Respirator Protection

Policy Statement

The City of Toronto is committed to providing and maintaining a healthy and safe working environment by implementing the hierarchy of controls: by elimination or by substitution of a product with one of a lesser toxicity, implementing engineering controls, using administrative practices and personal protective equipment.

Whenever work-related exposure to airborne contaminants (e.g. dusts, fumes, mists, bioaerosols, gases, vapours) cannot be controlled by means of elimination/substitution, engineering (e.g. ventilation) or work practice administration, or shut down for repair/ maintenance or in event of an emergency, respiratory protective devices will be used for employee protection. Issuance and use of respiratory protective devices shall be in keeping with requirements of a respiratory protection program.

Application

This policy applies to all City employees who are required to wear a respirator to protect against airborne contaminants to which they may be exposed during the course of their work.

Requirements

All City of Toronto Divisions with situations in which respiratory protective devices are used for protection against exposure to potentially hazardous environments, such as oxygen-deficiency or airborne contaminants (dusts, fumes, mists, gases, vapours, and bioaerosols) will develop and implement, in consultation with users and Joint Health and Safety Committees (JHSCs), a written Respiratory Protection Program.

The program will be in keeping with the Occupational Health and Safety Act and its associated regulations, including O. Reg. 833 “Control of Exposure to Chemical and Biological Agents”, as well as current accepted industry standards such as the Canadian Standards Association – Z94.4-18 – Selection, Use and Care of Respirators. Program elements will include:

• hazard assessment
• respirator selection and issuance
• cartridge change out schedules (if cartridges are used)
• fit testing
• health surveillance
• equipment cleaning, storage, inspection and maintenance
• training
• program evaluation

Respirator selection should be appropriate for the task and work location must be based on a hazard assessment that includes worker participation. Approved respirators are only those which are certified by NIOSH (National Institute for Occupational Health and Safety) or by CSA (Canadian Standards Association Group), i.e. CSA Z94.4.1 Performance Standard for Filtering Respirators.  Where required and prior to issuing a respirator, a hazard assessment must be performed by a qualified person(s) and to the extent possible, include worker participation, to determine the respiratory hazards present and to assist in the selection of an appropriate respirator. The nature of the respirable hazard must be considered, including, but not limited to:

• the physical state and concentration (estimated) of the contaminant
• potential for oxygen deficiency or immediately dangerous to life or health (IDLH) atmospheres
• the presence of oil in the air (for particulates) and occupational exposure limits.

A Respirable Hazard Assessment Form (Appendix A) can be used to document the assessment components above.

A tight-fitting respirator is a respirator that is designed to form a complete seal with the skin of the face or neck. They include the elastomeric (reusable) half-facepiece and full-facepiece, as well as the single use particulate filtering-facepiece. An Air Purifying Respirator (APR) is a respirator with an air-purifying filter, cartridge, or canister that removes specific contaminants by passing ambient air through the air-purifying element.

A Non-powered APR relies on the breathing action of the user to draw the ambient air through the air purifying element. A seal is required between the edge of facepiece where contact with skin on the face is made and referred to as a tight-fitting respirator. Examples include a single use particulate filtering respirator (e.g., N95, P100) or a re-usable respirator equipped with an air purifying element. A Powered APR (PAPR) uses a blower unit to pull the ambient air with the contaminant through an air-purifying component and then supplies the filtered air into the facepiece. It does not rely on the breathing action of the user. When a PAPR is equipped with a loose fitting facepiece, a seal between the edge of the facepiece and skin of the face is not required.

Fit testing applies to all respirator types with a tight-fitting facepiece.

A Qualitative Fit Test (QLFT) is a pass/fail test method that relies on the subject’s sensory response to detect a challenge agent in order to assess the adequacy of respirator fit.

A Quantitative Fit Test (QNFT) is a test method that uses an instrument to assess the adequacy of respirator fit.

Fit testing must be performed by a Qualified Fit Tester. As per CSA Z94.4-18 “shall be competent in the applicable fit test methods and be able to verify a user’s ability to obtain an effective respirator seal, comfort, and fit for a tight-fitting respirator. The fit tester shall also be able to manage the overall fit testing process, including the transition between sensitivity screening and fit testing where applicable, interpret test results, and document user, respirator, and instrument performance. Fit testers shall follow the requirements of the program and shall not perform a fit test if they observe that the person is not free from interference where the respirator seals to the skin of the face or neck. In such cases, the fit tester shall notify the program administrator.

