Cal/OSHA §5144 Respiratory Protection Compliance Checklist for Colleges and Universities

Cal/OSHA §5144 Respiratory Protection Compliance Checklist for Colleges and Universities

Colleges and universities face unique respiratory hazards—from chemistry labs exhaling solvent vapors to maintenance crews tackling asbestos in aging buildings. Cal/OSHA's Title 8 §5144 mandates a robust respiratory protection program to shield students, faculty, and staff. This checklist distills the regulation into actionable steps, drawing from our frontline experience auditing campus EHS programs.

1. Conduct a Thorough Respiratory Hazard Assessment

Start here. §5144 requires identifying all operations where respirators are needed.

  • Map high-risk areas: chem labs, bio labs, HVAC maintenance, construction/renovation sites, and art studios with spray paints.
  • Sample air quality using NIOSH methods or industrial hygienists— we've seen universities uncover hidden silica dust in facilities shops this way.
  • Document hazards, exposure levels, and required protection factors (e.g., APF from Table AC-1).
  • Reassess annually or after changes like new lab equipment.

2. Develop and Implement a Written Respiratory Protection Program

Your program's backbone. Make it campus-wide, tailored to academic and facilities needs.

  1. Assign a program administrator—often the EHS director—with authority and resources.
  2. Outline procedures for selection, maintenance, training, fit testing, and medical evaluations.
  3. Include emergency use protocols for IDLH atmospheres in research settings.
  4. Distribute to all users and keep accessible via your safety management software.
  5. Review and update annually; we've helped campuses integrate this into their JHA processes seamlessly.

3. Select Appropriate Respirators

No one-size-fits-all. Match respirators to assessed hazards per §5144 Appendix A.

  • Prioritize air-purifying for common lab fumes (e.g., half-masks with organic vapor cartridges).
  • Opt for supplied-air or SCBA in confined spaces like steam tunnels.
  • Ensure NIOSH approval via TC numbers; ban unapproved disposables for known hazards.
  • For voluntary use, provide at no cost and limit to nuisance dusts.

Pro tip: In university settings, stock varied sizes for diverse body types among international students and staff.

4. Require Medical Evaluations

Respirators stress the body—screen first.

  • Use a PLHCP (Physician or Licensed Health Care Professional) questionnaire from §5144 Appendix C.
  • Evaluate before initial fit test, every year for cartridges, or if health changes occur.
  • Provide exam results to employees confidentially; no clearance, no respirator.
  • Track via your incident reporting system—we've caught early COPD signals in maintenance crews this way.

5. Perform Qualitative and Quantitative Fit Testing

Airtight seal or bust. §5144 demands it annually.

  1. Train testers per Appendix A—QLFT for half-masks, QNFT for full-face.
  2. Test clean-shaven users only; enforce beard policies humanely.
  3. Retest after facial changes, dental work, or weight shifts common in student workers.
  4. Record pass/fail with OF% for QNFT; retain 30 years.

6. Deliver Comprehensive Training

Knowledge prevents disasters. Train before use, annually, and post-change.

  • Cover limitations, proper use, maintenance, and storage—use hands-on demos in labs.
  • Quiz on recognizing cartridge change signs (e.g., taste of solvents).
  • Tailor for roles: researchers on PAPRs, custodians on dust masks.
  • Document attendance; integrate with your training management platform.

We've trained thousands across California campuses—employees remember demos over slides.

7. Establish Cleaning, Maintenance, Inspection, and Storage Protocols

Neglect kills respirators fast.

  • Inspect before/after each use and monthly; log defects.
  • Clean per manufacturer with mild soap— no harsh campus disinfectants.
  • Store in sealed bags away from sunlight, contaminants, or crushing (e.g., dedicated lockers).
  • Repair or discard damaged units; track inventory to avoid shortages during flu season.

8. Monitor Program Effectiveness and Audit

Compliance isn't set-it-and-forget-it.

  1. Observe use in the field; survey users quarterly.
  2. Audit records yearly—fit tests, training, med evals.
  3. Report incidents involving respirators to Cal/OSHA if required.
  4. Seek third-party audits; reference Cal/OSHA §5144 full text and NIOSH Pocket Guide for updates.

Master this checklist, and your campus stays breathlessly compliant. Individual results vary by implementation—consult pros for tailored audits.

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