Management Instruction EL-810-2009-4 1
Management Instruction
Personal Protective Equipment and
Respiratory Protection Programs
This management instruction (MI) establishes Postal Service policy and
requirements for the use of:
1. Personal protective equipment, including eye, face, head, foot,
and hand protection.
2. Respiratory protection, including voluntary use of filtering
facepieces (dust masks), at Postal Service facilities.
Policy
Regulatory Requirements
The Postal Service will comply with Occupational Safety and Health
Administration (OSHA) standards set forth in Title 29, Code of Federal
Regulations (CFR), Part 1910, Subpart I, Personal Protective
Equipment, especially the following sections:
1910.132, General Requirements.
1910.133, Eye and Face Protection.
1910.134, Respiratory Protection, including Appendix D.
1901.135, Head Protection.
1910.136, Foot Protection.
1910.138, Hand Protection.
Postal Service Policy
The preferred practice of the Postal Service is to avoid and minimize
the use of personal protective equipment (PPE) and respiratory
protection (RP) and to eliminate workplace hazards when feasible. The
following policy applies to the use of PPE and RP:
1. Implement methods to eliminate, control, and reduce workplace
hazards to avoid the use of PPE and RP whenever feasible; such
methods may include, but are not limited to:
a. Use of engineering controls (isolation, enclosures, and
ventilation).
b. Adoption of administrative controls and approved work
practices.
c. Substitution of hazardous materials with non-hazardous
materials when feasible.
d. Incorporation of equipment with safety design features.
Date June 1, 2009
Effective Immediately
Number MI EL-810-2009-4
Obsoletes MI EL-810-2001-1
Unit Safety and Environment
Performance Management
Deborah Giannoni-Jackson
Vice President
Employee Resource Management
CONTENTS
Policy ............................................... 1
Regulatory Requirements ............ . 1
Postal Service Policy ................... . 1
Scope............................................... 2
Personal Protective Equipment
Program ........................................ 2
PPE Program Resources ............. . 2
Responsibilities............................ . 3
Hazard Assessments ................... . 3
Selection Considerations............. . 3
Training ........................................ . 4
Program Evaluation ..................... . 4
Other Requirements .................... . 5
Types of PPE................................... 5
Eye and Face Protection ............. . 5
Head Protection........................... . 6
Foot Protection ............................ . 6
Hand Protection........................... . 7
Protective Clothing ...................... . 8
Respiratory Protection
Programs ...................................... 8
Voluntary Use of Filtering
Facepieces .................................. . 8
Respiratory Protection
Requirements .............................. 10
References...................................... 12
Postal Service.............................. 12
Occupational Safety and
Health Administration .................. 12
Roles and Responsibilities ............ 13
Overall Responsibilities ............... 13
PPE Responsibilities.................... 16
RP Responsibilities...................... 20
2 Management Instruction EL-810-2009-4
2. Perform periodic hazard assessments of the workplace to
determine the presence of hazards that may require the use of
PPE or RP.
3. Establish written PPE and RP programs when required.
4. Provide employees with PPE and RP and ensure their proper use
as identified by the hazard assessment when:
a. Workplace hazards cannot be feasibly removed or
controlled.
b. Workplace hazard controls are being evaluated or
instituted, but are not yet in place.
5. Other than filtering face pieces (i.e., dust masks), no respirator
type may be worn voluntarily. Filtering face pieces may be
voluntarily worn by employees in accordance with OSHA
guidelines.
6. Prohibit employees from entering atmospheres that are:
a. Immediately dangerous to life or health (IDLH);
b. Oxygen-deficient; or
c. Can result in exposure to harmful airborne substances that
exceed acceptable limits.
Scope
This MI applies to the following:
Postal Service managers and supervisors that are subject to
OSHA hazard assessments of the workplace and applicable PPE
and RP requirements.
Safety personnel, managers, and supervisors who perform
hazard assessments of the workplace and administer PPE and
RP programs.
This MI does not cover PPE for electrical work requirements or hearing
conservation (see MI-EL-810-2000-1, Hearing Conservation Programs).
See References on page 12
for additional resources on PPE.
Personal Protective Equipment
Program
Managers must comply with Postal Service PPE policy, 29 CFR 1910,
and any other OSHA standard that requires PPE.
PPE Program Resources
PPE program resources are available on the Safety, Environmental, and
Ergonomic Resources Web site. The resources listed below provide the
information and forms needed to develop a site-specific written PPE
program:
PPE Program Guide.
PPE Decision Tree.
PPE Written Program Template.
CONTENTS
Definitions ....................................... 25
Acronyms ........................................ 28
Attachment 1 — PPE Hazard
Assessment Certification
Work Sheet ................................... 29
Instructions .................................. 29
Assessment Certifications ........... 29
Attachment 2 — PPE Selection
Work Sheet and Certification...... 33
Instructions .................................. 33
Attachment 3 — Guidance
Concerning Filtering
Facepieces.................................... 37
Safe Use of Filtering
Facepieces (Dust Masks)............. 37
Appendix D to 29 CFR
1910.134...................................... 38
Management Instruction EL-810-2009-4 3
PPE Hazard Assessment Worksheet.
PPE Selection Worksheet.
PPE Program Self Evaluation.
PPE Observation Worksheet.
PPE Safety Talk.
To access these resources:
1. Go to http://blue.usps.gov/
.
2. In the left column, click Safety and Environmental Resources.
3. In the right column, under “Safety Programs Resources,” click
OSHA Required Written Program Guides.
4. Click PPE Program Guide.
For additional Postal Service resources, see References on page 12
.
Responsibilities
See Overall Responsibilities (on page 13) and PPE Responsibilities (on
page 16
).
Hazard Assessments
Initial Assessment
Perform an initial hazard assessment to identify safety and health
hazards and determine whether OSHA PPE standards apply to the
workplace. See Attachment 1, PPE Hazard Assessment Certification
Work Sheet (on page 29
), and Attachment 2, PPE Selection Work Sheet
and Certification (on page 33
).
Note: The hazard assessment and PPE selection certification
worksheets must be documented with the facility’s written PPE
program.
When performing a hazard assessment:
Conduct a walk-through survey of the workplace.
Review records such as accident logs, material safety data
sheets, and OSHA Logs.
Evaluate the effectiveness of existing job safety analyses.
Solicit and evaluate observations from supervisors and affected
employees.
Review work tasks, equipment, and facilities.
Reassessment
Hazard reassessments must be performed annually or as necessary,
such as when new processes or equipment are introduced into the
work area or when a review of records indicates that changes to
existing PPE practices may be warranted.
Selection Considerations
Use the hazard assessment process to identify the appropriate PPE for
Postal Service employees (see attachment 2 on page 33
). Describe
PPE selection elements in the facility’s written PPE program. The PPE
selection process must consider the following:
Level and adequacy of protection required.
4 Management Instruction EL-810-2009-4
Fit, comfort, and durability of the PPE.
Provisions for cleaning and sanitizing the PPE.
Compatibility of the PPE with other potential hazards present and
assurance that the PPE itself does not pose an additional hazard.
Training
Resources
The National Center for Employee Development (NCED) provides PPE
training materials and current safety training matrix standards (http://
nced.usps.gov/environ/index.php).
Initial Training
Employees who use PPE must be trained to understand the following:
When PPE is necessary.
What PPE is necessary (i.e., the selection of PPE).
How to properly don, doff, adjust, and wear PPE.
The limitations of PPE.
The proper care, maintenance, useful life, and disposal of PPE.
Retraining
Employees must be retrained on PPE when:
Changes in the workplace render previous training obsolete.
Changes in the types of PPE to be used render previous training
obsolete.
They demonstrate inadequacies in retaining the requisite
understanding or skill to use PPE.
Training Documentation
A description of training elements must be included in the
facility’s written PPE program.
In addition, training documentation must be maintained in the
NCED Learning Management System (LMS) and must include, at
a minimum, the employee’s name, date(s) of training, and training
subject.
