Respiratory Protection Program Responsibilities
In order for the Respiratory Protection Program to be effective, all affected individuals must clearly understand and take an active role in meeting their responsibilities. Due to the potential hazards associated with such work, the specific responsibilities outlined in this program must be followed.
In addition to the duties and responsibilities of employees and supervisors outlined in the following sections, other groups at Harvard University will play an important role in supporting the successful implementation and maintenance of this program.
The Environmental, Health, and Safety Department will provide expert technical guidance to support safe use of respiratory protection, and will participate in the annual program review process and training.
In addition, Department Managers will provide management commitment and support for successful implementation and maintenance of this program.
Management and Supervisor's Responsibilities
- Management and supervisor's responsibilities are outlined below:
- Ensuring that employees and contractors abide by the terms and conditions of this program.
- Determining any necessary disciplinary action for violations of this program.
- Providing management commitment and support for successful implementation and maintenance of this program.
- Identifying, with the assistance of EH&S, those employees under their supervision who may need respiratory protection equipment and scheduling them for fitting and training in the proper use and maintenance of the equipment.
- Requesting assistance from EH&S in evaluating new operations that may present health and safety hazards.
- Coordinating with EH&S in obtaining approval from the University Health Services (UHS) - Occupational Health Physician before assigning known or suspected medically restricted employees to jobs requiring the use of respirators.
- Enforcing the use of respiratory protection equipment and other requirements when applicable
- Ensuring that respirator users have received an annual training and medical examinations.
- Ensuring respirator users use and operate their respirators under the respiratory protection procedures as described in this program.
- Applying engineering controls when feasible.
- Referring to the Supervisor's Management Checklist in Appendix D on a regular basis to ensure compliance with this program.
Employee Responsibilities
The responsibilities of employees qualified to wear respirators include:
- Following the requirements of this program.
- Attending required annual respiratory protection training classes and obtaining an annual medical clearance from an Occupational Health Physician to wear a respirator.
- Completing an annual fit test with Harvard EH&S personnel.
- Informing their supervisor of any change in operations, tasks, or hazards present.
- Utilizing the issued respiratory protection equipment in accordance with instruction and training provided by EH&S personnel. This includes maintaining the respirator in a clean " ready to use" condition
- Restricting the use of an assigned respirator to his or her exclusive use
- Informing his/her supervisor or Occupational Health Physician of any personal health problems that could be aggravated by the use of respiratory equipment
- Guarding against damage to equipment and ensuring respirators are not disassembled, modified, or otherwise altered in any way other than by the changing of respirator cartridges or filters.
- Reporting any observed or suspected malfunctioning respirator to their supervisor or EH&S personnel.
- Using only those brands and types of respiratory protection equipment for which they have been trained and fit tested.
Program Administrator Responsibilities
The Program Administrator's responsibilities include (but are not limited to):
- Overseeing the Respiratory Protection Program throughout Harvard Univeristy and conducting required evaluations of program effectiveness. At a minimum, evaluating the Respiratory Protection Program on an annual basis and updating as procedures change.
- Preparing written respirator testing and selection procedures in accordance with applicable standards and the requirements of this program.
- Keeping the University and affected personnel informed of any actions proposed or taken regarding the Respiratory Protection Program.
- Maintaining files that document measures taken to assure respiratory protection, including a current version of the Respiratory Protection Program and records of fit testing, training, and certifications issued.
- Performing and coordinating an annual review of jobs with respirator use with appropriate Managers and Supervisors.
- Reviewing respirator usage on a continual basis to ensure they are applicable and suitable for the purpose intended.
- Performing field audits and reporting back to Management.
- Developing and providing Initial and Refresher Respiratory Protection Training to Employees, Supervisors and Managers.
- Provide safety expertise and regulatory guidance to Employees, Supervisors and Managers as required.
- Recommending Respiratory Protection Equipment Requirements and PPE to supervisors and assisting in the Procurement of appropriate respiratory protective equipment.
- Authorizing the use, procurement, and issuance of respirators after review of work conditions.
- Providing regularly scheduled respirator fit testing and coordinating training to new and continuing employees.
Department of Environmental Health and Safety Responsibilities
The Department of Environmental Health and Safety responsibilities include, but are not limited to:
- Providing regulatory guidance to Harvard University regarding OSHA Respiratory Protection Standards.
- Providing technical guidance on selection of appropriate respiratory protection equipment.
- Providing technical expertise and assistance in air monitoring or industrial hygiene sampling as required.
- Participating in the annual review of the Respiratory Protection Program.
- Maintaining training records as part of the Web Training Database System.
- Training of Harvard University personnel.
Contractors
University contractors shall maintain a written respirator program that meets the requirements of 29 CFR 1910.134. Contractors shall be responsible for administering and maintaining their own Respiratory Protection Program in accordance with 29 CFR 1910.134.
Appendix F is a checklist to be used by Harvard contract managers to ensure compliance with the contractor requirements of the Respiratory Protection Program.
