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RESPIRATORY PROTECTION PROGRAM(Sample) RESPIRATORY PROTECTION PROGRAM
September 22, 2004
This program is provided by the Vancouver Fire Department to comply with the Washington Industrial Safety and Health Administration’s (WISHA) General Occupational Health Standards, Chapter 296-62 WAC, Part E, Respiratory Protection. Much of the information provided in this program was derived from the OSHA Technical Manual, Section VIII: Chapter 2, Respiratory Protection and OSHA’s Small Entity Compliance Guide, Appendix IV, Sample Respiratory Protection Program.
SEE ALSO: WAC 296-800 Safety and Health Core Rules WAC 296-841 Respiratory Hazards WAC 296-842 Respirators
TABLE OF CONTENTS
1.0 Purpose………………………………………………..……………………….. 3
2.0 Scope and Application………………………………………………….…..…..3
3.0 Responsibilities………………………………………………………………… 3 Respirator Program Administrator Supervisors Employees SCBA Committee 4.0 Respirator Selection……………………………….……………………….…. 5 Evaluating Respiratory Hazards Hazard Evaluation Update Workplace and User Factors Respirator Selection Table NIOSH Certification Assigned Protection Factors Contaminant Breakthrough Warning System Atmospheres Requiring Highest Level of Protection 5.0 Medical Evaluation…………………………………………………………… 9 Information Provided to the PLHCP Medical Questionnaire Administration PLHCP’s Written Recommendations Additional Medical Evaluations
6.0 Fit Testing…………………………………………………………………….. 11 Fit Testing Procedure Fit Testing Exercises
7.0 Respirator Use………………………………………….………….………… 12 Facepiece Seal Protection Monitoring Respirator Effectiveness Procedures for Immediately Dangerous to Life and Health (IDLH) Situations 8.0 Maintenance and Care……………………………………………….……… 13 Cleaning and Disinfecting Storage Inspection Repair 9.0 Breathing Air Quality………………………………………….……………. 15 Compressors 10.0 Identification of Filters, Cartridges and Canisters………………..………. 15
11.0 Training and Information…………………………………………..……….. 16 Respiratory Protection Training Guideline Frequency of Training
12.0 Program Evaluation …..………………………….…..…………….…..…….17 13.0 Recordkeeping……………………………………………………..………… 17
Appendix A: Cover letter for Respiratory Medical Evaluation Questionnaire …19 Respirator Medical Evaluation Questionnaire……………….……..21 Respiratory Medical Form……………………………………………25
Appendix B: Respirator Fit Test Record ………………….………………………. 26 Appendix C: Respirator Training Record ..……………………………………….. 27 Appendix D: QNFT / QLFT Protocols…...………………………………………… 28 Appendix E: General Fit Testing Requirements for Respiratory Protection……. 31 Appendix F: APR Cartridge-change Schedule………………………………………35 Appendix G: Glossary………………………………………………………………...40 Appendix H: Fire Investigator Safety at Fire Scenes—Admin. Guide 200.5 Investigator Respiratory Protection/Safety Chart Phase 3 Decision Logic Chart Post-fire site safety hazard evaluation worksheet Respirator-Selection-Decision Flow Chart Appendix I: SCBA Maintenance and Inspection—Admin. Guide 200.11 SCBA After-use Form Vancouver Fire Department 1.0 Purpose
It is policy that the Vancouver Fire Department (VFD) shall provide a safe and healthful work environment for all of it’s’ employees. The VFD has determined that some of its employees may be exposed to respiratory hazards. These hazards include particulates, vapors and in some cases may represent Immediately-Dangerous-to-Life-or-Health (IDLH) conditions. The purpose of this program is to ensure that all employees are protected from exposure to these hazards. Engineering controls such as ventilation is the first line of defense. However, engineering controls have not always been feasible for some of our operations or have not always completely controlled the identified hazards. In these situations, respirators and other protective equipment must be used. Respirators are also used for protection during emergencies. (WAC 296-62-07103, 07107)
2.0 Scope and Application
This program applies to all employees who are required to wear respirators during normal work operations such as structural firefighting, fire investigation, and emergency medical calls with potential exposures to airborne contaminants. Respirators will also be required for use during certain non-routine training or emergency operations involving Special Operations. Employees participating in the respiratory protection program do so at no cost to them. The expense associated with medical evaluations, training, fit testing and respiratory protection equipment will be borne by the VFD. (WAC 296-62-07115)
3.0 Responsibilities
3.1 Respirator Program Administrator The Respirator Program Administrator is responsible for overseeing the respiratory protection program and to conduct the required evaluations of program effectiveness thereby ensuring that all the requirements of this program are fully implemented, as necessary. Through authority delegated by the Fire Chief, the Respiratory Program Administrator has the ability to make changes to this plan. The person designated as the Program Administrator is the Deputy Chief of Operations. (WAC 296-62-07113)
Duties of the Program Administrator include:
3.2 Supervisors
Supervisors are responsible for ensuring that the Respiratory Protection Program is implemented in their particular areas. In addition to being knowledgeable about the program requirements for their own protection, supervisors must also ensure that the program is understood and followed by the employees under their charge. Duties of the supervisor include:
3.3 Employees Each employee has the responsibility to wear his or her respirator when and where required and in the manner in which they were trained. Employees must also:
3.4 SCBA Committee
The SCBA Committee is comprised of six SCBA Maintenance Technicians and one Coordinator. SCBA technicians are trained and certified by MSA and are responsible for the following: · Annual inspections of SCBAs. · All repairs needed due to damage. · Fit testing personnel.
4.0 Respirator Selection
The Program Administrator will ensure that the respirator selected will be adequate to effectively reduce exposure to the respirator user under all conditions of use including reasonably foreseeable emergency situations. (WAC 296-62-07130-07133) The respirator ensemble chosen by the VFD, whether in an APR application or SCBA, is the MSA Ultra Elite full-face mask. The approved SCBA ensemble for the VFD incorporates the MSA Firehawk. These SCBAs are certified for a minimum service life of thirty minutes. Additionally, the Technical Rescue Team (TRT) has the discretion to use larger air bottles providing one-hour certification and to use ISI hardline breathing apparatus with the supplemental escape cylinders. Only VFD investigators, hazmat technicians, and technical-rescue technicians will an APR configuration. The only cartridge filter approved for use in the VFD is the MSA GME P100.
