Document 0Jyx1bN280VLGkM1RXYoX3Xom

TO: P. A. HOLLIS FROM: W. L. WALTON CC: B. R. Sparks - Zachry ^,D. G. Jentsch S. V. Hinson - VI CON D. C. Maxcy VI CON J. E. Borden March 3, 1 981 JOB 2456 - RESPIRATOR FIT TESTING Per our previous discussions the Victoria Plant is providing routine respirator fit testing of Zachry maintenance'employees similar to the testing done for our own du Pont employees. The results of these tests will be forwarded to Zachry for your use in administration of respirator usage. The primary purpose of these tests is to provide a proper level of confidence that Zachry maintenance employees will be adequately protected by the equipment provided if it is worn properly. The purpose of this note is to reconfirm the fact that du Pont is only providing a fit test service and is not assuming other pertinent aspects of respirator protection followup. Specifically our testing of Zachry maintenance employees does not include any medical assessment of a person's physical ability to wear respirators, air masks, etc. (See OSHA 1910.134-10 attached.) WLW/vk Attachment OCCUPATIONAL SAFETY AND HEALTH (ii) Goggles that can be worn over correc tive spectacles without disturbing the adjustment of the spectacles. (iii) Goggles that incorporate corrective lenses mounted behind the protective lenses. (4) Every protector shall be distinctly marked to facilitate identification only of the manufacturer. 1910.133UX3X11) STANDARDS AND INTERPRETATIONS (5) When limitations or precautions are indicated by the manufacturer, they shall be transmitted to the user and care taken to see that such limitations and precautions are strictly observed. (6) Design, construction, testing, and use of devices for eye and face protection shall be in accordance with American National Standard for Occupational and Educational Eye and Face Protection, ZST.1-1968. 1910.134--RESPIRATORY PROTECTION (a) Permissible practice. (1) In the control of those occupational dis eases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the pri mary objective shall be to prevent at mospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitu tion of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to the following requirements. (2) Respirators shall be provided by the employer when such equipment is neces sary to protect the health of the employee. The employer shall provide the respirators which are applicable and suitable for .the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protective program which shall include the require ments outlined in paragraph (b) of this sec tion. (3) The employee shall use the provided respiratory protection in accordance with instructions and training received. (b) Requirements for a minimal acceptable program. (1) Written standard operating procedures 333 governing the selection and use of respirators shall be established. (2) Respirators shall be selected on the basis of hazards to which the worker is exposed. (3) The user.shall be instructed and trained in the proper use of respirators and their limitations. (4) Where practicable, the respirators should be assigned to individual workers for their exclusive use. (5) Respirators shall be regularly cleaned and disinfected. Those issued for the exclu sive use of one worker should be cleaned after each day's use, or more often if neces sary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. (6) Respirators shall be stored in a conven ient, clean, and sanitary location. (7) Respirators used routinely shall be inspected during cleaning. Worn or deteriorated parts shall be replaced. Res pirators for emergency use such as selfcontained devices shall be thoroughly inspected at least once a month and after each use. (8) Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained. 1910.134(bX8) DUP 0831056 ; s - r I91Q.134CbK9) STANDARDS AND INTERPRETATIONS OCCUPATIONAL SAFETY AND HEALTH (9) There shall be regular inspection and evaluation to determine the continued effectiveness of the program. (2) Breathing air may be supplied to respirators from cylinders or air compres sors. . (10) Persons should not be assigned to tasks lrequiringlus`e. .oLcespirators unless it has been determined that they are physically able to perform the work and use the equip ment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance, annually). (11) Approved or accepted respirators shall be used when they are available. The respirator furnished shall provide adequate respiratory protection against the par ticular hazard for which it is designed in accordance with standards established by competent authorities. The U.S. Depart ment of Interior, Bureau of Mines, and the U.S. Department of Agriculture are recog nized as such authorities. Although