Safe Solutions

Roof system installations often involve the use of solvents, adhesives, primers and coatings. Some projects involve the removal of roofing materials that may contain asbestos or lead, and some installations may expose workers to silica dust—all of which pose potential health hazards. Because of the potential for harm, the Occupational Safety and Health Administration (OSHA) requires you to provide your workers with respirators in certain situations.

In the hierarchy of worker protection, OSHA requires employers to engineer a solution or apply administrative controls so workers are not exposed to potentially hazardous materials above acceptable limits. This could include substituting a water-based adhesive or coating for a solvent-based product; rotating workers' duties to minimize their exposure to a potentially harmful product or substance; or using a wet saw for cutting concrete or clay roofing materials.

If engineered solutions or administrative controls are not possible or are inadequate to protect workers, you are required to provide personal protective equipment (PPE), which may include respirators.

Types

There are several respirator types available, including a simple filtering dust mask; an air-purifying respirator that filters vapors through a cartridge or canister; and an atmosphere-supplying respirator that provides the user with air from a source independent of the ambient air where the user is located.

Use of these respirator types should correspond to the severity of hazardous material to which workers are being exposed. A dust mask provides minimal protection from dust and particles; an air-purifying respirator provides protection from dust and some vapors, depending on the cartridge installed in the respirator; and an atmosphere-supplying respirator provides comprehensive protection (except against chemical, biological, radiological or nuclear exposures associated with terrorism events).

Selection

OSHA requires you to evaluate job-site respiratory hazards, as well as workplace- and worker-related factors that could affect respirator performance and reliability, when selecting a respirator type.

Material Safety Data Sheets (MSDSs) are a good source for hazard evaluation of products that roofing workers typically apply, and MSDSs usually will state the respirator type needed.

Additionally, the National Institute for Occupational Safety and Health (NIOSH) offers NIOSH Respirator Selection Logic 2004, which can assist you with respirator selection. The publication can be downloaded from www.cdc.gov/niosh. You must select a NIOSH-certified respirator and choose from a variety of models and sizes to ensure proper fit for all workers.

A plan

When respirator use is required because of a substance's nature and/or concentration, you must develop and implement a written respiratory protection plan. Such a plan should include the following:

• Procedures for respirator selection
• Medical evaluations of workers required to use respirators
• Fit-testing procedures
• Procedures for respirator use, cleaning, inspection and maintenance
• Training procedures to ensure proper operation of atmosphere-supplying respirators
• Worker training regarding respiratory hazards and respirator use and maintenance
• Procedures for evaluating your respiratory protection plan

Additionally, if a worker requests to use a respirator—even if you have determined a respirator is unnecessary—you must determine whether the voluntary use could be potentially hazardous. (Respirator use may be hazardous if it could cause communication problems, interfere with required PPE or obstruct vision, for example.)

Also, you must implement the provisions in your written respiratory program related to the worker's medical evaluation and respirator care and maintenance. You are not required to include in your written respiratory protection program workers whose only use of respirators involves voluntarily wearing dust masks.

Review requirements

Respirator use in roofing work can trigger complicated OSHA requirements. You should review OSHA regulations before requiring respirator use or implementing a written respiratory protection program.

Harry Dietz is NRCA's director of risk management.