4.1 Evaluating Respiratory Hazards
The Program Administrator will ensure selected respirators match the hazards to which workers are exposed and in accordance with all WISHA standards. The Incident Commander (IC) will conduct a hazard evaluation for each work area where airborne contaminants may be present in routine operations or during an emergency. The hazard evaluation will include:
Table 4.1 – Respirator Decision Logic Sequence Following a Structure Fire shall be used to assist in evaluating respiratory hazards and selecting an appropriate level of respiratory protection. Table 4.1 Respirator Decision Logic Sequence Following a Structure Fire
Covers activities following fire extinguishment and before, concurrent with, or after overhaul for the determination of the origin and cause of the fire.
Start Yes
Respiratory Protection Positive Pressure SAR · Continual atmospheric monitoring initiated · CO Levels less than 35 PPM (See notes 1 & 2) · Oxygen content at least 19.5% · Ambient and debris temperature at or below 165 F X Positive Pressure SCBA Positive Pressure SAR Full – Face APR equipped with organic vapor/acid gas cartridges and P 100 filters Half – Face APR used in conjunction with non-vented approved eye protection, and equipped with organic vapor/acid gas cartridges and P 100 filters * The levels or respiratory protection as discussed in this table are minimum requirements. The ability to exceed these requirements is a discretionary right of the wearer.
Notes: 1. Carbon Monoxide levels should be similar to ambient air, e.g. ½ the PEL for Co (35 ppm). Co levels much higher than ambient air may indicate the presence of other air contaminates.
2. Air monitoring equipment can detect only a few of many heat decomposition products.
3. Minimize exposure in environments where contents are hot to the touch or steaming. This may indicate the continued release of toxic products.
4. Chemical cartridge users shall guard against disturbing any materials that might release dust or fibers.
5. There should be no expectation for unusual toxic contaminants.
6. Respirator cartridges should be replaced per manufacturer’s instructions and recommendations.
7. Entrant shall exit hazardous atmosphere immediately if any odor is detected inside the respirator face piece.
4.2 Hazard Evaluation Update The IC or designee is responsible to revise and update the on-scene hazard evaluation as needed. If an employee feels that a greater level of respiratory protection is needed during a particular activity, s/he is to contact the IC. The IC or designee will evaluate the potential hazard. The IC or designee will then communicate the results of that assessment back to the affected employees. If it is determined that respiratory protection is necessary, all other elements of this program will be in effect for those tasks and this program will be updated accordingly.
The IC or designee will document the hazard evaluation update in the Incident Report using the narrative portion of the approved reporting system. The hazard evaluation update will then become part of the official record of the incident and be kept on file.
4.3 Workplace and User Factors The Program Administrator will ensure a review of the job operation, equipment or tools used, and any required motions do not interfere with the type of respirator to be selected.
The Program Administrator will ensure that selected respirators will not impair the worker’s vision, hearing, communication, and physical movement necessary to perform jobs safely. 4.4 NIOSH Certification All respirators used by employees of the VFD are certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification. All filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval label. The label must not be removed or defaced while it is in use. In addition all SCBA’s are certified CBRN; chemical, biological, radiological, nuclear (WAC 296-62-07130).
4.6 Assigned Protection Factors The assigned protection factors in “WAC 296-62-07131, Table 1--Assigned Protection Factors” will be used when selecting respirators. SCBA will be used for all fire department emergency activities with the exception of a fire investigator using an APR in a non-IDLH environment where the IC and lead investigator have determined the environment to be safe using the protocols set forth in the chart on Table 4.1.
4.7 Contaminant Breakthrough Warning Systems The system in place to prevent air-purifying-respirator wearers from being exposed to contaminant breakthrough includes using a respirator cartridge replacement schedule based on the manufacturer breakthrough-test data and quantitative post fire environmental analysis performed by NIOSH; the US Bureau of Alcohol, Tobacco, and Firearms; and studies summarized in the following documents: ● “Characterization of Firefighter Exposures During Fire Overhaul”, American Industrial Hygiene Association Journal (AIHAJ), 2000; 61:636-641 ● “Adverse respiratory Effects Following Overhaul in Firefighters”, Journal of Occupational Medicine, 2001; 43:467-473 ● “Health Hazard Evaluation Report 96-0171”, Bureau of Alcohol, Tobacco, and Firearms, 1998
Refer to Appendix F for a summary of the information and data that was relied upon and is the basis for the APR cartridge change schedule and reliance on the data. Employees using cartridges not equipped with End-of-Service-Life-Indicator (ESLI) must replace cartridges after every use, and no single use shall exceed 4 hours in length.
For respirators worn exclusively for protection against particles, filters will be changed per the manufacturer’s specification and whenever the wearer detects a change in breathing resistance.
4.8 Atmospheres Requiring Highest Level of Protection For IDLH atmospheres, the highest level of respiratory protection and reliability is required in the form of a complete SCBA ensemble. (WAC 296-62-07132).
5.0 Medical Evaluation
The VFD has the responsibility of ensuring that employees are medically fit and able to tolerate the physical and psychological stress imposed by respirator use, as well as the physical stress originating from job and workplace conditions. Employees will not be allowed to wear respirators until a physician or other licensed health care professional (PLHCP) has determined they are medically able to do so. Any employee refusing the medical evaluation cannot work in an area requiring respirator use.
Portland Adventist Occupational Medicine Clinic will provide initial and any follow-up medical evaluations.
The medical evaluation will be conducted using a questionnaire approved by WISHA, the VFD, and the PLHCP. A copy of this questionnaire can be found in Appendix A. The Program Administer will ensure a copy of the questionnaire is provided to all employees requiring medical evaluations. The frequency of the questionnaire and evaluations for employees will be determined by the PLHCP.
5.1 Information Provided to the PLHCP
The Program Administrator will ensure the PLHCP is provided the following general information before evaluations begin: · A copy of the approved “Respirator Medical Evaluation Questionnaire”. · A copy of this written respiratory protection program including a list of respirators used by the VFD. · A copy of the fit testing procedures used by the Vancouver Fire Department. · A copy of chapter “296-62 WAC, Part E, Respiratory protection.” · The type and weight of the respirator to be used by the employee. · The duration and frequency of respirator use (e.g., for routine, rescue and escape tasks). · The expected physical work effort (e.g., “low”, “medium” or “high”). · A description of additional protective clothing and equipment to be worn. · Estimates of temperature and humidity extremes that may be encountered. · Any special or hazardous conditions the employee could encounter.