Employee PPE safety service talks given at the local level should
be maintained on-site at the facility.
Program Evaluation
PPE evaluation must be performed to ensure proper
implementation of the program. A PPE self-evaluation checklist is
available on the Safety, Environmental, and Ergonomic
Resources Web site (see PPE Program Resources on page 2
).
Describe PPE program evaluation elements and document PPE
evaluations with the facility’s written PPE program.
PPE program evaluations must be performed annually or as
necessary, such as when there is a change that affects the PPE
program.
Management Instruction EL-810-2009-4 5
Other Requirements
Additional PPE program requirements include the following:
Maintain an adequate stock of PPE and PPE cleaning supplies for
employees.
Prohibit employees from using damaged, unapproved, or
defective PPE.
Ensure the adequacy, maintenance, and sanitation of PPE that is
provided voluntarily. (See also Voluntary Use of Filtering
Facepieces on page 8
.)
Types of PPE
Eye and Face Protection
Requirements
Equipment designed to protect the eye and face may include safety
spectacles, goggles, laser safety goggles, and side, face, and welding
shields. Eye and face protection equipment:
Is required for employees when eye or face hazards may be
present from flying particles, molten metal, liquid chemicals,
acids or caustic liquids, chemical gases or vapors, biological
hazards, or potentially harmful light radiation.
Must be worn by employees for protection from radiation during
activities such as welding, torching, soldering, brazing, and other
operations that emit light.
Must comply with 29 CFR 1910.133, which incorporates the
“American National Standard Practice for Occupational and
Educational Eye and Face Protection.”
Face Shields
Face shields do not protect the eyes from impact hazards; they must
be combined with safety glasses or impact goggles to protect eyes
from impact hazards.
For additional information about eye and face protection and work
tasks that require such protection, consult the PPE Program Guide and
MMO-025-04, Personal Protective Equipment. (See References on
page 12
.)
Prescription Safety Glasses
The following policy applies to the use of prescription safety glasses:
The Postal Service must purchase prescription safety glasses for
personnel who:
– Are engaged in occupations or perform tasks with eye
hazards; and
– Cannot use nonprescription safety glasses or other eye
protective equipment.
Employees must furnish prescriptions for safety glasses at their
own expense.
6 Management Instruction EL-810-2009-4
A request for safety glasses must include a copy of the facility’s
PPE Hazard Assessment Certification Work Sheet (attachment 1
on page 29
) signed by the appropriate manager or supervisor and
the assigned safety person.
Prescription safety glasses must be purchased with local funds
from optical companies whose products comply with 29 CFR
1910.133.
Contact Lenses
For information about limitations on wearing contact lenses, consult
MMO-025-04 (see References on page 12
).
Head Protection
Head protection is required for employees who work in areas or at
tasks where there is potential for head injury caused by:
Falling objects.
Striking the head against low, stationary objects.
Bumping the head against a fixed object.
Accidental head contact with electrical hazards.
Any other tasks that pose a risk of head injury.
Protective headgear must comply with 29 CFR 1910.135, which
incorporates the “American National Standard for Personnel
Protection—Protective Headwear for Industrial Workers.”
For additional information about tasks that require head protection,
consult the PPE Program Guide and MMO-025-04 (see References on
page 12
).
Foot Protection
Employees must wear protective footwear when working in areas
where foot injuries are likely to occur due to falling and rolling objects,
objects piercing the sole, or electrical shock through the foot.
In assessing the need for foot protection, review accident logs and
concentrate on locations where potential foot hazards are likely to
exist.
When assessing potential hazards and the need for foot protection in
mail processing operations, refer to Handbook EL-814, Postal
Employee’s Guide to Safety, for primary guidance.
Elements of the current postal safety system (e.g., requiring proper
footwear, training, safety talks, job task observation, aisle marking and
guarding by location, and removal of unsafe equipment) have proven
adequate for controlling foot-related accidents. However, if the need
for additional foot protection (e.g., toe caps, steel-toed shoes,
puncture-proof soles) is determined through the assessment process,
administrative and/or engineering controls must be considered.
If hazards are documented and no engineering or administrative
controls are feasible, provide protective footwear in accordance with
the OSHA standard and the PPE Program Guide (see PPE Program
Resources on page 2
).
Management Instruction EL-810-2009-4 7
Hand Protection
Requirement
Hand protection is required for employees whose hands may be
exposed to hazards such as skin absorption of harmful substances,
severe cuts or lacerations, severe abrasions, punctures, chemical
burns, thermal burns, electrical dangers, and harmful temperature
extremes. Hand protection must meet the standards of 29 CFR
1910.138.
Note: Skin creams and lotions may be used, but they are not
considered PPE and may not be used as hand protection.
Resources
For guidance regarding tasks that require hand protection, consult the
PPE Program Guide, MMO-025-04, and other references listed on
page 12
(Example: MI EL-810-2000-2, Bloodborne Disease Exposure
Control Plans).
Gloves
General
Gloves and other hand protection may be worn as long as their use
does not constitute or create a hazardous condition, e.g., getting
caught in moving machinery or mail processing equipment (including
conveyors).
Manual Handling Operations
The lack of a hazard assessment does not preclude the supply and use
of various gloves or finger protectors for manual handling operations as
long as their use does not constitute or create potentially hazardous
conditions. Routine use of gloves in manual handling operations may or
may not be based on a hazard assessment, as gloves are often used
primarily for comfort, facilitating grip, or cleanliness.
Operating Equipment
A hazard assessment must be performed to determine if hazards are
present that preclude the use of gloves when operating equipment.
There are situations involving powered equipment where the guarding
provided by the equipment provides a safe operational situation for an
ungloved finger or hand, but can result in serious bruising, crushing,
bone fracturing, or amputation of gloved fingers or hands. For this
reason, gloves of any kind (e.g., cotton, latex, vinyl, gauntlet, finger
protectors, or tapes) must not be worn when and where they can get
caught in powered machinery. This includes, but is not limited to,
conveyors, mail processing machines, material handling equipment,
and other equipment with moving parts that potentially have sufficient
energy or conditions that could result in bodily injuries.
Nitrile Gloves
In 2003 the Postal Service issued a nitrile glove wear policy based on a
national hazard assessment performed with OSHA. The policy allows
employees to wear nitrile gloves while working on nationally deployed
equipment.
8 Management Instruction EL-810-2009-4
OSHA determined that the use of nitrile gloves does not contribute to
an increase in the number of hand injuries, based on the following
findings:
Unused portions of the mail processing equipment were found to
be guarded to meet OSHA’s Subpart O (29 CFR 1910) machine-
guarding requirement.
Employees maintained safe distances from unguarded, ingoing
nip points while processing the mail.
Nitrile gloves tend to fit closely.
The Postal Service has developed procedures to remove jammed
papers safely from mail processing equipment in operation.
Therefore, the Postal Service has determined (with OSHA input) that,
when employees are operating nationally deployed Postal Service mail
processing equipment:
The voluntary use of nitrile gloves is allowed.
Employees must always keep hands clear of the ingoing nip
point.
No other kind of glove (including, but not limited to, cloth gloves)
is approved for use.
Latex Gloves
Postal Service employees may not use latex gloves, except in cases
where their use is demonstrated by a specific hazard assessment
determination, such as handling spills of biological specimens or by
medical personnel. When conducting hazard assessments, consider
alternatives to latex gloves due to potential allergic reactions to latex.
Protective Clothing
Conduct a hazard assessment of tasks that might require personal
protective clothing. Clothing and garments worn for general cleanliness
are not considered PPE pursuant to the OSHA standard. For guidance
on acceptable work clothing, see handbook EL-814, IV-A1, Clothing.
Respiratory Protection Programs
Respiratory protection programs comprise two distinct categories:
1. Voluntary use of filtering facepieces (FFPs).
2. All other respiratory protection required by Postal Service policy,
29 CFR 1910.134, and any other OSHA standard.
Voluntary Use of Filtering Facepieces
The phrase voluntary use of a filtering facepiece (FFP) refers to
situations in which:
1. An employee requests an FFP or provides his or her own FFP;
and
2. The employee is not required by OSHA to use an FFP for
protection from hazardous air contaminants.