respiratqrs jisted by the U.S. Department of Agriculture continue to be acceptable for protection against specified pesticides, the U.S. Department of the Interior, Bureau of Mines, is the agency now responsible for testing and approving pesticide respirators. (c) Selection of respirators. Proper selection of respirators shall be made according to the guidance of American National Standard Practices for Respiratory Protection Z88.2-1969. (d) Air quality. (i) Cylinders shall be tested and main tained as prescribed in the Shipping Con tainer Specification Regulations of the Department of Transportation (49 CFR Part 178). (ii) The compressor for supplying air shall be equipped with necessary safety and standby devices. A breathing air-type compressor shall be used. Compressors shall be constructed and situated so as to avoid entry of contaminated air into the system and suitable in-line air purify ing sorbent beds and filters installed to further assure breathing air quality. A receiver of sufficient capacity to enable the respirator wearer to escape from a contaminated atmosphere in event of compressor failure, and alarms to indicate compressor failure and overheat ing shall be installed in the system. If an oil-lubricated compressor is used, it shall have a high-temperature or carbon monoxide alarm, or both. If only a hightemperature alarm is used, the air from the compressor shall be frequently tested for carbon monoxide to insure that it meets the specifications in subparagraph (1) of this paragraph. (3) Air line couplings shall be incompatible with outlets for other gas systems to pre vent inadvertent servicing of air line respirators with nonrespirable gases or oxygen. (1) Compressed air, compressed oxygen, liquid air, and liquid oxygen used, for respi ration shall be of high purity. Oxygen shall meet the requirements of the United States Pharmacopoeia for medical or breathing oxygen. Breathing air shall meet at least the requirements of the specification for Grade D breathing air as described in Com pressed Gas Association Commodity Specifi cation G-7.1-1966. Compressed oxygen shall not be used in supplied-air respirators or in open circuit self-contained breathing apparatus that have previously used com pressed air. Oxygen must never be used with air line respirators. (4) Breathing gas containers shall be marked in accordance with American National Standard Method of Marking Port able Compressed Gas Containers to Identify the Material Contained, Z48.1-1954; Federal Specification BB-A-1034a, June 21, 1968, Air, Compressed for Breathing Pur poses; or Interim Federal Specification GG-B-00675b, April 27, 1965, Breathing Apparatus, Self-Contained. (e) Use of respirators. (1) Standard procedures shall be developed for respirator use. These should include all 1910.!34(eXl) 334 DUP 0831057 OCCUPATIONAL SAFETY AND HEALTH information and guidance necessary for their proper selection, use, and care. Possi ble emergency and routine uses of respirators should be anticipated and planned for. (2) The correct respirator shall be specified for each job. The respirator type is usually specified in the work procedures by a qual ified individual supervising the respiratory protective program. The individual issuing them shall be adequately instructed to insure that the correct respirator is issued. Each respirator permanently assigned to an individual should be durably marked to indicate to whom it was assigned. This mark shall not affect the respirator performance in any way. The date of issuance should be recorded. (3) Written procedures shall be prepared covering safe use of respirators in danger ous atmospheres that might be encountered in normal operations or in emergencies. Per sonnel shall be familiar with these proce dures and the available respirators. (i) In areas where the wearer, with failure of the respirator, could be overcome by a toxic or oxygen-deficient atmosphere, at least one additional man shall be pres ent. Communications (visual, voice, or signal line) shall be maintained between both or all individuals present. Planning shall be such that one individual will be unaffected by any likely incident and have the proper rescue equipment to be able to assist the other(s) in case of emer gency. (ii) When self-contained breathing apparatus or hose masks with blowers are used in atmospheres immediately dan gerous to life or health, standby men must be present with suitable rescue equip ment. (iii) Persons using air line respirators in atmospheres immediately hazardous to life or health shall be equipped withsafety harnesses and safety lines for lift ing or removing persons from hazardous atmospheres or other and equivalent pro visions for the rescue of persons