Fast Response Onsite Testing (FROST) is the grower’s best friend when it comes to complying with respiratory protection standards. If you don’t have a protection program in place, FROST can help you develop and maintain your program. If you already have a program in place, FROST will COME TO YOU and provide annual medical evaluations, fit testing and training WITHOUT loss of work productivity commonly seen when your workers go off the job to a clinic or center.
The new respiratory protection regulations have been recently adopted by the California
Department of Pesticide Regulation (DPR). County Agricultural Commissioners (CAC)
began enforcing the new regulations starting January 1, 2008.
General Requirements. The employer shall assure that employees use respirators
when required by label, restricted material permit condition or regulation. This
subsection also discusses the components of a written respiratory protection program.
Voluntary Respirator Provision. An employer may provide respirators to employees
or allow employees to use their own respirators on a voluntary basis. The employer must
provide to employees information outlined in subsection (r) about the proper use of
respirators and their limitations. Under an employer-supplied voluntary respirator
provision, the employer must implement a minimal written respiratory protection
program. A written program is not required when a voluntary respirator program only
involves the use of filtering facepiece.
Note: Filtering facepieces ARE respirators and are
subject to all provisions of Section 6739 when used for
protection from pesticides.
The employer shall identify a physician or other licensed health
care professional to conduct medical evaluations to determine an employee’s ability to wear a respirator. The physician shall perform the medical evaluation using the medical questionnaire in subsection (q), or by direct medical examination. The medical questionnaire and examinations shall be administered confidentially. The employer shall obtain a written medical recommendation from the physician regarding the employee’s ability to use a respirator. Though only required to have the employee evaluated once, the employer shall provide additional evaluations if certain regulatory triggers are met involving the ability of the worker to wear the respirator without adverse health effects.
Fit Testing. The employer shall assure that employees using tight-fitting facepieces
pass an appropriate Cal/OSHA compliant fit test prior to initial use of a respirator, and at
least annually thereafter.
Training and Information. Training shall be conducted prior to an employee using a
respirator. Retraining shall be done annually and when the following situations occur: (1)
changes in the workplace or respirator render previous training obsolete; (2) inadequacies
in the employee’s knowledge or use of the respirator indicate retraining is necessary; or
(3) any other situation arises in which retraining appears necessary. Among other things,
the employer shall ensure that the employee can demonstrate knowledge concerning why
the respirator is necessary; what the limitations and capabilities of the respirator are; how
to inspect and maintain the respirator; and how to recognize medical signs and symptoms
that may limit or prevent the effective use of respirators.
Program Evaluation. The employer shall conduct evaluations of the workplace as
necessary to ensure that the provisions of the current program are effective. The
employer shall also annually consult employees required to use respirators regarding their
views on program effectiveness and to identify any problems. Any deficiencies
identified during this assessment shall be corrected within 30 days. A written
documentation of these evaluations and consultations shall be maintained.
Recordkeeping. The employer shall retain written information regarding medical
recommendations, fit testing, and the respirator program. Records shall be maintained
while the employee is required to use a respirator, and for three years after the end of employment conditions requiring the use of a respirator. A written copy of the current respirator program shall be retained by the employer, and previous versions shall be retained for three years.
It is the employer’s responsibility to understand the respirator regulations and to implement the applicable portions at the work site DPR’s guidance document HS-1513 mentioned earlier was designed as a template to assist respirator program administrators in developing a written respirator program. Employers may want to check with their insurance carriers or with respirator manufacturer representatives for additional help in developing a respiratory protection program, including respirator selection and fit testing.