Management Instruction EL-810-2009-4 9
An FFP, also called a dust mask, is a negative-pressure, particulate
respirator in which:
1. The filter is an integral part of the facepiece; or
2. The entire facepiece is composed of the filtering medium.
Although FFPs are respirators, OSHA places no medical limitations on
their use.
What Is Permitted
Employees may voluntarily use FFPs in accordance with the following
guidelines:
Any Postal Service employee may voluntarily wear an FFP as long
as the FFP itself does not cause a hazardous condition and no
hazardous air contaminants are present.
FFPs do not necessarily protect against exposure to toxic
materials. If an employee needs protection against such
exposure, the Postal Service must supply an appropriate
respirator in accordance with 29 CFR 1910.134.
Local management will provide an FFP upon request or an
employee may use his or her own FFP.
Prior to voluntarily wearing an FFP, whether it is provided by the
Postal Service or by the employee, any employee requesting
wear of an FFP must be given the following required information:
– The safety talk in Attachment 3, Safe Use of Filtering
Facepieces (Dust Masks) on page 37
.
– 29 CFR 1910.134 Appendix D, Mandatory Information for
Employees Using Respirators When Not Required Under the
Standard (attachment 3 on page 38
).
Document that required information was provided to employees
using FFP. (See the Respiratory Protection Program Guide,
described on page 11
).
FFPs supplied by the Postal Service for voluntary use must be
approved by the National Institute for Occupational Safety and
Health (NIOSH).
FFPs worn voluntarily by employees are not subject to the
medical evaluation, cleaning, storage, and maintenance
provisions of the written RP program.
FFPs used voluntarily may not be worn if they are soiled, unclean,
or contaminated, or if they interfere with the employee’s ability to
work safely.
What Is Not Permitted
Employees may not voluntarily use tight-fitting, air-purifying respirators
or supplied air respirators (devices that provide clean breathing air from
uncontaminated sources).
The most commonly used tight-fitting respirators (half-face or full-face)
include elastomeric respirators, which are normally made of a rubber-
like material in which an appropriate filter (i.e., canister) can be
attached. Voluntary use of tight-fitting, air-purifying respirators and
lesser-used supplied air respirators is prohibited.
10 Management Instruction EL-810-2009-4
Guidance for Voluntary Users of FFP
Employees who use FFPs voluntarily must:
1. Read and follow the instructions to ensure a comfortable and
effective fit.
2. Follow recommendations for fit testing and use, storage, and
cleaning; a soiled FFP can cause skin irritation and other health
problems.
3. Not wear an FFP if they experience breathing problems or other
discomfort; they must consult medical or safety personnel if
these occur.
Filtering Facepiece Responsibilities
Respiratory Protection Requirements
Managers must comply with Postal Service policy, 29 CFR 1910.134,
and any other OSHA standard that requires the use of respirators (other
than FFPs used voluntarily). If a written RP program is required, it must
include all elements required by the OSHA RP standard.
Note: Most Postal Service facilities will not be required to
implement an OSHA Written Respiratory Protection Program (29
CFR 1910.134). OSHA’s RP standards are complex. Consult with
the appropriate occupational nurse, medical staff, and safety
personnel before establishing an RP program.
Position Responsibilities
Installation Head
Ensure that requirements, policies, and
procedures for FFPs worn voluntarily are
implemented.
District and Plant Safety
Personnel and Collateral
Duty Facility Safety
Coordinators
If FFPs are used voluntarily for comfort
and are supplied by the Postal Service,
ensure that they are NIOSH-approved;
OSHA advises that NIOSH-approved
FFPs are the most effective.
Assist responsible managers and
supervisors to select appropriate FFP for
voluntary use.
Provide responsible managers and
supervisors with guidance on 29 CFR
1910.134 Appendix D and the safety talk
on voluntary FFPs (attachment 3).
Managers and Supervisors Ensure that any employee who wears an
FFP voluntarily is given the information in
attachment 3, whether the FFP is provided
by the Postal Service or by the employee.
Document and maintain records showing
that employees have received the
information in attachment 3.
Ensure that employees do not wear FFPs
that are soiled, unclean, or contaminated.
Ensure that the FFP itself does not present
a hazardous condition.
Management Instruction EL-810-2009-4 11
RP Program Resources
RP program resources are available on the Safety, Environmental, and
Ergonomic Resources Web site. The resources listed below provide
information and forms to use in developing a site-specific, OSHA-
required written RP program.
Respiratory Protection Program Guide.
Respiratory Decision Tree Written Program Template.
Respiratory Program Self Evaluation.
Filtering Facepiece (Dust Mask) Safety Talk.
Respiratory Safety Talk.
To access these resources:
1. Go to http://blue.usps.gov/
.
2. In the left column, click Safety and Environmental Resources.
3. In the right column, under “Safety Programs Resources,” click
OSHA Required Written Program Guides.
4. Click Respiratory Protection Program Guide.
For additional Postal Service resources, see References on page 12
.
Responsibilities
See Overall Responsibilities (on page 13) and RP Responsibilities (on
page 20
).
Requirements
To ensure Postal Service compliance with applicable RP regulations,
the following activities are required:
Select a Respiratory Protection Program Administrator (RPPA) to
implement, manage, and evaluate the program.
Perform an RP hazard assessment (see attachments 1 and 2).
Perform RP medical evaluations, and establish procedures for
performing medical re-evaluations as needed.
Establish requirements for and perform annual RP fit testing, to
include fit test protocols and retesting.
Establish procedures for RP use, including seal-check
requirements and prohibitions on wear.
Establish procedures for RP maintenance and care, to include
cleaning and disinfecting, storage, inspection, and repair.
Establish standards for the quality of breathing air provided by
the RP (OSHA standard Type 1-Grade D Breathing Air).
Establish procedures for labeling and using NIOSH-approved RP
filters, cartridges, and canisters.
Establish and implement an RP training and information program,
to include requirements for initial training, retraining, annual
training, training topics, training certification and recordkeeping.
Establish procedures for and perform RP evaluations, to include
frequency requirements, effectiveness, corrective measures, and
self-evaluation checklist.
12 Management Instruction EL-810-2009-4
Establish procedures for RP recordkeeping and documentation,
to include retention of medical and fit test records and other
documents related to the written RP program.
Provide respirators, training, and medical evaluations at no cost
to employees when an RP program is necessary. This must
include maintaining an adequate stock of respirators and
cleaning, repair, and maintenance supplies as identified in the
facility’s written RP program.
References
Postal Service
The following handbooks and management instructions are available at
the PolicyNet Web site http://blue.usps.gov/cpim/
:
Handbook EL-801, Supervisor’s Safety Handbook.
Handbook EL-803, Maintenance Employee’s Guide to Safety.
Handbook EL-814, Postal Employee’s Guide to Safety.
MI EL-810-2000-2, Bloodborne Disease Exposure Control Plans.
MI EL-810-2006-3, Response to Hazardous Materials Releases.
MI-EL-810-2008-4, Hazard Communication (HazCom) Program.
MI-EL-810-2009-X*, Confined Space Safety.
*X stands for a number that will be assigned when the MI is published.
The following maintenance management orders (MMOs) are available
at the Maintenance Technical Support Center Web site http://
www.mtsc.usps.gov/:
MMO-025-04, Personal Protective Equipment.
MMO-087-07, Pandemic Flu Cleaning Contingency.
The following resources are available at the Safety, Environmental, and
Ergonomic Resources Web site http://safetytoolkit.usps.gov/resources/
resources.aspx:
PPE and RP Program Guides: see PPE Program Resources on
page 2
, and RP Program Resources on page 11.
Job Safety Analyses for specific jobs and tasks: in the right
column, under “Safety Programs Resources,” click Job Safety
Analysis.
