Sonoma County Agricultural Commissioner’s Office
Presents
New Respiratory Protection Regulation
Title 3 CCR Section 6739
for Employee Pesticide Handlers
By
By Alex
AlexMcVicker
McVicker
Agricultural
AgriculturalBiologist
Biologist
Scope
This regulation applies to persons required (either
by label, permit conditions, regulatory requirements
or employer) to wear respiratory protection.
This includes, but is not limited to, mixer/loaders,
applicators, field workers, fumigators, supervisors,
foremen, and those whose work tasks place them in
a pesticide treated environment.
More than likely, this means you.
Definitions:
Filter
A component used in respirators to
remove solid or liquid aerosols from the
inspired air.
Definitions:
Canister or Cartridge
A container with a filter, sorbent, or catalyst,
or combination of these items
Definitions:
Category
Negative Pressure Respirator
Negative pressure
created during
inhalation
Definitions:
Air
-Purifying Respirator (APR
Air-Purifying
(APR))
A respirator with an
air
-purifying filter,
air-purifying
cartridge, or canister
Definitions:
Filtering Facepiece
A particulate respirator with a filter as an
integral part of the facepiece or with the
entire facepiece composed of the filtering
material
Definitions:
Category
Positive Pressure Respirator
A respirator in
which the pressure
inside the
respiratory inlet
covering exceeds
the ambient air
pressure outside.
Definitions:
Powered Air
-Purifying Respirator (PAPR)
Air-Purifying
An air
-purifying respirator that uses a
air-purifying
blower to force the ambient air through air
air-purifying elements to the inlet covering.
Definitions:
Category
Atmosphere
-Supplying Respirator
Atmosphere-Supplying
ƒ Includes supplied
-air respirators
supplied-air
((SARs)
SARs) and self
-contained breathing
self-contained
apparatus ((SCBA)
SCBA)
Definitions:
Supplied Air Respirator (SAR)
An atmosphere-supplying respirator for which
the source of breathing air is not designed to be
carried by the user.
Air compressor to provide supplied air
for example.
Definitions:
Self-Contained Breathing Apparatus
An atmosphere-supplying
respirator
Definitions:
Escape
-Only Respirator
Escape-Only
A respirator intended to be used only
for emergency exit.
Title 33 CCR,
CCR, Section
Section 6739:
6739:
Title
Respiratory Protection
Protection
Respiratory
Supercedes Section
Section 6738
6738 (h)
(h)
Supercedes
General Requirements
6739 (a)
Respiratory Protection Program
ƒ Develop a written program when
respirators are necessary or required
by the employer
ƒ Update program as necessary to
reflect changes in workplace
conditions that affect respirator use
conditions
Continued
General Requirements
6739 (a)
Respiratory Protection Program
ƒ Designate a Program Administrator
who is qualified by appropriate training
or experience to oversee the program
and conduct program evaluations
Continued
General Requirements
6739 (a)
Respiratory Protection Program
So who is qualified to be a Program Administrator?
– Read and understand ““American
American National Standard for
Respiratory Protection
” (ANZI Z88.2)
Protection”
or ““Small
Small Entity Compliance Guide for the Revised
Respiratory Protection Standard
”
Standard”
OR
– Take classes about developing a respiratory program
from a college or manufacturing authorized
representative
OR
– Become a certified industrial hygienist
Voluntary Respirator Provision
6739 (b)
ƒ Employer may provide respirators at
worker
’s request or permit workers
worker’s
to use their own respirators
ƒ If voluntary use is permissible,
employer must provide users with
the Voluntary Respirator Provision
Information
Continued
Voluntary Respirator Provision
6739 (b)
ƒ If respirators are employer
employer-supplied, employer must do the
elements of a written program to
make sure that the employee is
medically able to use the respirator
Continued
Voluntary Respirator Provision
6739 (b)
EXCEPTIONS:
ƒ Employers are not required to
include in a written program
employees whose only use of
respirators involves voluntary use
of filtering facepieces (dust mask)
ƒ The employee provides their own
respirator
Selection of Respirators
6739 (c)
Respirators must be selected based
on the specific hazards encountered in
the workplace
Selection of Respirators
6739 (c)
ƒ Select a NIOSH
-Approved
NIOSH-Approved
Respirator
ƒ Select respirators from a
sufficient number of models and
sizes
Continued
Definitions:
Physician or Licensed Health Care
Professional ((PLHCP)
PLHCP)
An individual whose legally
permitted scope of practice (i.e.,
license, registration, or
certification) allows him/her to
independently provide, or be
delegated the responsibility to
provide, some or all of the health
care services required by
paragraph (d), Medical
evaluation.