5.2 Medical Questionnaire Administration Employees assigned to tasks requiring the use of respirators will be required to complete the WISHA approved “Respirator Medical Evaluation Questionnaire” (WAC 296-62-07255, Appendix C). The Program Administrator will ensure a copy of the questionnaire is provided to all employees requiring medical evaluations. The medical evaluation will be administered confidentially and during working hours at a place on site that is convenient to employees. A stamped and addressed envelope for mailing the questionnaire to the PLHCP will be provided. Employees will be paid per the existing labor agreements during questionnaire administration. To ensure confidentiality, no employee of the City of Vancouver or the VFD will review completed questions and there will be no employee/employer interaction that could be considered a breach of confidentiality. Where confidentiality cannot be maintained during administration of the questionnaire, the employee will be sent to the PLHCP for medical evaluation. If needed, employees will have the opportunity to discuss the questionnaire content and/or examination results with the PLHCP via telephone call. During questionnaire administration, the PLHCP's phone number will be given to employees and access to a phone will be provided at no charge to the employee. All records from medical evaluations, including completed questionnaires, will remain confidential between the employee and the PLHCP. 5.3 PLHCP’s Written Recommendations The VFD will obtain a written recommendation from the PLHCP on whether or not the employee is medically able to wear a respirator. The recommendation must identify any limitations on the employee's use of the respirator, as well as the need for periodic or future medical evaluations that are required by the PLHCP. The employee will receive a copy of the PLHCP's written recommendations directly from the PLHCP. Information concerning diagnosis, test results, or other confidential medical information will not be disclosed to the City of Vancouver or the VFD by the PLHCP. 5.4 Additional Medical Evaluations
The VFD will provide additional medical evaluation or medical re-evaluation for any employee when: • The employee reports medical signs or symptoms that are related to the employee's ability to use a respirator. • A PLHCP, supervisor, or the Respirator Program Administrator observes that the employee is having a medical problem during fit testing or workplace respirator use. • Information from the Respiratory Protection Program, including observations made during fit testing and program evaluation, indicates a need for employee re-evaluation. • A change occurs in workplace conditions (e.g., physical work effort, type of respirator used, protective clothing, or temperature) that may result in a substantial increase in the physiological burden placed on an employee. The content of such additional medical evaluations will be determined by the PLHCP. 6.0 Fit Testing
All employees required to wear a tight-fitting face piece along with a respirator will be required to pass a negative pressure fit test annually. Also, all employees who are required to wear N95 or other particulate respirators will be required to pass a qualitative fit test for an appropriate N95 or other respirator. Fit testing will be performed as follows:
Employees will be fit tested with the make, model, and size of respirator they will actually wear. Employees will be provided with different sizes of respirators and face pieces so they may find the optimal fit for SCBA, APR’s, and N95 respirators. If for any reason an employee finds the respirator fit is unacceptable, the VFD will provide a reasonable opportunity to select a different face piece and to be re-tested. The form in Appendix B: Respirator Fit Test record will be used to document respirator fit testing.
6.1 Fit Testing Procedure
A VFD-approved fit-testing technician will conduct fit testing. Fit testing will be administered using the WISHA-accepted qualitative fit test protocols found in “WAC 296-62-07201 Appendix A-1: General Fit Testing Requirements for Respiratory Protection and WAC 296-62-07230 Appendix A-3: Quantitative /fit Testing (QNFT) Protocols for Respiratory Protection.” The quantitative fit test protocol used by the VFD is the WAC 296-62-07245 Controlled Negative Pressure (CNP) Quantitative Fit Test protocol (QNFT). A copy of the protocol can be found in Appendix D.
6.2 Fit Testing Exercises
A fit-testing technician will ensure the test exercises described in Appendix D are performed when conducting a quantitative fit test.
The respirator must not be adjusted while a fit test is in progress. Employees will perform fit test exercises in the test environment while wearing other safety equipment normally worn during actual respirator use that could interfere with respirator fit. This equipment shall include turnout coat, nomex hood, and helmet. If the employee exhibits breathing difficulty during the fit test, s/he will be referred to the PHLCP to determine whether a respirator can be worn while performing his or her duties. 7.0 Respirator Use
The IC or designee will monitor emergency scene work areas to be aware of changing conditions where employees are using respirators. 7.1 Facepiece Seal Protection The VFD will not permit respirators with tight-fitting face pieces to be worn by employees who have conditions determined to compromise the facepiece-to-face seal. Examples of these conditions include facial hair (e.g., stubble, bangs) that interferes with the facepiece seal or valve function, absence of normally worn dentures, the use of jewelry or headgear that projects under the facepiece seal. The grooming standards for fire department employees are found in AG 400.6, and these guidelines meet the WAC 296-62-07170.
Corrective glasses or goggles, or other personal protective equipment, must be worn in such a way that they do not interfere with the seal of the facepiece to the face. Full-facepiece respirators will be provided where either corrective glasses or eye protection is required, since corrective lenses can be mounted inside a full-facepiece respirator. The use of contact lenses with respirators where the wearer has successfully worn such lenses before will be allowed. A user seal check (also known as a fit check) will be performed every time a tight-fitting respirator is put on or adjusted to ensure proper seating of the respirator to the face. The user seal check shall be conducted in accordance to the manufacturer’s recommendations, located in Appendix D. The manufacturer’s recommended fit check procedures are equally protective as the procedures described in WAC 296-62-07251 Appendix B-1: User Seal Check Procedures). 7.2 Monitoring Respirator Effectiveness
The IC or designee will be responsible to maintain appropriate surveillance of changes on the scene of an incident. Different work areas may present different conditions that may increase employee exposure or stress. (WAC 296-62-07171) Employees must leave the respirator use area when:
● The respirator user can detect vapor or gas breakthrough (by odor, taste, and/or irritation effects), a change in breathing resistance, or leakage of the facepiece. The employee must leave the respirator-use area before attempting to replace the respirator or the filter, cartridge, or canister elements. ● The respirator is not properly functioning and must be replaced or repaired. ● The employee experiences severe discomfort in wearing the respirator or if the employee experiences sensations of dizziness, nausea, weakness, breathing difficulty, coughing, sneezing, vomiting, fever, and chills.