For resources about hurricanes and floods: in the right column,
under “Safety Programs Resources,” click Emergencies, then
click Disaster Response.
Occupational Safety and Health Administration
For federal regulations enforced by OSHA, go to http://www.osha.gov.
In the left column, under “Laws and Standards,” click Standards. This
will take you to regulations in the 29 CFR series.
For OSHA resources on PPE, go to http://www.osha.gov/SLTC/
personalprotectiveequipment/.
For OSHA resources on RP, go to http://www.osha.gov/SLTC/
etools/respiratory/index.html.
Management Instruction EL-810-2009-4 13
Roles and Responsibilities
Overall Responsibilities
Headquarters
Position Responsibilities
Vice President, Employee
Resource Management
(ERM)
Serve as Chief Safety and Environmental
Officer for the Postal Service.
Communicate safety and environmental
policies, including those for PPE and RP.
National Medical Director
and National Occupational
Health Nurse Administrator
(OHNA)
Provide technical support and guidance
on PPE and RP program issues.
Consult on RP medical evaluations and
recordkeeping.
Director, Safety and
Environmental Performance
Management (SEPM)
Establish strategic direction and oversight
of Postal Service safety and environmental
programs, including PPE and RP.
Establish policies and procedures and
interpret standards and other criteria
related to PPE and RP and compliance
with OSHA PPE and RP standards.
Provide guidance about PPE and RP to
Headquarters functional areas and field
managers and support functions.
Engineering Evaluate, design, and engineer equipment,
processes, and systems, including
ventilation systems, where feasible, to
eliminate the need for PPE and RP.
Maintenance Policies and
Programs, Engineering
Establish procedures (i.e., current MMO)
for implementing PPE and RP for
maintenance personnel in accordance
with Postal Service policy.
Manager, Vehicle
Operations, Delivery
Establish procedures for implementing
PPE and RP for vehicle maintenance
operations in accordance with Postal
Service policy.
National Center for
Employee Development
(NCED)
Provide PPE and RP training and
resources.
Update training programs as necessary.
All Employees Wear PPE and respiratory protection when
required and attend training when
scheduled. See handbook EL-814, IV,
Personal Safety and Protective
Equipment.
14 Management Instruction EL-810-2009-4
Areas
Performance Clusters
Position Responsibilities
Managers of Human
Resources
Monitor and evaluate area PPE and RP
programs.
Medical Director and
National Occupational
Health Nurse Administrator
(OHNA)
Provide technical support and guidance
on PPE and RP program issues.
Consult on RP medical evaluations and
recordkeeping.
Managers of Safety Provide technical support and guidance
on PPE and RP program issues.
Evaluate and review alternatives to PPE
and RP use, where feasible.
All Employees Wear PPE and respiratory protection when
required and attend training when
scheduled. See handbook EL-814, IV,
Personal Safety and Protective
Equipment.
Position Responsibilities
District Managers Ensure that PPE and RP programs are
established and implemented.
Installation Heads Ensure that requirements, policies, and
procedures for PPE and RP programs are
established and implemented.
Ensure that sufficient funding and
personnel are available to implement PPE
and RP programs effectively.
Maintain awareness and knowledge of
tasks and operations that require PPE and
RP.
Designate a qualified RPPA if an RP
program is required.
Managers and Supervisors
Provide employees who request FFPs
voluntarily with NIOSH-approved FFP
respirators.
Provide employees who voluntarily use
FFP respirators with the information
required to use them properly and
document that the information was
provided.
Comply with the current MMO on PPE and
RP.
Ensure that hazard assessments are
periodically performed for OSHA
applicability to the PPE and RP programs.
Evaluate and review alternatives to PPE
and RP.
Coordinate with and assist the designated
facility RPPA to implement and administer
the RP program.
Management Instruction EL-810-2009-4 15
Managers and Supervisors
(continued)
Ensure that written PPE and RP programs
are implemented and administered for
large offices, plants, bulk mail centers,
and vehicle maintenance facilities (VMFs)
when required.
Consult with safety and medical staff
when selecting appropriate PPE or RP.
Maintain awareness of tasks under their
supervision that require PPE or RP.
Ensure employee adherence to PPE and
RP requirements.
Ensure that appropriate PPE or RP is
provided and properly cleaned,
maintained, inspected, and stored.
Ensure that employees wearing PPE or RP
are trained and that training records are
documented in the LMS.
Ensure that PPE and RP evaluations are
performed annually or as necessary;
document the evaluations.
Ensure that all required PPE and RP
program documents and records are
maintained.
District Manager, Safety Guide, support, and monitor PPE and RP
programs.
Assist safety personnel to implement and
administer written PPE and RP programs.
Assist district, plant, and collateral duty
safety officers to implement and
administer PPE and RP programs.
Evaluate and review alternatives to use of
PPE and RP.
District and Plant Safety
Personnel
Provide technical support and guidance
on PPE and RP program issues.
Consult with responsible medical office on
PPE and RP programs.
Provide assistance to ensure that:
– Employees who voluntarily request FFP
are given NIOSH-approved FFP
respirators.
– Employees who voluntarily use FFP
respirators are given the required
information.
– Hazard assessments are performed
periodically to determine OSHA
applicability to the PPE and RP
programs.
Evaluate and review alternatives to PPE
and RP use.
Coordinate with and assist the designated
facility RPPA to implement and administer
the RP program.
Position Responsibilities
16 Management Instruction EL-810-2009-4
PPE Responsibilities
For responsibilities related to program administration, see Personal
Protective Equipment Program on page 2
.
District and Plant Safety
Personnel
(continued)
Assist managers and supervisors to
implement and administer written PPE and
RP programs for large offices, plants, bulk
mail centers, and VMFs.
Assist collateral duty facility safety
coordinators to implement and administer
written PPE and RP programs in smaller
offices and facilities.
Observe the use of PPE and RP during
routine inspections; report deficiencies.
Collateral Duty Facility
Safety Coordinators
Consult with district and plant safety
personnel and the appropriate medical
office on PPE and RP program
requirements.
Consult with district and plant safety
personnel to:
– Perform hazard assessments
periodically to determine OSHA
applicability to the PPE and RP
programs.
– Ensure that the required PPE and RP
programs are implemented and
administered in smaller offices and
facilities.
Coordinate with and assist the designated
facility RPPA if an RP program is
necessary.
All Employees Wear PPE and respiratory protection when
required and attend training when
scheduled. See handbook EL-814, IV,
Personal Safety and Protective
Equipment.
Position Responsibilities
Installation Heads
Ensure that requirements, policies, and
procedures for PPE programs are
implemented, maintained, and evaluated.
Provide sufficient funding and personnel
to implement PPE programs effectively.
Maintain awareness and knowledge of
tasks and operations in the facilities that
require PPE and RP.
Position Responsibilities
Management Instruction EL-810-2009-4 17
Managers and Supervisors Perform or assist safety personnel with
hazard assessments to determine OSHA
applicability to the PPE program
(attachment 1).
Ensure that a hazard assessment is
completed, documented, and maintained
in the facility to certify compliance with the
OSHA standard (attachment 1).
Evaluate and review alternatives to the
use of PPE where feasible.
If PPE is deemed necessary (as
determined by a hazard assessment or
other evaluation), perform, complete,
maintain, and document the PPE selection
review for the hazard identified
(attachment 2).
Review and evaluate the effectiveness of
the PPE selected periodically; update PPE
as necessary.
Implement and administer written PPE
programs for large offices, plants, bulk
mail centers, and VMFs.
Consult with collateral duty facility safety
coordinators on PPE requirements for
smaller offices.
Maintain awareness of tasks under their
supervision that require PPE.
Ensure employee adherence to PPE
requirements.
Monitor operations to determine that
changes to existing PPE practices may be
warranted due to:
– New processes or equipment
introduced into the workplace.
– Results of a review of records.
Consult with affected employees, safety,
and medical staff.
