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Canadian respirator legislation compliance made easy

By Sean Donovan
| www.cos-mag.com

A working knowledge of applicable standards is critical to a company’s continued success. However, understanding your requirements to comply isn’t necessarily easy.

Standards are designed to establish and dictate the use of certain safe practices and equipment, and require employers to monitor hazards and keep records of workplace injuries and illnesses, in an effort to provide a work environment free from known dangers or hazards. 

Most standards are voluntary, meaning there are no laws requiring their application. Despite that, adherence to standards is beneficial to companies because it shows products have been independently tested to meet certain standards. These standards are trade-specific and are frequently self-imposed by industry-related societies or committees. Some, however, are mandatory. With that said, it is often difficult to discern which ones require compliance.

Laws and regulations in most municipalities, provinces and states in North America require certain products to be tested to a specific standard or group of standards by a Nationally Recognized Testing Laboratory (NRTL). The law of the jurisdiction often requires it, or the customer specifies it.  

Respiratory protection

An estimated five million workers are required to wear respirators in 1.3 million workplaces throughout North America. Respirators protect workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapours and sprays. These hazards may cause cancer, lung impairment, other diseases or even death.

Respirators are necessary for protection from airborne hazards and biological contaminants. They are also required in atmospheres that are oxygen-deficient or that could possibly pose that risk.

Generally, if respiratory protective equipment is used: 

•    Employers are required to provide the appropriate equipment.

•    Employers must ensure that it is properly fitted to the ?individual worker.

•    Employers are required to ensure that workers using respiratory protective equipment are adequately trained.

•    Employers must maintain and store equipment properly. 

CSA Standard Z94.4 - Selection, Use and Care of Respirators

Although most jurisdictional legislation across Canada has yet to adopt the latest CSA 2011 revision of the CSA Z94.4 standard, they all reference the standard as a whole. Using the latest standard as a basis for developing and maintaining a respirator program is the simplest way to ensure you are complying with the law.

CSA Z94.4 was designed to establish requirements for the selection, use and care of respirators. Furthermore, it identified the need for an effective respiratory protection program and the importance of its administration in the workplace. Its objective was to protect respirator users from any known respiratory hazards.

CSAZ94.4-11 was updated in 2011 and the scope was expanded to include protection against bio-aerosols when selecting a respirator. In addition, fit testing protocols were updated, respirator interference concerns were addressed and training requirements were added and updated in this version of the standard.

The respirator selection process used in CSA Z94.4-11 is based on NIOSH criteria for the testing and certification of respirators. 

CSA Z94.4-11 requires a written respiratory protection program to be in place where respiratory protection is used to protect workers from inhaling hazardous atmospheres.

The basic elements of a respiratory protection program are:

•    hazard identification

•    exposure assessment

•    education of employees on airborne hazards in the workplace;

•    selection of appropriate respirators;

•    provision of respirator fit testing;

•    provision of training in the proper use of respiratory protection;

•    provision of appropriate procedures for cleaning, inspecting and storing respirators;

•    provision of medical surveillance for workers using ?respiratory protection;

•    provision for evaluating the effectiveness of this program;

•    maintenance of training, fit testing and medical ?surveillance records;

•    control and monitoring of external contractors performing work in environments that require the use of respiratory protection.

Employers must choose respirators based on the selection criteria:

•    Respiratory protective equipment must be properly fitted to the wearer’s face.

•    Employers must comply with standard when fit testing respiratory protective equipment.

•    Employers must use the assigned protection factors (APFs) specified in that standard.

•    Employers must develop a written code of practice ?governing the selection, maintenance and use of respiratory protective equipment.

For more information about CSA Group visit

www.csagroup.org.



Compliance made easy

Proper protection of respirator users is the overall goal of a respirator program. Most respirator manufacturers have tools designed to simplify the process of developing, administering and maintaining a respiratory protection program in a work environment. 