7.3 Procedures for Immediately Dangerous to Life and Health (IDLH) Situations
The VFD has identified the following areas or job duties as presenting the potential for IDLH conditions: ● Environments that have elements of fire, smoke, hazardous materials, or the potential for explosion. ● Post-fire environments where fire origin and cause investigations may occur.
Written procedures developed for emergency scene operations in IDLH environments can be found in the following Administrative Guidelines: 200.3, Medical Surveillance Program 200.5, Fire Investigator Safety 300.2, Scene Control and Safety 300.3, Passport Accountability System 300.5, On-Scene Medical Rehabilitation 300.13, Emergency Egress Guidelines
For specific operational information regarding stand-by firefighters during operations in an IDLH atmosphere refer to AG 300.9, Rapid Intervention Team.
8.0 Maintenance and Care The Program Administrator will ensure oversight of respirator maintenance and care. The SCBA Committee (comprised of the Department’s SCBA maintenance technicians and their coordinator) shall maintain the record keeping of the respirator after use forms. The After-Use Form outlines the cleaning, disinfecting and inspection of all respirators in the fire department. This form is prescribed by Appendix I: Administrative Guideline 200.11 SCBA Maintenance and Inspections. 8.1 Cleaning, and Disinfecting
As prescribed in AG 200.11, respirator users must clean and disinfect their assigned respirators in accordance with the manufacturer’s recommended procedures. The cleaning and disinfecting procedures are posted by the decontamination sink in each station along with the appropriate cleaning supplies. The manufacturer’s recommended procedures are equally safe as the procedures listed in (WAC 296-62-07253 Appendix B-2: Respirator Cleaning Procedures.)
8.2 Storage All fire department respirators will be stored in a natural configuration protecting them from damage, contamination, dust, sunlight, temperature extremes, excessive moisture, and damaging chemicals. Each employee will be issued a facepiece and protective bag. The facepiece, exhalation valve, heads up display, and voice emitter will be stored in the protective bag and in a manner that prevents deformity. Each individual fire investigators is issued an additional facepiece in an APR configuration. (WAC 296-62-07176)
The Program Administrator will ensure that an adequate number of respirators are provided for each apparatus. The standard requirements for front line apparatus will be 4 SCBA’s for Engines, and 5 SCBA’s for Trucks. This will ensure that employees who are considered extra staffing for a given shift or given apparatus will have a respirator available along with the individual’s issued mask.
8.3 Inspection Respirators will be inspected and cleaned after each use, and the process documented on the After-use Form prescribed by A.G. 200.11. This will ensure that each respirator is inspected before each subsequent use. Respirators designated for use in reserve apparatus will be inspected at least weekly. All respirator inspections will be done following the manufacturer’s recommended procedure and checked for proper function before and after each use. Respirator inspections will include a check of respirator function, tightness of connections, and the condition of the various parts including but not limited to: The facepiece, head straps, valves, connecting tube, and all warning devices. On all APR’s cartridges, canisters, or filters will be checked for any deformity or expiration. In addition, the elastomeric parts must be evaluated for pliability and signs of deterioration. Respirator inspections will ensure the air cylinders are charged to at least 4,000 lbs. psi. This equals 90% of the manufacturer’s recommended full pressure level of 4,500 psi. Inspection information for all fire department respirators will be maintained at Station 88 with the SCBA maintenance technicians’ records. 8.4 Repair The Program Administrator will ensure respirators failing to pass inspection or otherwise found to be defective will be removed from service and repaired or adjusted. If a respirator cannot be repaired or adjusted, it will not be put back into service. Repairs or adjustments to respirators will be done by the Department’s SCBA maintenance technicians. Only NIOSH-approved manufacturer’s replacement parts designed for that respirator will be used, and work will be done according to the manufacturer's recommendations and specifications. SCBA's air cylinders will be maintained in a fully charged state and recharged when the pressure falls below 4,000lbs.psi. Cylinders will be recharged by individuals at fire stations that have air compressors with fill stations: 81, 82, 83, 84, and 88. SCBA air cylinders will be hydrostatically tested according the manufacturers recommended frequency. Hydrostatic testing will be conducted by an approved facility. 9.0 Breathing Air Quality The Program Administrator will ensure that breathing air for atmosphere-supplying respirators is of high purity, meets quality levels for content, and does not exceed certain contaminant levels and moisture requirements as specified in WAC 296-62-07182(2).
All breathing gas containers must be marked in accordance with the NIOSH respirator certification standard, 42 CFR part 84.
9.1 Compressors
Compressors used for supplying breathing air must be constructed and situated so contaminated air cannot enter the air-supply system. The location of the air intake will be in an uncontaminated area where exhaust gases from nearby vehicles, the internal combustion engine that is powering the compressor itself (if applicable), or other exhaust contaminants being ventilated will not be picked up by the compressor air intake.
Compressors will be equipped with suitable in-line, air-purifying sorbent beds and filters to further ensure breathing air quality and to minimize moisture content so that the dew point at 1 atmosphere pressure is 10°F (5.56°C) below the ambient temperature. Sorbent beds and filters will be maintained and replaced or refurbished periodically according to the manufacturer's recommendations. An inspection tag will be kept at the compressor indicating the most recent change date and the signature of the Program Administrator or designee authorized to perform the maintenance.
Oil lubricated compressors use a high temperature or carbon monoxide alarm, or both, to monitor CO levels. If only high temperature alarms are used, the Program Administrator will ensure the air supply will be monitored at intervals sufficient to make sure the concentrations of CO in the breathing air does not exceed 10 ppm. Where this is not possible or feasible, we will combine the use of a carbon monoxide alarm with a carbon monoxide sorbent bed. Breathing air couplings must be incompatible with outlets for non-respirable plant air or other gas systems to prevent accidental servicing of airline respirators with non-respirable gases or oxygen. No asphyxiating substance (e.g., nitrogen) will be allowed in the breathing airlines. 10.0 Identification of Filters, Cartridges and Canisters
The Program Administrator will ensure that all filters, cartridges, and canisters used in the workplace are labeled and color-coded with the NIOSH approval label, and ensure that the label is not removed and remains legible. (WAC 296-62-07184 Table 3 -- Color Coding of Respirator Filters, Cartridges and Canisters) provides color-coding information. For employees authorized to use APRs in their work, the safety policies and filter change requirements can be found in AG 200.5.
