Respiratory Protection Policy

I. Policy Description

This policy establishes an approval process and procedures to ensure safe and responsible selection and use of respiratory protection. Adherence to this policy ensures compliance with all applicable laws, enhances safety, and preserves privacy of members of the University community who use respiratory protection.

II. Who is Affected by the Policy?

This policy applies to all University faculty and staff and is highly recommended for students.

III. Policy and Procedures

The Occupational Safety and Health Administration (OSHA) requires the University to provide respiratory protection to employees when their risk of exposure to hazardous materials cannot be controlled by other means. The University has established a Respiratory Protection Program that addresses the selection and use of respiratory protection and has provisions for fit testing, training, and medical monitoring of respirator users. This program is administered by the Office of Environmental Health and Safety.

1. Assessing the Need for Respiratory Protection

Faculty, staff and students considering the need for respiratory protection should first consult with Environmental Health and Safety (EHS).

Prior to the assignment of respiratory protection for an individual, EHS will consider alternative solutions, such as engineering or administrative controls to minimize the risk of exposure. EHS will conduct exposure measurements subject to the constraints of available sampling and analytical methodologies and will apply the most conservative exposure limit available from organizations such as OSHA, NIOSH, or ACGIH when evaluating the need for respiratory protection.

In situations where there is no sampling data available or where there is insufficient or inconclusive evidence concerning the toxicity of the material in question, EHS judgment shall prevail.

2. Enrollment in Princeton University Respiratory Protection Program

If EHS determines that respiratory protection is needed, the individual will be included in the University’s Respiratory Protection Program. This requires EHS to assign and, on an annual basis, fit the individual with the appropriate device and train them in its proper care, maintenance, inspection and use as required by regulation. The respirator user must complete a medical history form administered by Employee Health annually. Employee Health must provide medical clearance for the respirator user annually.

3. Respirator Care and Use

Individuals who have been assigned respiratory protection are expected to clean and maintain the equipment and use it only as approved. Individuals may not loan their assigned respirator to other persons and are advised to keep such equipment secured to prevent its use or misuse by other persons.

4. Unnecessary Respiratory Protection

When EHS has determined that respiratory protection is not required or necessary, an individual may not wear respiratory protection unless they participate in the University’s Respiratory Protection Program or sign a release form.

The only exception to this requirement is when an individual chooses to wear a filtering facepiece respirator for comfort, such as an N95 or an N100, that is determined to be unnecessary by EHS. In these cases, the individual does not need to be enrolled in the Respiratory Protection Program, but they must review and follow appendix D of the OSHA Respiratory Protection Standard. Users should also review and follow the guidance offered in the EHS fact sheet on Voluntary Use of N95 Respirators (Filtering Facepiece Respirators).

IV. Enforcement

Failure to follow this policy is a violation of the Human Resources Workplace Health and Safety Policies and Responsibilities. In the event that employees do not follow this policy or procedures, it is the supervisor's responsibility to act in a timely manner and initiate a program of disciplinary steps to address the problem, as outlined in the University’s Disciplinary Procedure.

V. Related Documents and Forms

OSHA's Respiratory Protection Standard
NIOSH Respiratory Protection Information
Voluntary Use of N95 Respirators (Filtering Facepiece Respirators)

VI. Roles and Responsibilities

Environmental Health and Safety Conduct exposure assessment to determine if respiratory protection is necessary. Assign the appropriate device to respirator users and provide them with annual fit testing and training. 
Employee Health Services Conduct annual medical monitoring of all respirator users.
Supervisors Consult Environmental Health and Safety to determine the need for respiratory protection. Ensure that employees properly use assigned respiratory protection, receive fit testing and medical monitoring, and attend training.
Faculty and Staff Wear assigned respirator as directed. Receive annual medical monitoring, fit testing and training.

VII. Related Policies

University Policy on Health, Safety and the Environment (ESRM)
HR Policy 5.2.4 Disciplinary Procedure

VIII. Update Log

Adopted March 26, 1980 by the Committee on Occupational Safety and Health (now ESRM)
Amended February 20, 2017 by Environmental Safety and Risk Management Committee

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