from hazardous atmospheres shall be used. A standby man or men with suitable self- mo.m(exi) STANDARDS AND INTERPRETATIONS contained breathing apparatus shall be at the nearest fresh air base for emer gency rescue. (4) Respiratory protection is no better than the respirator in use, even though it is worn conscientiously. Frequent random inspec tions shall be conducted by a qualified individual to assure that respirators are properly selected, used, cleaned, and main tained. (5) For safe use of any respirator, it is essen tial that the user be properly instructed in its selection, use, and maintenance. Both supervisors and workers shall be so instructed by competent persons. Training shall provide the men an opportunity to handle the respirator, have it fitted prop erly, test its face-piece-to-face seal, wear it in normal air for a long'familiarity period, and, finally, to wear it in a test atmosphere. (i) Every respirator wearer shall receive fitting instructions including demonstra tions and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly. Res pirators shall not be worn when condi tions prevent a good face seal. Such condi tions may be a growth of beard, sideburns, a skull cap that projects under the facepiece, or temple pieces on glasses. Also, the absence of one or both dentures can seriously affect the fit of a facepiece. The worker's diligence in observing these factors shall be evaluated by periodic check. To assure proper protection, the facepiece fit shall be checked by the wearer each time he puts on the respirator. This may be done by following the manufacturer's facepiece fitting instructions. (ii) Providing respiratory protection for individuals wearing corrective glasses is a serious problem. A proper seal cannot be established if the temple bars of eye glasses extend through the sealing edge of the full facepiece. As a temporary measure, glasses with short temple bars or without temple bars may be taped to the wearer's head. Wearing of contact lenses in contaminated atmospheres with a respirator shall not be allowed. Systems have been developed for mountingcorrec- I9I0.I34(X5XI1) DUP 0831058 1910.134(eX5XH) STANDARDS AND INTERPRETATIONS tive lenses inside full facepieces. When a workman must wear corrective lenses as part of the facepiece, the facepiece and lenses shall be fitted by qualified in dividuals to provide good vision, comfort, and a gas-tight seal. (iii) If corrective spectacles or goggles are required, they shall be worn so as not to affect the fit of the facepiece. Proper selection of equipment will minimize or avoid this problem. (f) Maintenance and care of respirators. (1) A program for maintenance and care of respirators shall be adjusted to the type of plant, working conditions, and hazards involved, and shall include the following basic services: (i) Inspection for defects (including a leak check), (ii) Cleaning and disinfecting, (iii) Repair, (iv) Storage Equipment shall be properly maintained to retain its original effectiveness. (2) (i) All respirators shall be inspected routinely before and after each use. A respirator that is not routinely used but is kept ready for emergency use shall be inspected after each use and at least monthly to assure that it is in satisfactory working condition. (ii) Self-contained breathing apparatus shall be inspected monthly. Air and oxygen cylinders shall be fully charged according to the manufacturer's instruc tions. It shall be determined that the reg ulator and warningdevices function prop erly. (iii) Respirator inspection shall include a check of the tightness'of connections and the condition of the facepiece, head- 1910.134(0(5X1) OCCUPATIONAL SAFETY AND HEALTH bands, valves,connectingtube, and canis ters. Rubber or elastomer ppu-ts shall be inspected for pliability and signs of deterioration. Stretching and manipulat ing rubber or elastomer parts with a mas saging action will keep them pliable and flexible and prevent them from taking a set during storage. (iv) A record shall be kept of inspection dates and findings for respirators main tained for emergency use. (3) Routinely used respirators shall be col lected, cleaned, and disinfected as fre quently as necessary to insure that proper protection is provided for the wearer. Each worker should be briefed on the cleaning procedure and be assured that he will always receive a clean and disinfected respirator. Such assurances are of greatest significance when respirators are not individually assigned to workers. Res pirators maintained for emergency use shaft be cleaned and disinfected after each use. (4) Replacement or repairs shall be done only by experienced persons with parts designed for the respirator. No attempt shall be made to