be used. SCBA are approved for use in IDLH atmospheres. After the type and degree of breathing hazards are evaluated, other respiratory equipment may be recommended.

Reports

Following any incident where emergency respirator protective equipment has been used, SRMIS shall be notified in writing, as soon as possible.

IX. Recordkeeping

• Records of respirator training and fit testing are maintained by SRMIS.
• Monthly checks of Emergency Use Respirators will be conducted by the respiratory program administrator. These records will be kept for three years.
• Monthly inspections of university maintained self contained breathing apparatus, reserve air bottles, including hydrostatic test requirements, shall be completed by SRMIS. Records of these inspections shall be kept for three years.

X Program Evaluation

The effectiveness of the Respiratory Protection Program will be evaluated annually by comprehensive examination of employees in the program.

A 15 question review of program elements and operational requirements will be developed from a pool of appropriate questions. (Appendix "A" )

The examination will be administered during the annual fit test period for each employee.

The examination will be customized to conform to each specific trade, or user profile.

There will be no passing score, but refresher training will be required for those employees scoring below 70%.(10.5 questions).

Examinations will be kept on file for three years.