11.0 Training and Information
The Program Administrator will ensure training is provided to respirator users, supervisors, and any person issuing respirators on the contents of this Program and their responsibilities under it, and on the WISHA respiratory protection standard. Employees will be trained prior to using a respirator in the workplace. Supervisors will be trained prior to using a respirator in the workplace or prior to supervising employees who wear respirators. (WAC 296-62-07186)
11.1 Respiratory Protection Training Guideline
The Respiratory Protection Training course materials will cover the following information:
Employees will demonstrate their understanding of the information covered in the training through hands-on exercises and a written test. The VFD Training Division will document respirator training including the type, model, and size of respirator for which each employee has been trained and fit tested. The form in Appendix D: Respirator Training Record will be used.
11.2 Frequency of Training New employees will be provided respirator training prior to using a respirator in the workplace.
Employees will be retrained annually and more often as needed (e.g., if they change area/location/position and need to use a different respirator). Retraining will occur if the Program Administrator or Supervisor determines that any employee has not retained or demonstrated the knowledge, understanding, or skill level required by the training program. 12.0 Program Evaluation
The Program Administrator is responsible to conduct periodic evaluations to ensure that the provisions of the program are being implemented. The following factors will be evaluated to determine program effectiveness:
Supervisors are responsible to periodically monitor employee use of respirators to ensure that they are being used and worn properly. The Program Administrator will ensure corrective actions are taken to address problems associated with wearing a respirator that are identified by employees or that are revealed during any other part of this evaluation. 13.0 Recordkeeping
The Program Administrator will ensure retention of the PLHCP’s written recommendation for each employee subject to medical evaluation. Each employee’s completed medical questionnaire, results of relevant medical tests, examinations, and diagnosis, etc., will be maintained by the PHLCP for a period of 30 years. Records of medical evaluations will be made available as specified in Chapter 296-62 WAC, Part B, WISHA's Access to Records rule.
The Program Administrator will ensure retention of fit test records for respirator users until the next fit test is administered. These records consist of: • Name or identification of the employee tested; • Type of fit test performed (QLFT, QNFT -- irritant smoke, saccharin, etc.); • Make, model, and size of the respirator fitted; • Date of the fit test; • Pass/fail results if a QLFT is used; or • Fit factor and strip chart recording or other record of the test results if quantitative fit testing was performed. The form in Appendix B: Respirator Fit Test Record will be used to document employee fit testing. The Program Administrator will ensure retention of employee training records, including the names of employees trained and the dates when training was conducted. The Program Administrator will keep a current copy of the Vancouver Fire Department’s written respiratory protection program at Fire Station 81, located at 7110 NE 63rd St, Vancouver, WA 98661. Also, every computer desk top will have access to this written program in electronic form under Administrative Guideline 200.10, and every fire station will have a hard written copy of the Administrative Guideline. All written materials required to be maintained under the recordkeeping requirements will be made available, upon request, to the employee who is subject of the records and to the director or the director’s designee of the Washington State Department of Labor and Industries for examination and copying. Cover letter for respiratory medical evaluation questionnaire
All VFD personnel who are required to wear an SCBA must be evaluated on a regular basis by a PLHCP (Privately licensed health care provider) per WAC 296-62. The parameters for frequency of testing are:
The beginning of this requirement is the complete and accurate filling out of the attached questionnaire. Either, the department’s appointed PLHCP, or your own physician, who must be capable of rendering an occupational decision on your medical ability to wear a respirator, will review this questionnaire. The questionnaire will be given to you on duty and must be completed on duty. An envelope with postage will be provided for mailing to the department’s PLHCP (Or sent or taken to your own qualified PLHCP). All information contained on the questionnaire will be strictly confidential. No one from the department will have the right or the ability to ascertain any of your personal medical information or answers to these questions. The PLHCP will, however, render a medical opinion on your physical ability to wear an SCBA. Both you and the employer will receive a copy of this form. (See attached respiratory medical form) Should you choose to use the department’s PLHCP (which is currently Adventist Health / Wellness Services) and if they require further medical testing to evaluate your ability to wear an SCBA, you may give them permission to use your current year’s annual wellness testing results. If you feel this medical information will not assist them in determining your best current medical status, you can have the necessary additional testing done (at department expense) at the health care provider of your choice. It is a cost saving to the department that you let your choice of PLHCP use your current wellness test results. This medical information will only be shared with the PLHCP, and not the employer. In discussions with both WISHA and our PLHCP, it was determined that when filling out the questionnaire, you should answer the questions with regard to your ability to wear an SCBA. An example would be: Question #14. Have you ever had a back injury? (What they are looking for is: does your back pain or injuries currently keep you from wearing an SCBA, or having difficulty when you wear one?)
Another example is question #15. Do you currently have any of the following musculoskeletal problems? (Again, the PLHCP is asking you: are these problems occurring when you are wearing your respirator; and do they prevent or hinder your ability to wear the SCBA?) Should you choose to fill out the questionnaire and use your own qualified physician as the PLHCP, you will need to have this person contact the Departments Respirator Program Administrator to get the necessary forms and information regarding our SCBA’s, turnouts, and workplace environment. Should you have any questions, please ask the department’s Respiratory Program Administrator, currently the Deputy Chief of Operations, Dennis Walker.
Respirator Medical Evaluation Questionnaire
Appendix C to 1910.134: OSHA (Mandatory) To the employer: Answers to questions in Section 1, and to question 9 in Section 2 of Part A, do not require a medical examination.
Your employer must allow you to answer this questionnaire during normal working hours, or at a time and place that is convenient to you. To maintain your confidentiality, your employer or supervisor must not look at or review your answers, and your employer must tell you how to deliver or send this questionnaire to the health care professional who will review it.