Tips for fit testers are attached in Appendix B.

Conditions for Respirator Use

• Fit testing will be performed prior to staff receiving a respirator
• Fit testing will be performed every two years thereafter
• There must be no medical conditions preventing the use of a respirator
• There must be no interferences with the respirator-face seal

Fit test results must be recorded. The Respirator Fit Test Record must include information that conforms to CSA Z94.4.18, including but not limited to:

• Name of Person being Fit Tested
• Date of Fit Testing
• Person Conducting Fit Test
• Fit Testing Method
• Brand, Model and Size of Respirator used for the Fit Test
• Fit Test Result (Pass or Fail)

A process must be established to verify an employee’s fitness to wear a respiratory protective device (i.e. to verify that the employee is free of physiological or psychological conditions that may prevent them from using the respiratory protective device). This process may be achieved by either:

• Having the employee assessed by a health care professional prior to fit testing to confirm whether they are medically fit to wear respirators; or
• Having the employee complete screening information (Appendix C, D or E) prior to fit testing to identify whether there are potential health issues that preclude them wearing a respirator

When there is doubt about the fitness or ability of the person to wear a respirator, the employee who is required to use the respirator should seek a medical review.

Divisions may choose to use either the CSA Screening Form (Appendix E) or the City’s Respirator Fit Test Record (Appendix C&D) to document medical fitness to wear a respirator.

When an employee is deemed medically unfit to wear a tight-fitting respirator, attempts should be made to look at appropriate alternative types of respirators that are appropriate for the task. When an employee is unfit to wear any type of respirator, the division should seek assistance with the employee accommodation process, if applicable.

A PAPR equipped with a non-powered tight-fitting facepiece such as a loose-fitting hood is an alternative to a nonpowered APR when clean shaven conditions cannot be achieved due to religious or medical reasons, or when clean shaven conditions can be achieved but needed as means of a medical accommodation. Also, if the nonpowered APR does not afford the protection needed against the airborne concentration of the contaminant, a PAPR may be the appropriate based on the respirable hazard risk assessment. PAPRs have a higher assigned protection factor.

When using a tight-fitting respirator, users must be clean-shaven on areas of the face where the face piece seals to the skin. For employees who cannot be clean shaven the division should seek assistance with the employee accommodation process, if applicable.

Prior to using a respirator and at least every two years thereafter an employee must receive training on the use, limitations and care of the respirator, in addition to being fit tested. All records of respirator fit-checks and training will be maintained by the division issuing the respirator. Training may not be required in cases where a review has been conducted confirming that the employee remains qualified to wear a respirator.

Compressed breathing air and air compressors used for supplied air respirators or self-contained breathing apparatus (SCBA) must comply with the current CSA Standard Z180.1. SCBA cylinders must be inspected externally and internally by a qualified person in accordance with applicable standards and regulations including, but not limited to:

• CSA B339 and CSA B340;
• CGA C-6, C-6.1, or C-6.2, as applicable;
• applicable transport regulations; and
• the manufacturer’s instructions.

SCBA cylinders must be hydrostatically tested every five years. Other cylinders must be hydrostatically tested at a frequency and in the manner described in CSA B339 and CSA B340.

Responsibilities

Management will:

In situations, tasks or work areas requiring respiratory protection, management will:

• Designate a qualified person as the Program Administrator
• Provide the name of the Program Administrator to Purchasing & Materials Management Division (PMMD) responsible for the procurement, management and release of respiratory protective devices
• Ensure that tasks or work areas requiring use of respiratory protection has been assessed and documented, and the respirator type required for the task or work area is identified
• Ensure that resources for employee training, fit testing and respiratory protective equipment are made available
• Conduct a review of the respiratory protection program on a regular basis and as required

Supervision will:

• Identify situations or work areas where respirators may be required and ensure an assessment of the hazard is conducted
• Communicate areas or job tasks where respiratory protection is required based on the assessment
• Provide the appropriate respiratory protective device to employees
• Consult with appropriate People and Equity staff, when necessary, to assist with hazard assessments, respirator selection, or medical clearance
• Ensure that only employees who have been screened, fit tested and trained are issued respirators
• Ensure that workers use only those respirators for which they have been fit tested
• Ensure respirators are cleaned, sanitized, inspected, maintained, repaired and stored in accordance with the manufacturer’s written recommendations
• Conduct periodic, random inspections of work areas where respirators are worn to ensure appropriate use, i.e. being worn in accordance with the instructions, training received and with safe operating procedures
• In the case of tight-fitting face piece, inform users that they must maintain their required clean-shaven condition
• Make available the necessary filters/cartridges and respirator models for which employees have been fit tested
• Provide details of the type of respirator(s) selected for the associated tasks, when required
• Notify the Program Administrator of any user concerns, changes in process/equipment/operating procedures
• Notify the Program Administrator of investigation reports that reveal situations where a respirator may have prevented or contributed to an incident or injury
• Refer to the Use, Care and Limitations of Air-Purifying Respirators Safety Procedure (Appendix F) for detailed instructions

