Respiratory Protection and ASTM F3387-19
MSHA published the new silica rule last year. As we approach compliance dates for Coal mines and M/NM Mines a year later, I wanted to bring attention to the new respiratory protection standard. The regulation incorporated ASTM F3387-19 by reference. There is a lot to this standard, so I wanted to highlight some of the key parts to the updated program.
First, here is the link from the MSHA silica single-source page:
Now, how do we make a respiratory protection plan that complies with the new ASTM standard? Here are the minimum requirements:
ASTM F3387-19 5.5 Minimal Acceptable Respirator Program
5.5.1 Program Administration
5.5.2 SOPs
5.5.3 Medical Evaluation
5.5.4 Respirator Selection
5.5.5 Training
5.5.6 Fit Testing
5.5.7 Maintenance, Inspection, and Storage
or, to expand on this with the complete reference sections and specifications:
5.5 Minimal Acceptable Respirator Program
5.5.1 Program Administration (covered in Section 6)
6.1 RP Administrator (doesn’t have to be someone at the mine)
6.3 Responsibilities
Administer and update plans
Audit the plan at least annually
Ensure other person audits periodically that is not associated with the plan
May be covered under SOPs with auditing
5.5.2 SOPs (Section 7)
7.2.1 Hazard Assessment (covered in section 8.2)
Which contaminants are present
Physical state of chemical properties
Likely airborne concentrations
Potential for oxygen deficient atmospheres
Whether there is a TLV
Whether IDLH atmosphere exists
Can contaminant be absorbed through the eyes or skin or produce sensitivity
7.2.2 Respirator selection (covered in Section 8.3)
Nature of hazard
Activity and workplace factors
Respirator use duration
Respirator limitations
Use of approved respirator
7.2.3 Medical Evaluation (5.5.3)
Licensed Health Care Professional following
Type and weight of respirator
Duration and frequency of use
Hazards for which respirator will be worn
Additional PPE to be worn
Written records of medical evaluations maintained as medical records
7.2.4 Training (covered in Section 9)
Provide initial and annual
Basic Respiratory Protection Practices
Nature and extent of respiratory hazards encountered
Recognition and resolution of respirator use problems
Principals for selecting respirators
Fit testing and issuing respirators
Respirator inspection
Proper respirator use and monitoring use
Specific element change schedule
Respirator maintenance and storage
Regulations concerning respirator use
Records of training
7.2.5 Fit Testing (Section 10)
Negative-Pressure Respirator Fit Tests
Quantitative APF of 100 for half mask/500 for full mask
Qualitative cannot be worn in atmospheres greater than 10x TLV
Positive-Pressure Respirator Fit Tests (including PAPRs) (Section 10.3.2)
Fit Tested in Negative Pressure Mode
Qualitative or Quantitative (APF of 100/500 like above)
Fit Testing performed annually
Records shall be kept (10.7)
7.2.6 Issuance
7.2.7 Maintenance, inspection, and storage (Section 12)
Decontamination, Cleaning, and Sanitizing
Inspection
Parts Replacement and Repairs
Storage
7.2.8 Air-purifying element change schedule (Section A1)
Service Life of canister element
Change schedule
7.2.9 Breathing air quality (Section 13)
Only applies to supplied air. Not Applicable for most mines
7.2.10 Monitoring respirator use
7.2.11 Hazard Re-evaluation
7.2.12 Employer policies
7.2.13 Program evaluation and auditing
(covered with Program Administrator)
7.3 Special considerations for escape-only respirators
Only applicable if they use escape-only respirators such as H2S bite piece
5.5.3 Medical Evaluation (covered in SOPs)
5.5.4 Respirator Selection (covered in SOPs)
5.5.5 Training (Covered in SOPs)
5.5.6 Fit Testing (Covered in SOPs)
5.5.7 Maintenance, Inspection, and Storage (Covered in SOPs)
I hope this helps everyone to prepare for compliance dates ahead of the new rule.
As always, if you would like assistance writing a compliant program or review of your current plan, please contact me.