Ensure that all employees (including new
hires) who need or use PPE receive
appropriate training.
Ensure that retraining is performed when
workplace changes or changes in PPE
render previous training obsolete.
Ensure retraining for employees whose
inadequacies in knowledge or use of
assigned PPE indicate that they have not
retained the requisite understanding or
skill.
Document all training and retraining.
Position Responsibilities
18 Management Instruction EL-810-2009-4
Managers and Supervisors
(continued)
Ensure that all employee PPE training
records are entered in the LMS.
Note: To certify compliance with the OSHA
standard, the training record must include
the name of the employee trained, date of
training, and subject of training.
Ensure the adequacy of all PPE, whether
provided by the employee or by the Postal
Service, to include proper maintenance,
storage, care, and sanitation.
Ensure that damaged or defective PPE is
not used.
Ensure the availability of appropriate PPE,
accessories, and supplies.
Evaluate or assist safety personnel to
evaluate the PPE program annually or
whenever there is a change that affects
the PPE program.
Ensure that hazard assessments
(attachment 1), PPE selection
documentation (attachment 2), training
records, and PPE evaluations are
completed, maintained, and documented
in the facility’s written PPE program.
Ensure that the facility’s written PPE
program is reviewed and updated
annually or as necessary.
District and Plant Safety
Personnel
Assist the responsible manager or
supervisor and the collateral duty safety
coordinators with hazard assessments to
determine OSHA applicability to the PPE
program (attachment 1).
Ensure that hazard assessments are
completed, documented, and maintained
in the facility to certify compliance with the
OSHA standard (attachment 1).
Assist responsible managers and
supervisors to implement and administer
a written PPE program for large offices,
plants, bulk mail centers, and VMFs.
Assist collateral duty facility safety
coordinators to implement and administer
written PPE programs in smaller offices
and facilities.
Evaluate and review alternatives to the
use of PPE where feasible.
If PPE is deemed necessary (as
determined by a hazard assessment or
other evaluation), assist with performance
of the PPE selection review for the hazard
identified (attachment 2).
Position Responsibilities
Management Instruction EL-810-2009-4 19
District and Plant Safety
Personnel
(continued)
Assist with PPE selection, wear, use, care,
and maintenance.
Assist with PPE training and with
monitoring the integrity of the training
program.
Monitor PPE adequacy, condition, wear,
care, and maintenance during routine
inspections; report deficiencies to
responsible managers and supervisors
immediately.
Ensure that PPE training records are
entered in the LMS by responsible
managers, supervisors, and collateral duty
facility safety coordinators.
Note: To certify compliance with the OSHA
standard, the training record must include
the name of the employee trained, date of
training, and subject of training.
Assist with evaluation of the PPE program
annually or whenever there is a change
that affects the program.
Ensure that hazard assessments
(attachment 1), selection documentation
(attachment 2), training records, and
evaluations are maintained and
documented in the facility’s written PPE
program.
Assist with review and update of the
facility’s written PPE program annually or
as necessary.
Collateral Duty Facility
Safety Coordinators
Consult with district and plant safety
personnel, managers and supervisors,
and the appropriate medical office on PPE
program requirements.
Perform or assist district and plant safety
personnel with hazard assessments to
determine OSHA applicability to the PPE
program (attachment 1).
Maintain awareness of tasks that require
PPE.
Implement and administer required PPE
programs in smaller offices and facilities in
consultation with district and plant safety
personnel.
In consultation with district and plant
safety personnel, monitor operations to
determine that changes to existing PPE
practices may be warranted due to:
– New processes or equipment
introduced into the workplace.
– Results of a review of records.
Position Responsibilities
20 Management Instruction EL-810-2009-4
RP Responsibilities
For responsibilities related to program administration, see Respiratory
Protection Programs on page 8
.
Medical Staff Consult with the safety office, responsible
managers and supervisors, and affected
employees on medical and health issues
related to PPE.
NCED
Provide PPE training and resources.
Update training programs as necessary.
Position Responsibilities
Installation Heads Designate a qualified RPPA.
Ensure that requirements, policies, and
procedures for RP programs are
implemented, maintained, and evaluated.
Provide sufficient funding and personnel
to implement the RP program effectively.
Maintain awareness and knowledge of
tasks and operations in their facilities that
require RP.
Prohibit employees from entering or
performing tasks in IDLH or oxygen-
deficient atmospheres.
Facility RPPA (Appointed by
Installation Head)
Prepare and administer all aspects of the
facility’s written RP program.
Provide technical advice and consultative
assistance to responsible managers and
supervisors regarding the RP program.
Conduct hazard assessments with
responsible managers and supervisors,
safety personnel, and medical staff
(attachment 1).
Ensure that a hazard assessment is
completed, documented, and maintained
in the facility to certify compliance with the
OSHA standard (attachment 1).
If an RP is deemed necessary (as
determined by the hazard assessment or
other evaluation), perform, complete,
maintain, and document the NIOSH-
certified RP selection for the hazard
identified (attachment 2).
Periodically review and evaluate the
effectiveness of the RP selected; update if
necessary.
Coordinate with the responsible medical
office regarding medical evaluations,
follow-up examinations, medical
determinations, recordkeeping, and
related requirements.
Position Responsibilities
Management Instruction EL-810-2009-4 21
Facility RPPA (Appointed by
Installation Head)
(continued)
Ensure that no employee wears RP
without a medical evaluation.
Coordinate or conduct the required initial
and annual qualitative or quantitative
respiratory fit testing; perform additional fit
tests if conditions affecting respirator fit
change.
Document all fit-testing activities.
Monitor proper use and wear of
respirators in accordance with the
facility’s written RP program.
Monitor to ensure that no employee wears
a tight-fitting respirator.
Ensure proper maintenance, repair,
storage, and care of respirators, to include
inspection, cleaning, and disinfection.
Ensure that all RP equipment (filters,
cartridges, and canisters) used in the
workplace is labeled and color-coded with
the appropriate NIOSH-approved labels.
Ensure that employees who require or use
RP receive initial training prior to use and
annual retraining.
Ensure that retraining is performed when
workplace changes or changes in the type
of RP used render previous training
obsolete.
Ensure retraining for employees whose
inadequacies in knowledge or use of
assigned PPE indicate that they have not
retained the requisite understanding or
skill.
Ensure that employee RP training records
are entered in the LMS.
Note: To certify compliance with the OSHA
standard, the training record must include
the name of the employee trained, date of
training, and subject of training.
Evaluate the RP program with the
responsible managers and supervisors,
safety personnel, and medical staff
annually or whenever there is a change
that affects the RP program; document
the evaluation.
Review and update the written RP
program with responsible managers and
supervisors, safety personnel, and
medical staff.
Maintain all documentation required by
the program (the facility’s written RP
program, training records, medical
evaluations, fit tests, hazard assessments,
respiratory selection criteria, and
evaluations).
Position Responsibilities
22 Management Instruction EL-810-2009-4
District and Safety Plant
Personnel
Prohibit employees from entering or
performing tasks in IDLH or oxygen-
deficient atmospheres.
Provide technical support and guidance to
the RPPA in implementing the RP
program.
Assist the RPPA, responsible managers
and supervisors, safety personnel, and
medical staff to conduct hazard
assessments (attachment 1).
Ensure that a hazard assessment is
completed, documented, and maintained
in the facility to certify compliance with the
OSHA standard.
Review and evaluate alternatives to the
use of respirators where feasible.
Assist the RPPA, managers and
supervisors, and medical staff to
implement and administer the facility’s
written RP program.
If RP is deemed necessary (as determined
by a hazard assessment or other
evaluation), assist the RPPA to select the
appropriate NIOSH-certified respirator for
the identified hazard (attachment 2).
Periodically review and evaluate the
effectiveness of the RP selected; update if
necessary.
Ensure that employees do not wear tight-
fitting respirators.
Assist the RPPA to consult with the
responsible medical office regarding
medical evaluations, follow-up
examinations, medical determinations,
recordkeeping, and related requirements.
