RECORD ID D99-11-006

STANDARD NUMBER

INFORMATION DATE 12-14-1999

SUBJECT Storage And Inspection Requirements Of Respirators

QUESTION

What are the storage and inspection timeline requirements for respirators when they are stacked and stored in bins?

REGULATORY REVIEW

There are no storage and inspection timeline requirements for respirators that specifically deal with the fact that they are stacked and stored in bins. Requirements exist, however, that may be relevant to this question. OSHA's 29 CFR 1910.134, Respiratory Protection, includes the following requirements for inspecting respirators: "(h)(3)(i) The employer shall ensure that respirators are inspected as follows: (h)(3)(i)(A) All respirators used in routine situations shall be inspected before each use and during cleaning; (h)(3)(i)(B) All respirators maintained for use in emergency situations shall be inspected at least monthly and in accordance with the manufacturer's recommendations, and shall be checked for proper function before and after each use; and (h)(3)(i)(C) Emergency escape-only respirators shall be inspected before being carried into the workplace for use." The question implies that the respirators may be stacked on top of each other in the bins. OSHA has the following storage requirement: "(h)(2) Storage. The employer shall ensure that respirators are stored as follows: (h)(2)(i) All respirators shall be stored to protect them from damage, contamination, dust, sunlight, extreme temperatures, excessive moisture, and damaging chemicals, and they shall be packed or stored to prevent deformation of the facepiece and exhalation valve." Storing respirators on top of each other in bins after a certain length of time is likely to result in deformation of the facepiece and exhalation valve. Employers have options for meeting inspection requirements for respirators that are stacked and stored in bins. One option is to establish an inspection program using timelines based on recommendations and experience. Another option is to ensure that the respirators are inspected before each use, either by technicians or the respirator users, as long as the inspecting person is trained for this purpose.