Policy - Respiratory Protection

Format. Adopt as a policy approved by the fire chief (or the council or board where the municipality’s framework requires it), or restate as a standard operating guideline or directive; keep the numbering either way, because the program, the procedures and the audit checklist refer to it.

Drafting conventions. Shall is mandatory. Should is expected unless a documented reason exists. May is permitted. Placeholders in double curly braces, such as {{Department}}, are completed by the department. Drafting notes sit in callouts and are removed before adoption.

Keep intact. The facepiece-on rule for interior overhaul (5.4), the Rule of Air Management (5.5), two-in/two-out (5.6), the fit test and facial hair rules (5.2, 5.3), the medical clearance and privacy rule (5.1), the breathing air rule (5.8), the adverse-condition and near-miss rules (5.10), and the learning firewall (4(g), 5.10.4). Adapt the titles, the intervals where the manufacturer or the applicable provincial regulation is stricter, the records system, and the reporting lines.

1.1 To state {{Department}}’s commitment that no member breathes a hazardous atmosphere without adequate respiratory protection, that every member who enters one comes out with air to spare, and that the equipment, the air, the people and the records that make this true are managed as one written program.

1.2 To assign accountability for that program to the line, with verification by the health and safety officer and consultation with the joint occupational health and safety committee.

2.1 This policy applies to every member of {{Department}}, career, volunteer and paid-on-call, and to every person the department directs into a respiratory hazard, including recruits, instructors, fire investigators and mutual aid members operating under the department’s command.

2.2 It applies to every respirator the department issues: self-contained breathing apparatus, supplied-air respirators, air-purifying respirators, powered air-purifying respirators and filtering facepieces, and to the breathing air, cylinders, fill stations and air monitoring instruments that support them.

2.3 It applies at incidents, at training, in stations and shops, and wherever members do the department’s work. The wildland and hazardous materials provisions apply where those modules are switched on in the Program Profile Worksheet.

2.4 Exclusions: medical oxygen administered to patients; respirators worn by contractors under their own employer’s program, which must meet or exceed this policy on the department’s sites (Policy - Contractors and Mutual Aid).

• Adequate respirator: a respirator that is sufficient to protect the wearer from injury or damage to health in the atmosphere in which it is used, selected by assigned protection factor (CSA Z94.4-18, cl. 7).
• Breathing air: compressed air meeting the purity limits of CSA Z180.1 (CSA Z180.1:19).
• End-of-service-time indicator (EOSTI): the SCBA low-air alarm, set at 33 percent of rated service time (NFPA 1970, 2025).
• Fit test: a qualitative or quantitative test of the seal between a specific tight-fitting respirator and a specific person’s face (CSA Z94.4-18, cl. 9).
• Hazard area: any atmosphere that is immediately dangerous to life or health (IDLH), may become so, is oxygen-deficient, or is unknown, including the interior of a structure during and after a fire until air monitoring shows otherwise.
• Learning firewall: the rule that information gathered for learning is never used as the basis for discipline, and that conduct concerns are handled by a separate process run by different people (Incident Investigation and Learning Program).
• Member: any person who performs work for the department, paid or unpaid.
• Near miss: an event that could have caused injury or death but did not, including every low-air alarm inside a hazard area.
• Program administrator: the person appointed in writing with authority to run the respiratory protection program (CSA Z94.4-18, cl. 5).
• Psychological safety: the shared belief that it is safe to speak up, ask, admit error and challenge (Edmondson, 1999)DOI.
• Rule of Air Management: know how much air you have and manage it so that you leave the hazardous environment before your low-air alarm activates (NFPA 1404, 2018, s. 5.1.4.2).
• Work-as-done: how a task is actually performed under real conditions, as distinct from work-as-imagined (Hollnagel, 2014).

1. Air is the first control. The department plans every entry around the air its members carry, not around the task to be finished.

2. The atmosphere is hazardous until proven otherwise. Readings, not appearances, decide when a facepiece comes off, and no reading decides it during interior overhaul.

3. Nobody enters alone and nobody is left inside. Crews enter together, stay together and leave together, with a crew outside ready to get them.