Assist the RPPA to conduct initial and
annual qualitative or quantitative
respiratory fit testing; document testing.
Monitor the performance of additional fit
tests if conditions affecting respirator fit
change.
Monitor the use and wear of respirators in
the facility during routine inspections;
report deficiencies immediately to the
RPPA and responsible manager and
supervisors.
Assist with PPE training and with
monitoring the integrity of the training
program.
Position Responsibilities
Management Instruction EL-810-2009-4 23
District and Safety Plant
Personnel
(continued)
Ensure that the RPPA enters RP training
records in the LMS.
Note: To certify compliance with the OSHA
standard, the training record must include
the name of the employee trained, date of
training, and subject of the training.
Assist the RPPA, responsible managers
and supervisors, safety personnel, and
medical staff to:
– Perform RP evaluations annually or
whenever there is a change that affects
the RP program,
– Review and update the facility’s written
RP program.
– Maintain the documents required for the
program (the facility’s written RP
program, training records, medical
evaluations, fit tests, hazard
assessments, respiratory selection
criteria, and evaluations).
Managers and Supervisors
Prohibit employees from entering or
performing tasks in IDLH or oxygen-
deficient atmospheres.
Assist the RPPA, safety personnel, and
medical staff to conduct hazard
assessments (attachment 1).
Ensure that a hazard assessment is
completed, documented, and maintained
in the facility to certify compliance with the
OSHA standard.
Maintain awareness of tasks under their
supervision that require RP.
Ensure employee adherence to RP
requirements.
Monitor work areas and operations to
identify potential respiratory hazards and
consult with the RPPA, safety personnel,
and medical staff for employees under
their supervision.
If RP is deemed necessary (as determined
by a hazard assessment or other
evaluation), assist the RPPA to select the
appropriate NIOSH-certified respirator for
the identified hazard (attachment 2).
Periodically review and evaluate the
effectiveness of the RP selected; update if
necessary.
Work with the RPPA to ensure that the
written RP program is implemented and
administered properly.
Position Responsibilities
24 Management Instruction EL-810-2009-4
Managers and Supervisors
(continued)
Ensure that employees under their
supervision who need or use RP have
received:
– Medical clearance prior to use,
– Initial and annual fit tests and retests, as
necessary.
– Initial training prior to use and annual
retraining.
Ensure that retraining for employees under
their supervision is conducted when
workplace changes or changes in RP
render previous training obsolete.
Ensure retraining for employees whose
inadequacies in knowledge or use of
assigned RP indicate that they have not
retained the requisite understanding or
skill.
Document all training and retraining.
Ensure that RP training records for
employees under their supervision are
entered in the LMS.
Note: To certify compliance with the OSHA
standard, the training record must include
the name of the employee trained, date of
training, and subject of training.
Monitor to ensure that employees under
their supervision do not wear tight-fitting
respirators.
Work with the RPPA to ensure that
employees under their supervision:
– Have a sufficient supply of NIOSH-
certified respirators and NIOSH-
approved equipment, accessories, and
other supplies.
– Inspect, use, clean, disinfect, maintain,
repair, and store RP properly.
Work with the RPPA, responsible
managers and supervisors, safety
personnel, and medical staff to ensure
that they:
– Perform RP evaluations annually or
whenever there is a change that affects
the RP program.
– Review and update the facility’s written
RP program when required.
– Maintain required program documents
(the facility’s written RP program,
training records, medical evaluations, fit
tests, hazard assessments, respiratory
selection criteria, and evaluations).
Position Responsibilities
Management Instruction EL-810-2009-4 25
Definitions
Air-purifying respirator. A respirator with an air-purifying filter,
cartridge, or canister that removes specific air contaminants by passing
ambient air through the air-purifying element.
Assigned protection factor (APF). The workplace level of respiratory
protection that a respirator or class of respirators is expected to
provide to employees when the employer implements a continuing,
effective respiratory protection program.
Collateral Duty Facility
Safety Coordinators
Prohibit employees from entering or
performing tasks in IDLH or oxygen-
deficient atmospheres.
Consult with the RPPA, district and plant
safety personnel, and the appropriate
medical office on RP program
requirements.
Assist the RPPA, managers and
supervisors, district and plant safety
personnel, and medical staff to conduct
and document hazard assessments
(attachment 1).
Maintain awareness of tasks that require
RP programs.
Assist the RPPA to implement and
administer RP programs in smaller offices
and facilities in consultation with district
and plant safety personnel.
In consultation with district and plant
safety personnel, monitor operations to
determine that changes to existing RP
practices may be warranted due to:
– New processes or equipment
introduced into the workplace.
– Results of a review of records.
Medical Staff
Assist the RPPA, responsible managers
and supervisors, and safety personnel to
conduct hazard assessments (attachment
1).
Coordinate and assist with RP medical
evaluations, fit testing, and recordkeeping
requirements.
Assist the RPPA, responsible managers
and supervisors, and safety personnel to
conduct annual RP evaluations.
Consult with the RPPA, responsible
managers and supervisors, affected
employees, and safety on medical and
health issues related to RP.
NCED Provide PPE and RP training and
resources.
Update training programs as necessary.
Position Responsibilities
26 Management Instruction EL-810-2009-4
Atmosphere-supplying respirator. A respirator that supplies the
respirator user with breathing air from a source independent of the
ambient atmosphere, and includes supplied-air respirators (SARs) and
self-contained breathing apparatus (SCBA) units.
Canister or cartridge. A container with a filter, sorbent, or catalyst, or
combination of these items, which removes specific contaminants from
the air passed through the container.
Demand respirator. An atmosphere-supplying respirator that admits
breathing air to the facepiece only when a negative pressure is created
inside the facepiece by inhalation.
Elastomeric respirator. Normally made of a rubber-like material in
which an appropriate filter (i.e., canister) can be attached.
Emergency situation. Any occurrence such as (but not limited to)
equipment failure, rupture of containers, or failure of control equipment
that may or does result in an uncontrolled significant release of an
airborne contaminant.
Employee exposure. Exposure to a concentration of an airborne
contaminant that would occur if the employee were not using
respiratory protection.
End-of-service-life indicator (ESLI). A system that warns the
respirator user of the approach of the end of adequate respiratory
protection, for example, that the sorbent is approaching saturation or is
no longer effective.
Escape-only respirator. A respirator intended to be used only for
emergency exit.
Filter or air purifying element. A component used in respirators to
remove solid or liquid aerosols from the inspired air.
Filtering facepiece (dust mask). A negative pressure particulate
respirator with a filter as an integral part of the facepiece or with the
entire facepiece composed of the filtering medium.
Fit factor. A quantitative estimate of the fit of a particular respirator to a
specific individual, and typically estimates the ratio of the concentration
of a substance in ambient air to its concentration inside the respirator
when worn.
Fit test. The use of a protocol to qualitatively or quantitatively evaluate
the fit of a respirator on an individual. (See qualitative fit test and
quantitative fit test below.)
Helmet. A rigid respiratory inlet covering that also provides head
protection against impact and penetration.
High efficiency particulate air (HEPA) filter. A filter that is at least
99.97% efficient in removing monodisperse particles of 0.3
micrometers in diameter. The equivalent NIOSH 42 CFR 84 particulate
filters are the N100, R100, and P100 filters.
Hood. A respiratory inlet covering that completely covers the head and
neck and may also cover portions of the shoulders and torso.
Immediately dangerous to life or health (IDLH). An atmosphere that
poses an immediate threat to life, would cause irreversible adverse
health effects, or would impair an individual's ability to escape from a
dangerous atmosphere.
Management Instruction EL-810-2009-4 27
Interior structural firefighting. The physical activity of fire
suppression, rescue or both, inside of buildings or enclosed structures
which are involved in a fire situation beyond the incipient stage. (See 29
CFR 1910.155).
Loose-fitting facepiece. A respiratory inlet covering that is designed
to form a partial seal with the face.
