Using OSHA inspection data to analyze respirator protection program compliance

Abstract

for Occupational Safety and Health (NIOSH). 1 That survey collected extensive information from respondents at companies about the types of respirators used and the conditions of their use and asked specific questions about the companies' compliance with some aspects of the OSHA respiratory protection standard (1910.95).By looking at OSHA inspection findings about respirator use, this paper provides another way to estimate the use of respirators as well as insights into noncompliance.The questions addressed in this study are the following: How many establishments had violations of the OSHA Respiratory Protection (RP) standard? 2 How did those numbers vary among establishments in different industries and size categories, and how did the numbers vary with the presence of labor unions?How closely do the findings from inspection data match those in the RUPS report?Which particular provisions of the RP standards were violated and what do these violations tell us about the patterns of noncompliance?What are the characteristics of the establishments that have repeated violations of the RP standards?There are several reasons to believe that the value of OSHA inspection data could be substantial:OSHA inspects approximately 100,000 workplaces each year; the extent of coverage exceeds what most surveys or special research efforts can provide.OSHA health standards typically stipulate exposure limits.When those limits are exceeded, OSHA requires that engineering controls and administrative controls be considered.If implementing them is not feasible, then respiratory protection programs are required.The standards that are cited are often very specific, thereby aiding in the diagnoses of problems at the worksites.Data on violations cited have a great deal of validity in that it is unlikely that the violations did not occur.OSHA does not have to rely only on compliance self-reports; such self-reports would be likely to underreport problems.On the other hand, OSHA may be unable to detect some instances of noncompliance.