4. People are the solution we build around, not the problem to fix. Members’ judgment, adaptations and reports are the program’s main source of safety; the policy exists to support that judgment, not to replace it.

5. Procedures describe work as done, written with the people who do it. Every respiratory procedure starts from a learning-team description of how the task is really done and is revised with the crews who do it.

6. Learning comes before blame, and learning information is never used for discipline. Near-miss reports, after-action reviews, learning teams and post-incident analyses sit behind the learning firewall.

7. Psychological safety is a condition of safety, so speaking up is expected and protected. Any member may stop a respiratory task; the officer acknowledges, acts and reviews later; nobody is questioned for having raised a concern in good faith.

8. Standards are followed at their latest edition. The applicable regulation may adopt CSA Z94.4 and CSA Z180.1 as their latest edition or name a particular edition (J14 Respiratory Protection, Fit Testing and Breathing Air); this policy and its program follow the latest edition, meet any edition the regulation names, and keep an edition watch.

5.1 Medical clearance before respirator use. No member shall be fit tested or wear a tight-fitting respirator until {{Occupational Health Provider}} has confirmed that the member is medically able to wear it. 5.1.1 Clearance shall be repeated on the provider’s schedule and whenever a member reports a change in breathing, heart or lung condition, a significant weight change or difficulty wearing the respirator. 5.1.2 The department shall receive only the outcome (fit, fit with restriction, not fit) and any restriction, never a diagnosis. Accountable: {{Occupational Health Provider}} for the determination; the program administrator for the clearance list.

5.2 Fit testing. Every tight-fitting respirator a member may be issued shall be fit tested on that member before first use, every 12 months, and after any change that could affect fit. 5.2.1 SCBA facepieces shall be tested by a quantitative method. 5.2.2 Fit tests shall be performed with the hood, helmet, eyewear insert and radio strap the member wears at work, by a tester whose competency is on record. 5.2.3 No member without a current pass for the facepiece in use shall enter a hazard area. Accountable: the program manager.

5.3 Facial hair and seal. No member shall wear a tight-fitting respirator with hair between the sealing surface and the face. 5.3.1 Company officers shall confirm this at the start of each duty period and record it on the daily SCBA check sheet. 5.3.2 A member who cannot shave shall be assigned away from hazard areas and may be issued a loose-fitting powered air-purifying respirator for tasks that do not require SCBA. 5.3.3 Every member shall perform a user seal check at every donning. Accountable: company officers.

5.4 Respiratory protection in hazard areas. Every member who enters or may enter a hazard area shall wear a positive-pressure open-circuit SCBA that is NIOSH-approved and certified to the current edition of NFPA 1970, with an integrated PASS armed. 5.4.1 SCBA shall be worn through fire attack, search, extinguishment and all interior overhaul, and at vehicle, dumpster, rubbish and battery fires through overhaul, regardless of carbon monoxide or hydrogen cyanide readings and regardless of visible smoke. 5.4.2 A facepiece shall be removed inside a structure only after the incident commander has decided, on the basis of multi-gas monitoring that includes hydrogen cyanide and the absence of visible smoke, off-gassing and odour, that the atmosphere is safe, and has logged the readings and the decision. 5.4.3 Air-purifying respirators, powered air-purifying respirators, supplied-air respirators, wildland respirators and filtering facepieces shall be used only within the task limits the program’s selection table sets, and never in a hazard area. Accountable: incident commanders for the decision; company officers for compliance.

5.5 Air management. The department shall maintain a written air management procedure and every member shall follow it. 5.5.1 Members shall enter a hazard area with a full cylinder, check the gauge at the door and at every benchmark, report the crew’s lowest reading on every status report, and begin to leave at the exit pressure the officer set at entry. 5.5.2 Every member shall manage air so as to leave the hazard area before the low-air alarm activates. 5.5.3 A low-air alarm inside a hazard area shall be treated as an immediate action item: the whole crew leaves, the officer tells command, and the event is reported as a near miss before the end of the shift. 5.5.4 Every member shall complete an individual consumption rate drill at recruit training and at least every three years. Accountable: company officers at incidents; the program manager for the procedure and the drills.

