Respiratory ProtectionBuilding a defendable programBy Nancy Maher, CRSP, Waterloo Regional Police ServicesWhen you think about the hazards an officer faces in the line of duty, it likely isn’t exposure to hazardous particulates, gases, and vapours that initially come to mind; violence, physical injuries, and psychological trauma are probably at the forefront.Rightly so, as these are the top injurycausing workplace hazards impacting police officers across the province.However, exposure to respiratory hazards such as infectious diseases, illicit drugs, hazardous vapours/ particulates at fire scenes and riot gas are real hazards that our members face on a regular basis and have the potential to cause significant injury or illness. Respirators are often deployed to officers to protect them from these hazards, but this should be done by building a respiratory protection program that is rooted in risk assessment, injury prevention and is compliant with health and safety and human rights legislation.CSA STANDARD Z94 IS REGARDED AS THE BEST PRACTICE BY THE MINISTRY OF LABOUR AND THE LEADING STANDARD USED BY EMPLOYERS WHEN DEVELOPING AND IMPLEMENTING A RESPIRATORY PROTECTION PROGRAM.For workers who are exposed to hazardous agents in the workplace, Ontario Regulation 833 states that employers shall provide and workers shall use a respirator appropriate in the circumstances when engineering controls are not available or practical. While engineering controls such as ventilation and fume hoods would be an effective approach to control identified respiratory hazards within police buildings (i.e., forensic identification chemical lab or powdered drug processing ventilation unit), these options are not available when responding to calls for service. It is under this regulation that requires an employer who issues respirators to develop a written respiratory protection program. Regulation 833 goes onto specify that, “a respirator that is designed to be tight-fitting shall not be provided to, or used by, a worker with facial hair that comes between the sealing surface of the facepiece and the face or that interferes with the functioning of the respirator.”CSA Standard Z94, Selection, Care and Use of Respirators, is regarded as the best practice by the Ministry of Labour, and the leading standard used by employers when developing and implementing a respiratory protection program. This standard outlines the requirement for the employer to develop and implement a written respiratory protection program and to ensure respiratory hazard risk assessments are completed. The completed respiratory hazard assessment will be the backbone of the program, serving to identify the existing or potential respiratory hazards and to select the appropriate respirator. The standard dictates responsibilities for the employer, supervisor and respirator wearer. Due to the fact that tight-fitting respirators such as an N95, half-face or full-face elastomeric respirators commonly deployed amongst police services need to seal against the skin in order to provide protection, the standard requires the respirator user to maintain their respirator seal interference-free from any object or material that would interfere with the seal or operation of the respirator and places the onus on the supervisor to ensure that the respirator user maintains the required interference-free seal. Anything getting in the way of a proper seal will impact the effectiveness of the respirator.A respiratory protection program will need to allow for accommodations on grounds protected by the Human Rights Code, such as medical and religious. If a member is at risk of exposure to a respiratory hazard but cannot wear a tight-fitting respirator, alternate accommodations must be utilized to keep the member safe while respecting human rights legislation. Having a documented request and approval process for these accommodations will ensure both the member and the employer are informed and protected under the law. There may also be a need for special operational exemptions, such as during undercover work. These exemptions should also have a formal and documented approval process and have a set duration. If alternative protective equipment is used as part of an accommodation or exemption, be mindful to assess and address any new hazards or risks that may be introduced and ensure the worker is adequately protected.The Ontario Occupational Health and Safety Act places responsibilities for health and safety on the employer, supervisor and worker, but the greatest responsibility falls to the employer. To review, the Act requires the employer to develop and maintain a health and safety program, to provide the equipment, materials and protective devices prescribed by the Act and regulations, and to ensure these items are used and maintained in good condition. More generally and perhaps more importantly, the Act requires the employer to take every precaution reasonable in the circumstances for the protection of the worker. This is known as the General Duty Clause. While the term “reasonable” is purposefully flexible and subjective, it is used to hold employers accountable for any harm or injuries due to inadequate safety measures.Depending on the situation, simply complying with specific safety regulations may not suffice when faced with legal scrutiny. The General Duty Clause looks at whether the employer took reasonable precautions to best protect the worker, not just comply with regulations. For example, a police officer attends a domestic violence call and once in the residence sees large amounts of powdered substances. The officer has a beard and is unable to don their N95 respirator because the employer’s respiratory protection program allows members to have facial hair but stipulates they must shave before wearing a tight-fitting respirator and issues dry-shave kits. The officer didn’t know there was a potential respiratory hazard at this call, therefore didn’t shave and now is at risk of exposure. In theory, the procedure complies with legislation and the CSA standard by requiring the officer to shave before donning the issued respirator. However, this approach leaves the officer at risk to unpredictable exposures and the service could face orders or fines for not taking every precaution reasonable for the protection of the worker.There is no denying that police officers face a wide array of respiratory hazards in the course of their duties. Legislation and standards exist to ensure employers who provide respiratory protection also develop written procedures for the selection, use and care of respirators in the workplace. In addition to these regulations and standards, there is an overarching responsibility for the employer to take every precaution reasonable for the protection of the worker. By designing and implementing a respiratory protection program that is legislatively compliant and puts the protection of the member at the forefront, it demonstrates a commitment to protecting the health and well-being of the officers who serve the community.Nancy Maher is a Health and Safety Advisor with the Waterloo Regional Police Service. She can be reached at nancy.maher@wrps.on.ca.
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