Program Administrator will:

• Arrange and co-ordinate training and fit testing
• Maintain a list of activities and work areas, determined by a hazard assessment, to require the use of a respirator and the type of respirator needed
• Ensure that the respirator protection program addresses screening, fit testing and training of those who are to wear respirators
• Maintain a list of respirator users with details as required
• Advise Management of any program element changes or gaps
• Maintain training and fit testing records of all respirator users
• Ensure that a cartridge change-out schedule is developed and implemented for areas where chemical cartridges are used
• Use the PMMD Respirator Order Form (Appendix G) to order respiratory protective devices, filters and chemical cartridges

Respirator Users will:

• Wear and use the appropriate fit tested respirator in accordance with the instructions and training received
• Maintain a clean-shaven condition where the respirator contacts the face when using a tight fitting face piece
• Check that the respirator is clean and in good operating condition
• Perform a negative and/or positive pressure user seal-check at the start of each use
• Remove respirators from service that are defective and report defects to their supervisor
• Change out filters and cartridges as per the change-out schedule
• Report to their supervisor any condition or change that may impact on their ability to use a respirator safely
• Immediately advise their supervisor of any health and safety issues or concerns
• Participate fully in all aspects of the Respirator Protection Program, including fit testing and training
• Advise of any accommodation requirements
• Refer to the Use, Care and Limitations of Air-Purifying Respirators Safety Procedure (Appendix F) for detailed instructions

Occupational Hygiene staff will:

• Provide technical advice and recommendations for respiratory hazard assessments
• Assist supervisors in determining the type(s) of respiratory protection required for the specific respiratory hazard(s)
• Assist with the development and delivery of training and education when necessary
• Upon request, provide tools on the use, care, fit and storage of air purifying respirators
• Assist in developing a Fit Test Program for divisions
• Monitor regulatory and industry standards regarding respiratory protection

People and Equity Health and safety staff will:

• Provide consultation to members of the JHSC pertaining to respiratory protection needs
• Consult with divisional management regarding the provision of training and development of safe work procedures
• Assist divisional management and/or JHSCs with hazard assessments

Joint Health and Safety Committees will:

• Review the division/section- specific Respiratory Protection Program on a regular basis, and make recommendations for change, as needed

The Occupational Health and Safety Coordinating Committee will:

• Monitor the implementation and effectiveness of this policy

Purchasing and Materials Management Division will:

• Procure and maintain stock of approved respirators
• Maintain and process requests using their Respirator Request Form
• Fulfill order requests signed by the Program Administrator, on behalf of divisional management for which respirator use is a requirement of the job
• Maintain a list of divisional Program Administrators

Endorsed by

Occupational Health and Safety Coordinating Committee, September 2013

Approved by

City Manager, November 25, 2013

Revised and re-endorsed by OHSCC

September 28, 2021

June 6, 2024

Related Information

• O. Reg. 833, Control of Exposure to Chemical and Biological Agents
• CSA Z94.4-18, Selection, Use and Care of Respirators Program
• CSA Z180.1-13, Compressed Air Breathing Systems
• CSA B339, B340, Design/manufacture/qualification & selection/use, of cylinders
• CGA C_6, 6.1, 6.2, Compressed Gas Association Visual Inspection of Steel Cylinders
• CSA B339, Cylinders, Spheres & Tubes for Transportation of Dangerous Goods
• CSA B340, Selection & Use of Cylinders, Spheres & Tubes & Other Containers for Transportation of Dangerous Goods, Class 2

Attachments

• Appendix A: Respirable Hazard Assessment Form
• Appendix B: Tips and Checklist for Respirator Fit Tester
• Appendix C and D: Respirator Fit Test Records (Quantitative or Qualitative)
• Appendix E: CSA Respirator User Screening Form
• Appendix F: Use, Care and Limitations of Air Purifying Respirators Safety Procedures
• Appendix G: PMMD Respirator Request Form