5.6 Two-in/two-out, rapid intervention and accountability. No member shall enter a hazard area alone. 5.6.1 At least two members shall enter together and remain in contact, and at least two equipped members shall remain outside ready to rescue them before entry begins, except in a known, imminent life-threatening situation that the incident commander records. 5.6.2 A dedicated rapid intervention crew shall be assigned as the incident grows and shall not be given tasks that consume its air. 5.6.3 A personnel accountability system with personnel accountability reports shall be in use at every incident where members enter a hazard area. Accountable: incident commanders. (Full provisions in Policy - Emergency Operations Safety.)

5.7 Equipment selection, inspection, maintenance and retirement. The department shall select respirators by a documented hazard assessment, keep a fleet approval register reconciled to the NIOSH Certified Equipment List, and buy only equipment that meets the current NFPA edition. 5.7.1 Assigned SCBA shall be inspected by the user at the start of each duty period and after each use; unassigned units at least weekly and after each use. 5.7.2 Every SCBA shall be flow tested on a calibrated breathing machine at least annually, before first use and after any repair, by a manufacturer-authorized technician. 5.7.3 Any respirator with a defect shall be removed from service, tagged, secured and reported the same day. 5.7.4 SCBA shall be retired on the program’s criteria and rendered unusable. 5.7.5 Contaminated SCBA shall be bagged, transported outside the cab and cleaned to the level the contamination requires. Accountable: the program manager; company officers for daily inspection.

5.8 Breathing air and cylinders. All breathing air shall meet CSA Z180.1. Air from every compressor and every purchased-air source shall be sampled and tested by an accredited laboratory at commissioning, quarterly, and after any major overhaul, extensive repair or filter change. Quarterly testing meets NFPA 1989 and is inside the six-month maximum interval that CSA Z180.1 allows (NFPA 1989, 2019; CSA Z180.1:19). 5.8.1 Compressors shall have a continuous carbon monoxide monitor with alarm and shutdown; fill stations shall have an enclosure that contains a cylinder failure; only trained operators shall fill cylinders. 5.8.2 Every cylinder shall be in a register, visually inspected before every fill and after every use, requalified on the interval for its specification at a Transport Canada registered facility, and condemned at the end of its service life. 5.8.3 Any out-of-limit air test shall stop filling from that source and quarantine every cylinder filled since the last good test. Accountable: the program manager; the program administrator for the registers.

5.9 Training and competency. Every member shall be trained before first respirator use and evaluated annually for SCBA proficiency; officers shall be trained in air management supervision before acting as incident commander; technicians, fit testers, fill station operators and air monitor users shall hold the competencies the program sets. Accountable: the deputy chief responsible for training.

5.10 Reporting, learning and speaking up. 5.10.1 Every low-air alarm inside a hazard area, mayday, PASS activation in earnest, facepiece breach, buddy-breathing event and respirator failure shall be reported as a near miss within the shift and reviewed through the learning system. 5.10.2 Any member may stop a respiratory task at any time by stating the hazard and the action; the officer shall acknowledge, act and review it later for learning. 5.10.3 Every member who raises a respiratory protection concern shall receive a written answer from the program administrator within five working days. 5.10.4 Learning information shall never be used as the basis for discipline; conduct concerns shall be handled by a separate process run by different people. 5.10.5 No member shall suffer reprisal for a report, a stop-work call or a concern raised in good faith. Accountable: the fire chief.

5.11 Program, consultation and review. The department shall maintain Respiratory Protection Program as the written program this policy requires, appoint a program administrator in writing, consult the JOHSC on the program and on every safety-sensitive change before adoption, evaluate the program annually and have it independently reviewed every three years. Accountable: the fire chief.

Only the differences from 01 Roles and Responsibilities are stated here.

6.1 Fire chief: approves this policy; appoints the program administrator; answers JOHSC recommendations on respiratory protection in writing within the time the applicable statute sets (J05 Joint Committee and Health and Safety Representative); receives the annual program appraisal.