To the employee: Can you read (circle one): Yes No Part A. Section 1. (Mandatory) The following information must be provided by every employee who has been selected to use any type of respirator (please print). 1. Today's date:_________________________________________________________ 2. Your name:__________________________________________________________ 3. Your age (to nearest year):______________________________________________ 4. Sex (circle one): Male Female 5. Your height: __________ ft. __________ in. 6. Your weight: ____________ lbs. 7. Your job title:________________________________________________________ 8. A phone number where you can be reached by the health care professional who reviews this questionnaire (please include the Area Code): _________________________________ 9. The best time to phone you at this number: ________________ 10. Has your employer told you how to contact the health care professional who will review this questionnaire (circle one): ..................................................................... Yes No 11. Check the type of respirator you will use (you can check more than one category): a. ______ N, R, or P disposable respirator (filter-mask, non-cartridge type only). b. ______ Other type (for example, half- or full-facepiece type, powered-air purifying, supplied-air, self-contained breathing apparatus). 12. Have you worn a respirator (circle one): ............................................. Yes No If "yes," what type(s): ______________________________________________________________________________________________________________________________________ Part A. Section 2. (Mandatory) Questions 1 through 9 below must be answered by every employee who has been selected to use any type of respirator (please circle "yes" or "no"). 1. Do you currently smoke tobacco, or have you smoked tobacco in the last month: ............... Yes No 2. Have you ever had any of the following conditions? a. Seizures (fits): ........................................................... Yes No b. Diabetes (sugar disease): .......................................... Yes No c. Allergic reactions that interfere with your breathing: ..................... Yes No d. Claustrophobia (fear of closed-in places): ...................................... Yes No e. Trouble smelling odors (except when you had a cold): .................. Yes No 3. Have you ever had any of the following pulmonary or lung problems? a. Asbestosis: ...........................................…............... Yes No b. Asthma: ...................................................…........... Yes No c. Chronic bronchitis: ................................................. Yes No d. Emphysema: ........................................................... Yes No e. Pneumonia: ............................................................. Yes No f. Tuberculosis: ........................................................... Yes No g. Silicosis: .......................................................…...... Yes No h. Pneumothorax (collapsed lung): ............................. Yes No i. Lung cancer: ............................................................ Yes No j. Broken ribs: ............................................................. Yes No k. Any chest injuries or surgeries: ...............................Yes No l. Any other lung problem that you've been told about: ................. Yes No 4. Do you currently have any of the following symptoms of pulmonary or lung illness? a. Shortness of breath: ................................................. Yes No b. Shortness of breath when walking fast on level ground or walking up a slight hill or incline: Yes No c. Shortness of breath when walking with other people at an ordinary pace on level ground: Yes No d. Have to stop for breath when walking at your own pace on level ground: ........... Yes No e. Shortness of breath when washing or dressing yourself: ..................... Yes No f. Shortness of breath that interferes with your job: ................................ Yes No g. Coughing that produces phlegm (thick sputum): ................................ Yes No h. Coughing that wakes you early in the morning: ................................. Yes No i. Coughing that occurs mostly when you are lying down: ..................... Yes No j. Coughing up blood in the last month: ............…….............................. Yes No k. Wheezing: ....................................................……………………....... Yes No l. Wheezing that interferes with your job: .....................……................. Yes No m. Chest pain when you breathe deeply: .............................……........... Yes No n. Any other symptoms that you think may be related to lung problems: ................. Yes No 5. Have you ever had any of the following cardiovascular or heart problems? a. Heart attack: ....................................................... Yes No b. Stroke: ................................................................ Yes No c. Angina: ............................................................... Yes No d. Heart failure: ...................................................... Yes No e. Swelling in your legs or feet (not caused by walking): .................... Yes No f. Heart arrhythmia (heart beating irregularly): .................................... Yes No g. High blood pressure: .........................................……………............ Yes No h. Any other heart problem that you've been told about: ...................... Yes No
6. Have you ever had any of the following cardiovascular or heart symptoms? a. Frequent pain or tightness in your chest: .......................………................ Yes No b. Pain or tightness in your chest during physical activity: ........................... Yes No c. Pain or tightness in your chest that interferes with your job: .................... Yes No d. In the past two years, have you noticed your heart skipping or missing a beat: ....…....... Yes No e. Heartburn or indigestion that is not related to eating: ...................…........ Yes No f. Any other symptoms that you think may be related to heart or circulation problems: ...... Yes No 7. Do you currently take medication for any of the following problems? a. Breathing or lung problems: .................................... Yes No b. Heart trouble: ........................................................... Yes No c. Blood pressure: ........................................................ Yes No d. Seizures (fits): .......................................................... Yes No 8. Has your wearing a respirator caused any of the following problems? (If you've never used a respirator, check the following space __ and go to question 9:) a. Eye irritation: ........................................................... Yes No b. Skin allergies or rashes: ........................................... Yes No c. Anxiety that occurs only when you use the respirator: ......... Yes No d. Unusual weakness or fatigue: ............................................... Yes No e. Any other problem that interferes with your use of a respirator: ............ Yes No 9. Would you like to talk to the health care professional who will review this questionnaire about your answers to this questionnaire: ......................................…....................... Yes No Questions 10 to 15 below must be answered by every employee who has been selected to use either a full-facepiece respirator or a self-contained breathing apparatus (SCBA). For employees who have been selected to use other types of respirators, answering these questions is voluntary. 10. Have you ever lost vision in either eye (temporarily or permanently): ....................... Yes No 11. Do you currently have any of the following vision problems? a. Wear contact lenses: ............................................... Yes No b. Wear glasses: .......................................................... Yes No c. Color blind: ............................................................. Yes No d. Any other eye or vision problem: ........................... Yes No 12. Have you ever had an injury to your ears, including a broken ear drum: .................... Yes No 13. Do you currently have any of the following hearing problems? a. Difficulty hearing: ................................................... Yes No b. Wear a hearing aid: ................................................. Yes No c. Any other hearing or ear problem: .......................... Yes No 14. Have you ever had a back injury: .......................... Yes No 15. Do you currently have any of the following musculoskeletal problems? a. Weakness in any of your arms, hands, legs, or feet: ................... Yes No b. Back pain: .......................................................... .... Yes No c. Difficulty fully moving your arms and legs: ............................... Yes No d. Pain or stiffness when you lean forward or backward at the waist: ............... Yes No e. Difficulty fully moving your head up or down: .......................... Yes No f. Difficulty fully moving your head side to side: ........................... Yes No g. Difficulty bending at your knees: .............................….............. Yes No h. Difficulty squatting to the ground: ...................…...................... Yes No i. Difficulty climbing a flight of stairs or a ladder carrying more than 25 lbs: ..........…. Yes No j. Any other muscle or skeletal problem that interferes with using a respirator: ............ Yes No
Please list and explain any questions that you answered “yes” to. (ie. Does it interfere with your ability to wear a SCBA?)