Medical Evaluation
6739 (d)
ƒ Employer must provide a medical
evaluation to see if a worker is able to
safely use a respirator
ƒ Employer must identify a PLHCP to
perform medical evaluations using a
medical questionnaire OR an initial
medical examination that obtains the
same information
Continued
Medical Evaluation
6739 (d)
ƒ Evaluation form must be filled out
confidentially during worker
’s
worker’s
normal work hours or at a time and
place convenient to the employee
Continued
Medical Evaluation
6739 (d)
Employer must provide PLHCP certain information:
Type/Weight of respirator
Duration/Frequency of use
Expected physical effort
Temperature/Humidity extremes
Copy of Respiratory Protection Program
Copy of Title 3, Section 6739
Continued
Medical Evaluation
6739 (d)
ƒ After review of the medical
evaluation and/or physical
examination of the worker, PLHCP
shall provide employer with a
written recommendation, subsection
(s)
Medical Evaluation
6739 (d)
ƒ Annual review of medical status IS NOT
REQUIRED
ƒ However
However,, employer must provide additional
medical evaluations if:
– Worker reports medical symptoms about their ability
to use a respirator
– PLHCP, supervisor, or program administrator informs
that a worker needs to be reevaluated
– Change occurs in workplace conditions that may be a
physiological burden on a worker
Fit Testing
6739 (e)
Before a worker uses any respirator with a
negative or positive pressure tight-fitting
facepiece, the worker must be fit tested
Continued
Definitions:
Qualitative Fit Test (QLFT)
Depends on ability to detect testing
agent and may be falsified (except in
case of irritant smoke)
Definitions:
Quantitative Fit Test (QNTF)
An assessment of the adequacy of
respirator fit by numerically measuring the
amount of leakage into the respirator
Fit Testing
6739 (e)
ƒ Workers using tight
-fitting facepiece
tight-fitting
respirators must pass an appropriate
qualitative fit test (QLFT)
or
quantitative fit test (QNFT)
Continued
Fit Testing
6739 (e)
ƒ The fit test must be administered
using a Cal/OSHA
-accepted QLFT
Cal/OSHA-accepted
or QNFT protocol
ƒ Title 8 of the California Code
of Regulations , Section 5144,
Appendix A
Continued
Fit Testing
6739 (e)
A little bit of Good News:
–
The QLFT is acceptable for ALL
–The
negative
-pressure tight
-fitting HALF
negative-pressure
tight-fitting
or FULL facepiece respirators used
for pesticide applications
Fit Testing
6739 (e)
ƒ Must conduct an additional fit test
whenever the worker reports, or the
employer or PLHCP makes visual
observations of, changes in the
worker
’s physical condition that could
worker’s
affect respirator fit
Facepiece Seal Protection
6739 (f)
A Couple Common Sense Items:
ƒ Respirators with tight
-fitting facepieces
tight-fitting
must not be worn by workers who have
facial hair or any condition that interferes
with the face
-to-facepiece seal or valve
face-to-facepiece
function
ƒ Corrective glasses or goggles or other PPE
must be worn in a manner that does not
interfere with the face
-to-facepiece seal
face-to-facepiece
Continued
Facepiece Seal Protection
6739 (f)
A Required Good Habit:
ƒ Workers wearing tight
-fitting respirators
tight-fitting
must perform a user seal check each
time they put on the respirator using the
procedures in Title 8, Section 5144,
Appendix B
-1 or equally effective
B-1
manufacturer
’s procedures
manufacturer’s
Cleaning and Disinfecting
6739 (h)
ƒ Provide each user with a respirator that is
clean, sanitary and in good working order
ƒ Clean and disinfect at the following intervals:
– as necessary when issued for exclusive use
(cleaning only)
– before being worn by different individuals (clean
and disinfect)
– after each use for emergency respirators, fit
testing and training (clean and disinfect)
Emergency Respirators
6739 (i)
ƒ Must be immediately accessible
ƒ Clearly marked as containing emergency
respirator
ƒ Stored according to manufacturer
’s
manufacturer’s
recommendation
ƒ Stored such that it is safely accessible
during emergency conditions
Inspection and Repair
6739 (j)
ƒ Ensure that all respirators are
inspected before each use
ƒ Defective or failed respirators shall be
taken out of service until repaired or
discarded
ƒ Repair of respiratory equipment shall
be done by persons trained to do so
using NIOSH
-approved parts.