6.2 Program manager (line officer leading the Respiratory Protection team): accountable for the program’s outcome and indicators; owns every open corrective action for the program; presents the quarterly update and the annual appraisal.

6.3 Program administrator: runs the program day to day; keeps the fit-test register, the clearance status list, the fleet approval register and the cylinder register; has the authority to stop respirator use and remove equipment from service; answers members’ concerns within five working days; keeps the edition watch.

6.4 Health and safety officer: verifies the program against law and standards; samples records quarterly; observes overhaul SCBA use at working fires; runs the annual internal audit.

6.5 Incident commanders: decide, log and announce any facepiece removal inside a structure; establish two-in/two-out and rapid intervention; assign the incident safety officer per the Emergency Operations Safety triggers.

6.6 Company officers: confirm facial hair and daily inspection at the start of each duty period; set the exit pressure at entry; track the crew’s air; enforce the facepiece-on rule; record and pass on every concern the same day.

6.7 Members: inspect and clean their SCBA and facepiece; keep fit test and clearance current; follow the Rule of Air Management; report every near miss, defect and concern; speak up and stop work when something is wrong.

6.8 SCBA technicians, fit testers, fill station operators: perform only the work their competency record covers; keep the records the program names.

6.9 {{Occupational Health Provider}}: determines medical fitness for respirator use; keeps medical records separate and confidential.

6.10 {{JOHSC}}: designates a standing consultant to the Respiratory Protection team; is consulted before any safety-sensitive change; inspects SCBA storage, cleaning and fill areas during station inspections; receives the quarterly update and the corrective action register.

• Respiratory Protection Program (FSSMS-PRG-01) with its implementation toolkit.
• SWP - SCBA Donning, Use and Air Management; SWP - SCBA Daily and After-Use Inspection and Cleaning; SWP - Respirator Fit Testing; SWP - Breathing Air Fill Station and Cylinder Handling.
• From Emergency Operations Safety: SWP - Two-In Two-Out and Rapid Intervention; SWP - Mayday; SWP - Accountability and Personnel Accountability Reports.
• From Decontamination and Contamination Control: SWP - On-Scene Preliminary Exposure Reduction; SWP - Post-Call Station Decontamination; SWP - Exposure Reporting.
• Forms: Form - Fit Test Record; Form - SCBA Inspection and Maintenance Log; Form - Breathing Air Quality Test Record; Form - Respirator Medical Clearance Request.

8.1 The records this policy creates are the fit-test register and records, the clearance status list (outcome and restriction only), the fleet approval register, the inspection and cleaning sheets, the flow-test and maintenance log, the breathing air test records and fill logs, the cylinder register, training and competency records, adverse-condition and near-miss reports, the concern reply log, the quarterly updates and the annual appraisal. They are kept in {{Records system}} on the retention schedule in Respiratory Protection Program section 9.

8.2 Medical questionnaires, examinations and diagnoses are held by {{Occupational Health Provider}} and never by the department. The department’s record is the outcome, the restriction and the dates.

8.3 Every record is written on the assumption that it may be disclosed under freedom-of-information legislation. Records identify people by role wherever the purpose allows; where a member must be identified (fit test, clearance, training), the record carries no health information beyond the outcome.

8.4 Near-miss reports, learning-team write-ups and post-incident analyses are de-identified before they are shared and are never placed in a personnel file. Privilege is asserted only on counsel’s advice.

9.1 To the fire chief: the quarterly indicator update; every Tier 2 or Tier 3 respiratory event within 24 hours; the annual program appraisal; the corrective action register at management review.

9.2 To {{JOHSC}}: the quarterly update; the corrective action register monthly; every out-of-limit air test and every adverse-condition report with chain of custody; every learning review outcome; the annual audit result.

9.3 To council or the governing board: respiratory protection indicators within the annual health and safety report (03 Accountability and Reporting).

9.4 To the regulator and the workers’ compensation board: as the applicable occupational health and safety and workers’ compensation law requires for injuries, exposures and dangerous occurrences (J08 Incident Reporting and Investigation).