Respiratory Medical Form
____________________ is found to be medically capable of wearing (Employee name) an SCBA and an N95 Particulate Respirator per WISHA and WAC requirements. Yes ______ No ______ (Will be reevaluated in _____ months) No ______ (Will never be able to pass certification)
The employee must submit for re-evaluation in 1 year _______ 3 years ______ Other _______ (Recommended guideline for frequency of evaluation is every 3 years for those under 40 without relevant medical problems and every year for those 40 and over)
__________________________ _________________ (PLHCP Signature) (Date)
A copy of this will be sent to the employer and to the employee.
APPENDIX B: Respirator Fit Test Record
Name: __________________________________________________ Initials: ________
Type of qualitative/quantitative fit test used: ____________________________________ Name of test operator: ______________________________________ Initials: ________ Date: _________________ RESPIRATOR MFR./MODEL/APPROVAL NO. SIZE PASS/FAIL 1. _____________________________________________ S M L P F 2. _____________________________________________ S M L P F 3. _____________________________________________ S M L P F 4. _____________________________________________ S M L P F NOTES: _____________________________________________________________
____________________________________________________________________
____________________________________________________________________
____________________________________________________________________ This record indicates that you have passed or failed a qualitative or quantitative fit test as shown above for the particular respirator(s) shown. Other types will not be used until fit tested.
APPENDIX C: Respirator Training Record
___________________________________________Employee Name (printed) I certify that I have been trained in the use of the following: This training included the inspection procedures, fitting, maintenance and limitations of the above respirator(s). I understand how the respirator operates and provides protection. I further certify that I have heard the explanation of the unit(s) as described above and I understand the instructions relevant to use, cleaning, disinfecting and the limitations of the unit(s). __________________________________ Employee Signature __________________________________ Instructor Signature __________________________________ Date
Appendix D:
Controlled Negative Pressure (CNP) Quantitative Fit Testing Protocol (QNFT). How does controlled negative pressure (CNP) fit testing work (QNFT)? (1) The CNP fit test method technology is based on exhausting air from a temporarily sealed respirator facepiece to generate and then maintain a constant negative pressure inside the facepiece. The rate of air exhaust is controlled so that a constant negative pressure is maintained in the respirator during the fit test. The level of pressure is selected to replicate the mean inspiratory pressure that causes leakage into the respirator under normal use conditions. With pressure held constant, air flow out of the respirator is equal to air flow into the respirator. Therefore, measurement of the exhaust stream that is required to hold the pressure in the temporarily sealed respirator constant yields a direct measure of leakage air flow into the respirator. (2) The CNP fit test method measures leak rates through the facepiece as a method for determining the facepiece fit for negative pressure respirators. (3) Manufacturer attachments. The CNP instrument manufacturer Occupational Health Dynamics also provides attachments (sampling manifolds) that replace the filter cartridges to permit fit testing in an employee's own respirator. (4) Performing the test. To perform the test, the employees close their mouths and hold their breath, after which an air pump removes air from the respirator facepiece at a preselected constant pressure. (5) Facepiece fit. The facepiece fit is expressed as the leak rate through the facepiece, expressed as milliliters per minute. (6) The quality and validity of the CNP fit tests are determined by the degree to which the in-mask pressure tracks the test pressure during the system measurement time of approximately five seconds. Instantaneous feedback in the form of a real-time pressure trace of the in-mask pressure is provided and used to determine test validity and quality. What are the controlled negative pressure (CNP) fit testing requirements and procedures (QNFT)? (1) Fit factor. § A minimum fit factor pass level of 100 is necessary for a half-mask respirator. § A minimum fit factor of at least 500 is required for a full facepiece respirator. (2) The entire screening and testing procedure must be explained to the employee prior to the conduct of the screening test. (3) The instrument must have a nonadjustable test pressure of 15.0 mm water pressure. (4) When performing fit tests, set the CNP system defaults at: § 15 mm of water (-0.58 inches of water) test pressure and § 53.8 liters per minute for the modeled inspiratory flow rate. § Note: CNP systems have built-in capability to conduct fit testing that is specific to unique work rate, mask, and gender situations that might apply in a specific workplace. Use of system default values, which were selected to represent respirator wear with medium cartridge resistance at a low-moderate work rate, will allow inter-test comparison of the respirator fit. (5) The person conducting the CNP fit testing must be thoroughly trained to perform the test. (6) Replace the respirator filter or cartridge with the CNP test manifold. Temporarily remove or prop open the inhalation valve downstream from the manifold. (7) Train employees to hold their breath for at least 20 seconds. (8) Have the employee put on the test respirator without any assistance from the individual who conducts the CNP fit test. (9) The QNFT protocol must be followed according to WAC 296-62-07231 with an exception for the CNP test. (10) The test instrument must have an effective audio warning device when the employee fails to hold his or her breath during the test. (11) Stop the test whenever the employees fail to hold their breath. The employees must be refitted and retested. (12) A record of the test must be kept on file, assuming the fit test was successful. The record must contain the employee's name; overall fit factor; make, model, style and size of respirator used; and date tested. What test exercises are required for controlled negative pressure (CNP) fit testing (QNFT)? (1) Normal breathing. In a normal standing position, without talking, the employees must breathe normally for 1 minute. After the normal breathing exercise, the employees must hold their head straight ahead and hold their breath for 10 seconds during the test measurement. (2) Deep breathing. In a normal standing position, the employees must breathe slowly and deeply for 1 minute, being careful not to hyperventilate. After the deep breathing exercise, the employees must hold their head straight ahead and hold their breath for 10 seconds during test measurement. (3) Turning head side to side. § Standing in place, the employees must slowly turn their heads from side to side between the extreme positions on each side for 1 minute, holding their heads each extreme momentarily so they can inhale at each side. § After the turning head side to side exercise, have the employees hold their heads full left and hold their breath for 10 seconds during test measurement. § Next, have the employees need to hold their head full right and hold their breath for 10 seconds during test measurement. (4) Moving head up and down. § Standing in place, the employees must slowly move their heads up and down for 1 minute. § Instruct the employee to inhale in the up position (when looking toward the ceiling). § After the moving head up and down exercise, the employees must hold their heads full up and hold their breath for 10 seconds during test measurement. § Next, the employees must hold their heads full down and hold their breath for 10 seconds during test measurement. (5) Talking. The employee must talk out loud slowly and loud enough so as to be heard clearly by the test conductor. The employee can read from a prepared text such as the Rainbow Passage, count backward from 100, or recite a memorized poem or song for 1 minute. After the talking exercise, the employee must hold his or her head straight ahead and hold his or her breath for 10 seconds during the test measurement. (6) Grimace. The employee must grimace by smiling or frowning for 15 seconds. (7) Bending over. Employees must bend at the waist as if they were touching their toes for 1 minute. Jogging in place must be substituted for this exercise in those test environments such as shroud-type QNFT units that prohibit bending at the waist. After the bending over exercise, the employees must hold their head straight ahead and hold their breath for 10 seconds during the test measurement. (8) Normal Breathing. § The employee must remove and put on the respirator again within a one-minute period. § Then, in a normal standing position, without talking, the employee must breathe normally for 1 minute. § After the normal breathing exercise, the employee must hold his or her head straight ahead and hold his or her breath for 10 seconds during the test measurement. (9) After the test exercises, question the employee about the comfort of the respirator. If the respirator has become unacceptable, another model of a respirator must be tried.