Some examples are:

•    Respirator Selection Guide

•    Cartridge Life Expectancy Calculator

•    Interactive Training Program

Respirator Selection Guide

The purpose of a Respirator Selection Guide is to offer a compilation of a broad range of respiratory protective products to help you to determine which respiratory solution best fits your specific requirements. Not only does the Respirator Selection Guide encompasses your various choices in respirator options, but it will offer guidance on choosing the correct cartridges and/or filters. The most important factor in determining the best respirator for your individual needs is to understand the environmental factors involved. This can be achieved through proper air sampling. Respirator and cartridge selection are determined by the following factors: the results of your air sampling program; the accepted NIOSH, ACGIH or other jurisdictionally recognized exposure limits for contaminants; and, the maximum use concentration of those substances.   

Cartridge Life Expectancy Calculator

Caution must be used when checking filters and cartridges. Should they become clogged, it can increase the likelihood of contaminated air entering the mask. In addition, should cartridges become full or saturated, gases or vapors will leak through the cartridge. Both cartridges and filters must be replaced on a regular basis by using the manufacturer’s recommendations. An example of this is the Cartridge Life Expectancy Calculator.

The Cartridge Life Expectancy Calculator is an interactive means to help determine when a specific cartridge should be replaced, based on length of use and concentration.

The following information is needed to adequately utilize a Cartridge Life Expectancy Calculator:

•    chemical hazard

•    exposure and concentration

•    temperature

•    relative humidity

•    atmospheric pressure  

•    what type of respirator you are using

•    type of work and average breathing rate

•    breakthrough concentration preference

Interactive Training Program

Most respirator manufacturers now offer training programs in CD format and/or online through their websites. As part of an effective interactive training program, online courses are available to inform users about the respirator, how to wear it and how to maintain it. CSA Z94.4-11 mandates that if you issue respirator, you must train the person on the respirator. Online classes offer ease of use since it is available 24 hours a day, and end-users can be trained when it is convenient.

Users should also consider consulting manufacturers for recommendations or with any questions on specific products.

Resources

There are a number of notable resources available to help guide you. A few of the more widely recognized authorities on respiratory protection are profiled as follows:

CCOHS

In Canada, workers are covered by provincial or federal labour codes depending on the sector in which one works. The Canadian Centre for Occupational Health and Safety (CCOHS), an agency of the Government of Canada, is driven by the belief that all Canadians have a fundamental right to a healthy and safe working environment. CCOHS’s goal is to provide tools that are both useful and credible in an effort to improve workplace health and safety programs.

CSA

The Canadian Standards Association is the most widely accepted regulatory agency in Canada. CSA is an independent, not-for-profit membership association that encompasses standards development, training and advisory solutions, global testing and certification services, as well as consumer product evaluation services. Currently 40 per cent of all the standards issued by CSA are referenced in Canadian legislation.

NIOSH

The National Institute for Occupational Safety and Health (NIOSH) is the U.S. federal agency responsible for conducting research and making recommendations for the prevention of work-related injury and illness. NIOSH conducts scientific research, develops guidance and authoritative recommendations, disseminates information, and responds to requests for workplace health hazard evaluations. Where there is a danger of an airborne hazardous substance or an oxygen deficient atmosphere in a workplace, the employer shall provide a respiratory protective device that is listed in the NIOSH Certified Equipment List.

There are various avenues that can help you with the trials and tribulation of respiratory standard compliance. To stay current on the standards that pertain to your industry and specific work environment, it is always in your best interest to turn to your jurisdictional occupational safety and health websites first. Contacting the manufacturer of your equipment can also be of benefit. 

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Sean Donovan, senior product line manager for industrial products with MSA Canada, has been an integral part of MSA Head, Eye, Face and Hearing Regional Steering Team for North America. Donovan’s background and extensive industry experience has earned him a representative seat on a number of CSA committees, including CSA Z94.2 – Hearing Protection Devices.

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