Get prepared: MLITSD Respiratory Protection inspections are starting soon
Earlier in 2022, the Ministry of Labour, Immigration, Training and Skills Development (MLITSD) started to take a closer look at occupational disease among Ontario workers, particularly respiratory illnesses. Under the Healthy Workers in Healthy Workplaces Initiative, MLITSD inspectors targeted silica and asbestos exposure - two designated substances known to cause respiratory illnesses.
Starting in January and going until March 31st, inspectors will begin a Respiratory Protection Initiative, which will have them paying particular attention to airborne exposures in workplaces and focusing on what employers are doing to protect their workers.
Before discussing how to prepare your workplace for this initiative, it’s important to have an understanding of what respiratory hazards are and how to recognize them. "When we talk about respiratory hazards, we're talking about biological or chemical agents in the air we breathe, or in some cases, oxygen-deficient atmospheres," says Madison Sieloff, a Specialized Consultant (Occupational Hygiene) with WSPS.
"Employers need to examine their work processes, determine whether or not a respiratory hazard is present, and, if so, identify if the hazard is in the form of dust, fume, mist, gas, vapour, etc.," says Madison. When determining whether a respiratory hazard is present, Madison emphasizes how important it is to review safety data sheets (SDSs). "A SDS will outline the hazards associated with the product or chemical you are using as well as exposure control measures, so they’re a great source of information," she says.
Prepare for inspections
- Start with a hazard assessment. Madison recommends breaking down your work processes to systematically identify the hazards associated with each one. Doing this will help you uncover where and what the respiratory hazards may be. "If we look at welding, for example, consider the materials you are using and the type of welding you are doing. What are the hazards? Is a worker potentially exposed to specific contaminants in welding fumes from the type of base metal or welding wire being used?" asks Madison. Remember to also consider non-routine work activities when performing hazard assessments.
- Measure the exposure levels. If your hazard assessment determines that respiratory hazards are present, your next step to consider is air sampling. Have a qualified professional (e.g., an occupational hygienist) measure the level of airborne chemical exposures in your workplace. "Once we identify the potential exposure, we collect individual air samples from workers during their work activities," describes Madison. "These results are compared to the occupational exposure limits (OELs) outlined in Ontario Regulation 833 Control of Exposure to Biological or Chemical Agents (O. Reg. 833) or Ontario Regulation 490/09 Designated Substances (O. Reg. 490/09)." From a compliance perspective, if the air sampling results show that exposures are above the OEL, controls must be put in place, or existing controls must be improved-to protect workers.
Madison points out that an airborne exposure assessment helps assess the effectiveness of any controls that are currently in place. If exposure levels are low, then this is a good indication that your controls are working. However, airborne exposure levels should be reassessed periodically to generate a history of exposures and to monitor the efficacy of controls. Exposure levels should also be reassessed each time there is a change in the process, material, or work environment.
- Control the respiratory hazard. When dealing with a respiratory hazard, many employers still go straight to personal protective equipment (PPE). "PPE is your last line of defence," reminds Madison. "Consider elimination, substitution, engineering or administrative controls first.” One example is reviewing the use of isocyanate-containing products. If you are spray painting with a product that contains isocyanates, consider substituting with another less hazardous product to eliminate any potential exposure to isocyanates. "Local exhaust ventilation is one of the most common engineering controls I see in manufacturing environments," says Madison. Following O.Reg.833 and O.Reg.490, substitution, engineering, and administrative controls must be reviewed before requiring respirator use. In situations where these controls are not reasonable, practical, or not effective in reducing worker exposure to acceptable concentrations, respirators must be provided to protect workers.
- Communicate, train, and document. After completing a hazard assessment, air sampling, and a review of elimination, substitution, engineering, and administrative controls, you may determine that PPE (e.g., a respirator) is a necessary layer in your controls to protect your workers from respiratory hazards. If this is the case, employers must ensure their workers are trained on the proper use and care-including fit testing, inspection, limitations, and cleaning-of the respirators provided. And all of it must be documented as part of a Respiratory Protection Program
- Follow the requirements outlined in O.Reg.833 and O.Reg.490 for a Respiratory Protection Program. "Ultimately, the employer must ensure that any respirator they provide is appropriate for the form and concentration of the airborne exposure and that workers are trained on the proper use and care of the respirators provided, including following manufacturers' instructions," says Madison.
How WSPS Can Help
Connect with a WSPS Occupational Hygiene Consultant for services, such as air sampling and Respiratory Protection Program development.
- WHMIS 2015 (1 hour; eCourse)
- Hazard Identification, Assessment, and Control (3 hours; eCourse)