11.1 The applicable occupational health and safety statute and regulations, which differ by province and territory: the employer’s general duty and the duties of supervisors and workers (J02 Duties of Employers, Supervisors, Workers and Contractors); the duty to provide an adequate respirator under a program that meets CSA Z94.4, with breathing air that meets CSA Z180.1, at the edition the regulation adopts, and the fit test interval and method (J14 Respiratory Protection, Fit Testing and Breathing Air); any fire-service rules on SCBA, PASS and the buddy or two-in rule (J12 Fire Service OHS Rules and Fireground Operations; J13 Firefighter PPE and Protective Equipment); written procedures, equipment inspection and exposure limits (J06 Written Procedures and Committee Consultation; J15 Equipment Inspection, Ladders and Aerial Devices; J22 Exposure Limits, Heat and Cold Stress); and the duty to consult the joint committee (J05 Joint Committee and Health and Safety Representative). The Jurisdiction requirements table at the end of this policy lists what to confirm for your province or territory.

11.2 CSA Z94.4: written program, administrator, hazard assessment, selection, fit testing, health surveillance, training, inspection and maintenance, records, evaluation (CSA Z94.4-18, cl. 5 to 15).

11.3 CSA Z180.1: breathing air purity, testing at least every six months, compressor and fill station requirements (CSA Z180.1:19). NFPA 1989: breathing air quality, with quarterly testing (NFPA 1989, 2019). The department tests quarterly, which meets both (5.8).

11.4 CSA B339 and CSA B340 (CSA B339-25; CSA B340-25), in force under Part 5 of the federal Transportation of Dangerous Goods Regulations (Transport Canada, 2025a): cylinder requalification and service life.

11.5 NFPA 1550: respiratory protection program, breathing air, equipment, fit testing, cylinders, PASS, accountability, rapid intervention, rehabilitation (NFPA 1550, 2024, ss. 9.11 to 9.17, 10.5, 10.8, 10.9, 21.5, 21.8).

11.6 NFPA 1970: SCBA and PASS performance, EOSTI at 33 percent (NFPA 1970, 2025); NIOSH approval under 42 CFR 84 with a 25 percent minimum indicator (NIOSH, 2013).

11.7 NFPA 1850: SCBA selection, inspection, cleaning, maintenance, retirement and records (NFPA 1850, 2026, ch. 14 to 17).

11.8 NFPA 1404, now within NFPA 1400: respiratory protection training and air management (NFPA 1404, 2018; NFPA 1400, 2026).

11.9 NFPA 1984, NFPA 1986 and NFPA 1987: wildland, tactical and combination respirators, within the limits the program sets (NFPA 1984, 2022; NFPA 1986, 2023; NFPA 1987, 2023).

11.10 The Criminal Code: the duty of everyone who directs work to take reasonable steps to prevent bodily harm (Criminal Code [CA], 1985, s. 217.1); see 01 Roles and Responsibilities.

11.11 Accreditation: the CPSE self-assessment manual, 10th edition (CPSE, 2019, criteria 11A.1 to 11A.6, 11A.8 to 11A.12, CC 6F.1 to 6F.5).

12.1 This policy is reviewed 12 months after adoption and every three years after that.

12.2 It is reviewed sooner after any respiratory-related death, critical injury or Tier 2 event; after a change in the applicable regulation or a new edition of CSA Z94.4, CSA Z180.1, NFPA 1550, NFPA 1970 or NFPA 1850; on a written request of {{JOHSC}}; or when the annual audit or appraisal recommends it.

12.3 Every revision is consulted with {{JOHSC}}, {{Union}} and {{Volunteer Association}} before approval, and the consultation record is filed with the policy.

Consult early, before the policy is in final form, and put the outcome in writing. The committee and the bargaining agents will ask these questions; the honest answers follow.

Where the parties disagree, record the disagreement, adopt what can be adopted, and review at 12 months.

Disclaimer. This model policy is general information for the use of {{Department}} in building its own policy. It is not legal advice. The applicable statute, regulation and collective agreement govern on any conflict. Confirm every cited clause and section with counsel before adoption.

End of model policy.

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.