NIOSH-approved
Identification of Filter, Cartridges and Canisters
¾
All filters, cartridges and canisters
¾All
used in the workplace must be labeled
and color coded with the NIOSH
approval label
¾
The label must not be removed and
¾The
must remain legible
6739 (l)
Training and Information
6739 (m)
Employers must provide training to
workers who are required to use
respirators.
Training must be understandable to
workers.
Continued
Training and Information
6739 (m)
ƒ Employees trained to use respirators must be
able to demonstrate knowledge of at least:
– why the respirator is necessary and how improper fit
can compromise protection
– limitations and capabilities of the respirator
– recognition of medical signs that may prevent
effective us
– how to inspect, wear, and
check the seals
– effective use in
emergency situations
– maintenance and storage
Continued
Training and Information
6739 (m)
ƒ Training must be provided prior to use
ƒ Retraining is required Annually
Annually,, and
when:
– Changes in the workplace or type of respirator
– Employee has inadequate knowledge
ƒ Advisory information in subsection (r)
must be displayed for workers who
wear respirators voluntarily
Program Evaluation
6739 (n)
ƒ Employers must evaluate the
workplace as necessary to ensure
program is effective
ƒ Must ask workers required to use
respirators about program
effectiveness and assess problems
they see
End
-of-Service Life
End-of-Service
6739 (o)
Hierarchy of Replacement:
1. Odor, taste or irritation
2. ESLI triggered
3. All disposable Filtering Face Piece (FFP), at end of the*
workday
4. According to pesticide-specific label or respirator
manufacturer directions
5. Absent any pesticide-specific directions, at the end of
the workday
* or,
or, as
as according
according to
to manufacturer,
manufacturer, on
on excessive
excessive breathing
breathing resistance.
resistance.
Recordkeeping
6739 (p)
“ A record of fit tests must be kept
“ Written copy of the current program must be kept
“ Medical recommendations must be kept
ƒ Records required to be kept must be made
available upon request to affected workers,
the local CAC, or others designated by the
Director of DPR
ƒ Records must be kept during employment
requiring respiratory protection and for
three years after such conditions end
Medical Evaluation Questionnaire
6739(q)
Questionnare provided in
regulation, or a substantially
equivalent one, must be completed
by each worker required to wear a
respirator
Voluntary Respirator Provision
Information that must be
provided to workers who
want to wear respiratory
protection when a respirator
is not required by label,
regulation, permit conditions
or employer policy.
6739(r)
Medical Recommendation Form
6739(s)
This form, or one substantially similar,
is used by the PLHCP to state to the
employer if the worker can wear the
respiratory protection
It allows the PLHCP (Physician or
Licensed Health Care Professional) to
recommend other types of respiratory
protection if medically necessary
FORM SOURCES
TEMPLATE FOR A WRITTEN PROGRAM: DOCUMENT HS-1513
AND A COPY OF THE ACTUAL RESPIRATORY REGULATIONS
(SECT 6739)
GO TO Æ WWW.SONOMA
-COUNTY.ORG
WWW.SONOMA-COUNTY.ORG
MEDICAL QUESTIONNAIRE,
MEDICAL RECOMMENDATION FORM,
VOLUNTARY RESPIRATOR INFORMATION
GO TO Æ WWW.SONOMA
-COUNTY.ORG
WWW.SONOMA-COUNTY.ORG
ALSO AVAILABLE IN OUR OFFICE
THE RESPIRATORY HANDOUT HAS SOURCES INFORMATION