General Fit Testing Requirements for Respiratory Protection
General Requirements for Fit Testing (1) Fit testing using the procedures found in Appendices F of this plan will be conducted. The requirements in this appendix apply to all WISHA-accepted quantitative (QNFT) fit test methods. (2) The employee will be allowed to pick the most acceptable respirator from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits.
(3) Prior to selecting a respirator, the Fit Test Technician shall show the employee how to:
(4) The Fit Test Technician shall provide a mirror for employees to use when evaluating the fit and positioning of the respirator. (5) Employees must be informed that:
(6) Employees shall hold each chosen face piece up to their face and eliminate those that obviously do not give an acceptable fit. (7) The Fit Test Technician must note the more acceptable face pieces in case the one selected proves unacceptable. The mask must be put on and worn at least five minutes to make sure it is tight-fitting. The Fit Test Technician must help the employee assess comfort by discussing the points in subsection (8) of this section. If the employee is not familiar with using a particular respirator, have the employee put on the mask several times and adjust the straps each time to become adept at setting proper tension on the straps. (8) The fit test technician shall review how to assess the comfort of a respirator by reviewing the following points with the employee and allowing the employee enough time to check the comfort of the respirator chosen: (a) Position of the mask on the nose; (b) Room for eye protection; (c) Room to talk; (d) Position of mask on face and cheeks. (9) The Fit Test Technician must use the following criteria to determine if the respirator adequately fits each employee: (a) Chin properly placed; (b) Adequate strap tension, not overly tightened; (c) Fit across nose bridge; (d) Respirator of proper size to span distance from nose to chin; (e) Tendency of respirator to slip; (f) Self-observation in mirror to evaluate fit and respirator position. (10) Employees must complete a user seal check. They must use either the negative and positive pressure seal checks described in WAC 296-62-07251, Appendix B-1 or those recommended by the respirator manufacturers that provide equivalent protection to the procedures in WAC 296-62-07251, Appendix B-1. Before conducting the negative and positive pressure checks, the employee must be told to seat the mask on the face by moving the head from side-to-side and up and down slowly while taking in a few slow deep breaths. Another facepiece must be selected and retested if the employee's respirator fails the user seal check tests. (11) The Fit Test Technician must not conduct the fit test if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth, beard, mustache or sideburns that cross the respirator sealing surface. Any type of apparel that interferes with a satisfactory fit must be altered or removed. (12) If the employee has difficulty in breathing during the tests, the Fit Test Technician Must refer the employee to a physician or other licensed health care professional, as appropriate, to determine whether the employee can wear respirators while performing the employee's duties. (13) If the employee finds the fit of the respirator unacceptable, the Fit Test Technician Must give the employee the opportunity to select a different respirator and the employee must be retested. (14) Prior to starting the fit test, the Fit Test Technician must describe the:
(15) The employee must wear the respirator at least 5 minutes before starting the fit test. (16) When performing the fit test, the Fit Test Technician must have your employee wear any applicable safety equipment that may be worn during actual respirator use that could interfere with respirator fit. Fit Test Exercise Requirements (1) Employees must perform the following test exercises for all fit testing methods required in the appendices for Respiratory Protection, Part E, except for the controlled negative pressure (CNP) testing. The CNP protocol contains a different fit testing exercise regimen. The employee must perform exercises, in the test environment, in the following ways: (a) Normal breathing. In a normal standing position, without talking, the employee must breathe normally. (b) Deep breathing. In a normal standing position, the employee must breathe slowly and deeply, taking caution so as not to hyperventilate. (c) Turning head side to side. Standing in place, the employees must slowly turn their heads from side to side between the extreme positions on each side, holding their heads at each extreme momentarily so they can inhale at each side. (d) Moving head up and down. Standing in place, the employees must slowly move their heads up and down, inhaling in the up position (when looking toward the ceiling). (e) Talking. The employee must talk out loud slowly and loud enough so as to be heard clearly by the test conductor. The employee can read from a prepared text such as the Rainbow Passage, count backward from 100, or recite a memorized poem or song. Rainbow Passage “When the sunlight strikes raindrops in the air, they act like a prism and form a rainbow. The rainbow is a division of white light into many beautiful colors. These take the shape of a long round arch, with its path high above, and its two ends apparently beyond the horizon. There is, according to legend, a boiling pot of gold at one end. People look, but no one ever finds it. When a man looks for something beyond reach, his friends say he is looking for the pot of gold at the end of the rainbow.” (f) Grimace. The employee must grimace by smiling or frowning. (g) Bending over. Employees must bend at their waist as if they were touching their toes. Jogging in place must be substituted for this exercise in those test environments such as shroud type QNFT or QLFT units that do not permit bending over at the waist. (h) Normal breathing. Repeat exercise (a) for normal breathing. (2) Each test exercise must be performed for one minute except for the grimace exercise, which must be performed for 15 seconds. (3) The Fit Test Technician must question the employee about the comfort of the respirator after completing the test exercises. If the respirator has become unacceptable, the Fit Test Technician must try another model of respirator.
Appendix F:
Filter Cartridge Change Schedule Decision Logic
Purpose:
To document the logic and decision-making behind adopting the current APR filter cartridge change schedule.
Research:
Several studies were researched and analyzed that provides the basis of the APR filter cartridge change schedule. The system in place to warn air purifying respirator wearers of contaminant breakthrough includes using a respirator cartridge replacement schedule based on manufacturer breakthrough test data and an analysis of quantitative post-fire environmental |