Maximum use concentration (MUC). The maximum atmospheric
concentration of a hazardous substance from which an employee can
be expected to be protected when wearing a respirator, and is
determined by the assigned protection factor of the respirator or class
of respirators and the exposure limit of the hazardous substance. The
MUC can be determined mathematically by multiplying the assigned
protection factor specified for a respirator by the required OSHA
permissible exposure limit, short-term exposure limit, or ceiling limit.
When no OSHA exposure limit is available for a hazardous substance,
an employer must determine an MUC on the basis of relevant available
information and informed professional judgment.
Negative pressure respirator (tight fitting). A respirator in which the
air pressure inside the facepiece is negative during inhalation with
respect to the ambient air pressure outside the respirator.
Oxygen deficient atmosphere. An atmosphere with an oxygen
content below 19.5% by volume.
Physician or other licensed health care professional (PLHCP). An
individual whose legally permitted scope of practice (i.e., license,
registration, or certification) allows him or her to independently provide,
or be delegated the responsibility to provide, some or all of the health
care services required by paragraph (e) of this section.
Positive pressure respirator. A respirator in which the pressure inside
the respiratory inlet covering exceeds the ambient air pressure outside
the respirator.
Powered air-purifying respirator (PAPR). An air-purifying respirator
that uses a blower to force the ambient air through air-purifying
elements to the inlet covering.
Pressure demand respirator. A positive pressure atmosphere-
supplying respirator that admits breathing air to the facepiece when the
positive pressure is reduced inside the facepiece by inhalation.
Qualitative fit test (QLFT). A pass/fail fit test to assess the adequacy
of respirator fit that relies on the individual's response to the test agent.
Quantitative fit test (QNFT). An assessment of the adequacy of
respirator fit by numerically measuring the amount of leakage into the
respirator.
Respiratory inlet covering. That portion of a respirator that forms the
protective barrier between the user’s respiratory tract and an air-
purifying device or breathing air source, or both. It may be a facepiece,
helmet, hood, suit, or a mouthpiece respirator with nose clamp.
Self-contained breathing apparatus (SCBA). An atmosphere-
supplying respirator for which the breathing air source is designed to
be carried by the user.
28 Management Instruction EL-810-2009-4
Service life. The period of time that a respirator, filter or sorbent, or
other respiratory equipment provides adequate protection to the
wearer.
Supplied-air respirator (SAR) or airline respirator. An atmosphere-
supplying respirator for which the source of breathing air is not
designed to be carried by the user.
Tight-fitting facepiece. A respiratory inlet covering that forms a
complete seal with the face.
User seal check. An action conducted by the respirator user to
determine if the respirator is properly seated to the face.
Acronyms
ANS American National Standard
APF assigned protection factor
CFR Code of Federal Regulations
ERM Employee Resource Management
ESLI end-of-service-life indicator
FFP filtering facepiece
HEPA high efficiency particulate air
IDLH immediately dangerous to life or health
JSA Job Safety Analysis
LMS Learning Management System
MI management instruction
MMO maintenance management order
MSDS Material Safety Data Sheet
MTSC Maintenance Technical Support Center
MUC maximum use concentration
NCED National Center for Employee Development
NIOSH National Institute for Occupational Safety
and Health
OHNA Occupational Health Nurse Administrator
OSHA Occupational Safety and Health
Administration
PAPR powered air-purifying respirator
PLHCP physician or other licensed health care
professional
PPE personal protective equipment
QLFT qualitative fit test
QNFT quantitative fit test
RP respiratory protection
RPPA Respiratory Protection Program
Administrator
SAR supplied-air respirator
SCBA self-contained breathing apparatus
VMF vehicle maintenance facility
Management Instruction EL-810-2009-4 29
Attachment 1 — PPE Hazard Assessment Certification Work
Sheet
Instructions
Completion of a hazard assessment must be certified in accordance with the OSHA standard listed in 29 CFR
1910, Sections 132, 133, 135, 136, and 138, concerning personal protective equipment (PPE).
Refer to the Personal Protective Equipment Program Guide available in the Safety Toolkit; refer to Subpart I,
Appendix B, of the OSHA Standard.
This work sheet describes and provides a format to document a two-part process for hazard assessment:
Part 1. Review of Records
The full-time or collateral duty facility safety coordinator responsible for the facility conducts a review of
records by checking the following:
1. Facility accident data, using the installation’s OSHA Form 300 Log or electronic equivalent.
2. Safety Toolkit Hazard Log and Summary.
3. Material Safety Data Sheets (MSDSs) for chemicals in use and equipment manufacturers’
recommendations.
4. Other pertinent records.
Depending on the size and complexity of the facility or operation, the review can cover the entire facility,
groups of operations, or specific operations.
After completing Part 1, the manager or supervisor works with the safety professional to complete part 2.
Part 2. Walk-through Survey and Risk Determination
The walk-through survey is conducted and documented by the safety representative and the manager or
supervisor of the location or operation being assessed. Managers and supervisors should review existing Job
Safety Analyses (JSAs) and verify that the hazards identified are correct.
At a minimum, the manager or supervisor completes the Location/Operations and Potential Hazard portions.
Safety personnel will consult with the manager or supervisor about the risk category and potential hazards.
Assessment Certifications
Both the manager or supervisor and the safety professional must sign the hazard assessment to
certify it.
Assessment certifications must be retained in the safety office for the facility or, in smaller offices, by the
collateral duty facility safety coordinator.
Certifications must be reviewed annually or when conditions in the workplace change.
30 Management Instruction EL-810-2009-4
Part 1. Records Review
Review the facility accident data, using the OSHA Form 300 Log, the Safety Toolkit Hazard Log and
Summary, and other pertinent records (such as MSDSs) for 3 previous years. Look for injuries or illnesses that
could have been prevented by PPE if it were properly selected and worn.
Use the guidance provided in the Employee and Labor Relations Manual, 821.3, Accident Analysis.
The analysis may cover the entire facility, operation by operation, or selected operations and locations. Use
this checklist for analysis or create your own. Whichever method you use, share the review of records with
supervisors so that they can examine and use them in their assessments of the workplace.
Reviewer: _________________________________ Date: _________________
Records Review Findings
OSHA Form 300 Log
Safety Toolkit Hazard Log
MSDSs
Comments:
Management Instruction EL-810-2009-4 31
Part 2. Walk-through Survey and Risk Determination
The safety representative and the supervisor or manager should walk through the locations and operations for
which they are responsible, using the review of PPE records (page 30
of this attachment or locally created
sheet), JSAs, etc., to assist in identifying potential hazards and risks.
Facility PPE Hazard Assessment Work Sheet
Facility: ___________________________________________________ Date: ______________
Safety Certification: __________________________ _______________ Date: ______________
(Full-time or Collateral Duty Facility Safety Coordinator)
Safety Certification: _________________________________________ Date: ______________
(Manager or Supervisor)
Location/Operations Potential Hazard
1
Risk Code
2
Remarks
32 Management Instruction EL-810-2009-4
1. Potential Hazard — Use these codes:
I=impact
P=penetration
COM = compression (rollover)
F = falling objects
CHEM/BIO = chemical/biological hazards
H=heat
HD = harmful dust (eye hazard)
L = light or radiation
E = electrical
2. Risk Code — Use the following guidelines for determining if employees must be supplied with PPE. These are
guidelines and require the judgment of the safety professional. Enter one of the codes below:
1 = High Risk. If any of the following conditions exist, PPE must be supplied and worn:
a. Observed conditions at the time of the walk-through clearly warrant PPE; PPE has been used historically
based on known risks (e.g., fallen or falling objects are observed, a chemical is routinely used, or welding
is performed); or an OSHA standard requires PPE.
b. The operation or task has a history of accidents or injuries associated with a hazard that cannot be
controlled by engineering controls.
