UVa Seal

Policy: Controlling Hazardous Air Contaminants and Respiratory Protection 


Date: 07/25/05 Policy ID: SEC-021 Status: Final

Policy Type: University
   
Contact Office: Environmental Health and Safety
   
Oversight Executive: Vice President for Research
   
Applies To:  Academic Division, the Medical Center and the College at Wise.
   
Table of Contents: 

Policy Statement
Departmental Responsibility
Procedures

   
Reason for Policy:  To protect faculty, staff and students from harmful air contaminants and other factors which may lead to illnesses or disabilities.
   
Policy Summary:  Appropriate controls shall be specified and used to control exposure to harmful air contaminants.
   
Definition of Terms in Statement: 

Engineering Controls: Processes that may include either (1) enclosure or confinement of a work process generating harmful air contaminants; (2) general dilution ventilation or local exhaust ventilation at the point of generation.

Harmful Air Contaminants: This includes, but is not limited to, dusts, fibers, smoke, sprays, aerosols (including biologically-derived), gases, fumes and vapors.

Industrial Hygiene: The science and the art of recognizing, evaluating and controlling environmental factors or stresses at the work place which may cause illness or disabilities among the workforce or community as a whole.

Recognition: Requires extensive knowledge of potential workplace exposures to hazardous materials, chemicals or agents.

Evaluation: Measuring and inspecting the workplace environment to describe potential exposures and make decisions regarding their seriousness.

Control: The application of procedures which isolate, substitute materials, or change processes to reduce or eliminate exposures.

   
Policy Statement: 

Departments will consult first with the EHS Industrial Hygienist or Respiratory Program Administrator before allowing an employee or student to use a respirator.  EHS will evaluate the work environment or process that may be generating harmful air contaminants and advise on appropriate controls to eliminate or mitigate exposures.  Controls to include but are not limited to engineering, administrative or process controls. When effective controls are not feasible, or while they are being instituted, respiratory protection may be required as determined by the EHS evaluation.
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Departmental Responsibility
Consultation with EHS is required if a department/laboratory has a work environment or performs work processes that can generate harmful air contaminants or could result in releases of contaminants to the atmosphere. Departments may not utilize respiratory protection for affected individuals prior to consultation.
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EHS will provide consultative services at no charge to the department/laboratory. There may, however, be charges applied to the requesting department/laboratory if environmental samples are collected and subsequently analyzed by a certified commercial laboratory. The fees will not exceed those charged by the commercial laboratory.

EHS administers the University’s Respiratory Protection Program (RPP) (refer to Procedure 14-4). The RPP includes all University faculty, staff and students who must wear respirators as determined by EHS due to the infeasibility of successful controls or containment.  The RPP also includes individuals who choose to wear respirators for additional comfort and/or protection in the performance of their job duties. Departments shall provide respirators for the faculty, staff or student member when such equipment is necessary as determined by EHS and coordinate initial medical clearance and annual medical evaluations for respirator users with UVa WorkMed. EHS in consultation with the department will determine:

  • The need or prudence of respiratory protection.
  • The proper respirator selection.
  • How to educate respirator users on the effects of exposure to  harmful air contaminant(s) and the safe use of a respirator.

There may be cases when personnel simply prefer to voluntarily wear respiratory protection for personal reasons, although it may not be required to provide protection from any known airborne exposure. The Occupational Safety & Health Administration (OSHA) permits the use of voluntary respiratory protection so long as the respirator use will not in itself create a hazard. Consultation with Environmental Health and Safety will ensure University Departments meet this requirement as well as assure voluntary respirator use is done in a safe manner. Accordingly, prior to voluntarily wearing a respirator, personnel must first contact Environmental Health & Safety to:

Questions concerning potential biological exposures can be directed to the Environmental Health and Safety Biosafety Officers. Questions concerning potential chemical, dust or mold exposures can be directed to the Environmental Health and Safety Industrial Hygienist or Respirator Program Manager.

Beards or other configurations of facial hair that comes into contact with the respirator face piece seal, will disqualify faculty, staff and students from wearing tight fitting respirators. Other options are available for bearded individuals if respiratory protection is a requirement.
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Procedures: 

The University of Virginia’s Office of Environmental Health and Safety provides Industrial Hygiene and Respiratory Protection services to all organizational levels of the Institution. These services are delivered in an attempt to minimize worker exposures to toxic or hazardous materials, as well as physical hazards. Employees whose day-to-day occupational activities (e.g., construction, renovations, research, etc.) may result in these exposures may arrange for consultative services by contacting Environmental Health and Safety at 982-4911.

Procedure 14-4, “Respiratory Protection"
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Related Information: 

Occupational Health & Safety Code of Federal Regulations:

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Policy Background: 
   
Major Category: Safety, Security and Environmental Quality
   
Category Cross Reference: 
   
   
Process: 
   
Next Scheduled Review: 07/25/11
   
Approved By, Date: Policy Review Committee, 07/25/05
   
Revision History: Updated 9/7/11, 8/26/08.
   
Supersedes (previous policy):   Combined: Industrial Hygiene XIV.L.1 & Respiratory Protection XIV.M.1.