| Topic: Respiratory protective equipment – Compressed breathing air | Issued by: V.P., WorkSafe Services and reviewed by Engineer, Investigations and Technical Services |
| Statute: General Regulation 91-191 | Date Issued: December 11, 1998 |
| Section: 45(2) | Date Revised: April 30, 2024 |
45(2) An employer shall comply with CSA standard Z94.4-11, “Selection, Care, and Use of Respirators” in developing the code of practice.
Question:
General Regulation 91-191 references a standard. That standard in turn references a second standard. Is an employer required to comply with the second standard?
Answer:
Section 45(2) requires an employer to develop a code of practice that complies with the 2011 version of CSA Z94.4 Selection, Use, and Care of Respirators. That standard says “Compressed breathing air shall meet or exceed the requirements of CSA Standard Z180.1”.
Section 14.2.2 of CSA standard Z180.1 Compressed Breathing Air and Systems requires purity analysis testing of the air produced by the breathing air system "A sample of compressed breathing air produced and delivered by a compressed breathing air system shall be collected and analyzed at least once every six months". Section 14.1.4 attests that "Samples shall be analyzed by an accredited laboratory".
In essence, Reg. 91-191 incorporates a standard, which in turn incorporates another standard. In this circumstance, the second standard has the effect of the regulation. One standard is on respirators and the other is on compressed breathing air. It is reasonable for an employer in a workplace that requires respiratory equipment to be familiar with both. Both are CSA standards and are readily available.