2 = Moderate Risk. If any of the following conditions are met, PPE must be supplied and worn:
a. A potential hazard is noted due to the nature of the operation but is not directly observed during the
walk-through. Employees have reported hazards using PS Form 1767, Report of Hazard, Unsafe
Condition, or Practice (check the Safety Toolkit Hazard Log).
b. Accident analysis indicates a reasonable potential for injury.
3 = Minimal Risk. If either of the following conditions apply, PPE may not be required:
a. Hazards are noted but are controlled by engineering methods (e.g., guarding, interlocks) that prevent
employee injury.
b. No history of injuries is associated with this operation.
Review conditions and accident data for this category annually or if conditions change.
Management Instruction EL-810-2009-4 33
Attachment 2 — PPE Selection Work Sheet and Certification
Instructions
Completing the PPE Selection Record
When potential hazards that require PPE are identified by a hazard assessment (attachment 1):
The safety professional completes the PPE Selection Record using the appropriate part, e.g., eye and
face, hand, foot, or head protection.
The safety professional (full-time or collateral duty facility safety coordinator) should review the Job
Safety Analysis (JSA) for the operation or task with the manager or supervisor and ensure that the
hazards noted and PPE selected are included in the JSA.
Selecting PPE
To select PPE, use the tables provided in OSHA standard 29 CFR 1910, sections 132, 133, 135, 136, and 138,
and Appendix B to Subpart I, Non-mandatory Compliance Guidelines for Hazard Assessment and Personal
Protective Equipment Selection. Consult the PPE Program Guide, which provides tables from the OSHA
standard and other references to help you select appropriate PPE based on the hazards identified. Also see
the guidance supplied in the footnotes to the PPE Selection Record.
Certifications
Certifications must be retained in the safety office for the facility or, in smaller offices, by the collateral duty
facility safety coordinator. The certifications must be reviewed annually or when conditions in the workplace
change.
34 Management Instruction EL-810-2009-4
PPE Selection Work Sheet and Certification
Safety Certification: __________________________________________ Date: ______________
(Full-time or Collateral Duty Facility Safety Coordinator)
Safety Certification: __________________________________________ Date: ______________
(Manager or Supervisor)
PPE Selection Record
Location/Operation Potential Harzard
1
Type of PPE
2
Risk Code
3
PPE Selected
4
Management Instruction EL-810-2009-4 35
1. Potential Hazard — Use these codes for all PPE selection except hand protection:
I=impact
P=penetration
COM = compression (rollover)
F = falling objects
CHEM/BIO = chemical/biological hazards
H=heat
HD = harmful dust (eye hazard)
L = light or radiation
E = electrical
Use these codes for selecting PPE for hand protection hazards:
T=toxic
C = severe cuts or lacerations
A = severe abrasions
P = punctures
COR = corrosives (chemical burns)
B = thermal burns
TEMP = temperature extremes
2. Type of PPE — The following provides guidance on types of PPE:
a. Eye and Face Protection. Consult Appendix B of the OSHA standard and the Personal Protective
Equipment Program Guide for details on eye and face protection.
b. Head Protection. Consult Appendix B of the OSHA standard and the Personal Protective Equipment
Program Guide for details on head protection.
The OSHA standard does not specifically address bump caps, but they should be provided as necessary in
accordance with existing policy. Bump caps may be listed here for purposes of tracking their use.
Additionally, OSHA may at some future date consider protection from impact with fixed objects to be within
the purview of the standard.
Under “PPE Selected” indicate the class of electrical protection if necessary.
c. Hand Protection. Select hand protection appropriate to the hazard. Gloves used in manual handling
operations for comfort, improving grip, or cleanliness are not normally listed as PPE. Provide information
about the PPE selected, to include the glove materials, e.g., butyl rubber or viton.
d. Foot Protection. Select foot protection appropriate to the hazard. Employees, contractors, customers, and
others visiting or observing the operation are not normally required to wear foot protection unless their
activities put them directly at risk.
36 Management Instruction EL-810-2009-4
3. Risk Code — Follow these guidelines for determining if employees must use PPE. These guidelines require the
judgment of the safety professional. Enter one of the codes below:
1 = High Risk. If any of the following conditions exist, PPE must be supplied and worn:
a. Observed conditions at the time of the walk-through clearly warrant PPE; PPE has been used historically
based on known risks (e.g., fallen or falling objects are observed, a chemical is routinely used, or welding
is performed); or an OSHA standard requires PPE.
b. The operation or task has a history of accidents or injuries associated with a hazard that cannot be
controlled by engineering controls.
2 = Moderate Risk. If any of the following conditions are met, PPE must be supplied and worn:
a. A potential hazard is noted due to the nature of the operation but is not directly observed during the
walkthrough. Employees have reported hazards (e.g., on PS Form 1767).
b. Accident analysis indicates a reasonable potential for injury.
3 = Minimal Risk. If either of the following conditions apply, PPE may not be required:
a. Hazards are noted but are controlled by engineering methods (e.g., guarding, interlocks) that prevent
employee injury.
b. No history of injuries is associated with this operation.
Review conditions and accident data for this category annually or if conditions change.
4. PPE Selected — Provide sufficient detail to ensure that the PPE is approved (that is, that it meets the OSHA
standard) and is adequate to protect personnel from the hazard, and that its use can easily be checked by
referring to this information. Provide shade numbers as necessary for protective eye wear (welding helmets).
Management Instruction EL-810-2009-4 37
Attachment 3 — Guidance Concerning Filtering Facepieces
Safe Use of Filtering Facepieces (Dust Masks)
The following information must be shared with all employees who voluntarily wear a filtering facepiece (dust
mask) on the job:
1. The Occupational Safety and Health Administration (OSHA) requires that you be given the information
provided on the second page of this attachment if you wear a filtering facepiece (FFP), also known as a
dust mask, while working.
2. This information applies whether the Postal Service offers you an FFP or you choose to wear your own.
3. Postal Service employees may wear an FFP while working unless it would cause a hazardous condition
(see OSHA Appendix D0).
4. Employees are not permitted to wear tight-fitting, air-purifying respirators or other non-FFP respirators
unless they are supplied by the Postal Service in conformance with OSHA regulations. This policy is for
your protection.
5. The information OSHA requires the Postal Service to share with you deals mostly with tight-fitting
respirators (such as the rubber-mask-type with canisters attached). However, some of this information
is also pertinent to FFPs. Note the following points when wearing an FFP, whether it is your own or it is
offered for your comfort by the Postal Service:
a. Read and follow the instructions for a more comfortable fit and effectiveness. Follow
recommendations for fit testing and use, storage, and cleaning, because a dirty FFP can cause
skin irritation or other health problems.
b. FFPs may be suitable to provide comfort and to avoid allergens (like pollen) and nuisance dust.
However, they do not necessarily protect you from toxic materials. If necessary, the Postal Service
will supply you with a carefully selected respirator for that purpose in conformance with OSHA
regulations.
c. Do not wear an FFP if it causes breathing problems or other discomfort. Consult with safety or
medical personnel.
38 Management Instruction EL-810-2009-4
Appendix D to 29 CFR 1910.134
*Mandatory Information for Employees Using Respirators When Not Required Under the Standard
“Respirators are an effective method of protection against designated hazards when properly selected and
worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an
additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept
clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to
avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by
OSHA standards. If your employer provides respirators for your voluntary use, or if you provide your own
respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard.
“You should do the following:
1. Read and heed all instructions provided by the manufacturer on use, maintenance, cleaning and care,
and warnings regarding the respirator’s limitations.
2. Choose respirators certified for use to protect against the contaminant of concern. NIOSH, the National
Institute for Occupational Safety and Health of the U.S. Department of Health and Human Services,
certifies respirators. A label or statement of certification should appear on the respirator or respirator
packaging. It will tell you what the respirator is designed for and how much it will protect you.
3. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not
designed to protect against. For example, a respirator designed to filter dust particles will not protect
you against gases, vapors, or very small solid particles of fumes or smoke.
4. Keep track of your respirator so that you do not mistakenly use someone else’s respirator.”