replace components or to make adjustment or repairs beyond the manufacturer's recommendations. Reduc ing or admission valves or regulators shall be returned to the manufacturer or to a trained technician for adjustment or repair. (5) (i) After inspection, cleaning, and neces sary repair, respirators shall be stored to protect against dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Respirators placed at stations and work areas for emergency use should be quickly accessible at all times and should be stored in compart ments built for the purpose. The compart ments should be clearly marked. Routinely used respirators, such as dust respirators, may be placed in plastic bags. Respirators should not be stored in such places as lockers or tool boxes unless they are in carrying cases or cartons. DUP 0831059 r OCCUPATIONAL SAFETY AND HEALTH (ii) Respirators should be packed or stored so that the facepiece and exhalation valve will rest in a normal position and function will not be impaired by the elastomer set ting in an abnormal position. (iii) Instructions for proper storage of emergency respirators, such as gas masks and self-contained breathing apparatus, are found in "use and care" instructions usually mounted inside the carrying case lid. (g) Identification of gas mask canisters. (1) The primary means of identifying a gas mask canister shall be by means of properly worded labels. The secondary means of iden tifying a gas mask canister shall be by a color code. (2) All who issue or use gas masks falling within the scope of this section shall see that all gas mask canisters purchased or used by them are properly labeled and colored in accordance with these requirements before they are placed in service and that the labels and colors are properly main tained at all times thereafter until the canisters have completely served their pur pose. (3) On each canister shall appear in bold let ters the following; ('} Canister for.......................................................... . (Name for atmospheric contaminant) or Type N Gas Mask Canister ' (ii) In addition, essentially the following wording shall appear beneath the appro priate phase on the canister label: "For 1910.134(0(5 KH> STANDARDS AND INTERPRETATIONS respiratory protection in atmospheres containing not more than ............. per cent by volume of......................................... (4) Canisters having a special high-effi ciency filter for protection against radionuclides and other highly toxic par ticulates shall be labeled with a statement of the type and degree of protection afforded by the filter. The label shall be affixed to the neck end of, or to the gray stripe which is around and near the top of, the canister. The degree of protection shall be marked as the percent of penetration of the canister by a 0.3-micron-diameter dioctyl phthalate (DOP) smoke at a flow rate of 85 liters per minute. (5) Each canister shall have a label warning that gas masks should be used only in atmospheres containing sufficient oxygen to support life (at least 16 percent by volume), since gas mask canisters are only designed to neutralize or remove contami nants from the air. (6) Each gas mask canister shall be painted a distinctive color or combination of colors indicated in Table 1-1. All colors used shall be such that they are clearly identifiable by the user and clearly distinguishable from one another. The color coating used shall offer a high degree of resistance to chipping, scaling, peeling, blistering, fading, and the effects of the ordinary atmospheres to which they may be exposed under normal conditions of storage and use. Appro priately colored pressure sensitive tape may be used for the stripes. DUP 0831060 Change ^ 337 l910.1M(gK) 1910.134(fX6) STANDARDS AND INTERPRETATIONS OCCUPATIONAL SAFETY AND HEALTH Table 1-1 Atmospheric contaminants to be protected against Acid gases--------------------- -------- ----------- -------Hydrocyanic acid gas......... ........... ...................... Chlorine gas-------------------------------------------------- Organic vapors..--------- ---------------------------------Ammonia gas------------ `----------------------------------Acid gases and ammonia gas Carbon monoxide-----------------------------------------Acid gases and organic vapors----------------------Hydrocyanic acid gas and chloroplcrin vapor. Acid gases, organic vapors, and ammonia gases. Radioactive materials, excepting tritium and noble gases. Particulates (dusts, fumes, mists, fogs, or smokes) In combination with any of the above gases or vapors. All of the above atmospheric contaminants__ Colors assigned* White. White with 14-Inch green stripe completely around the canister near the bottom. White with Vi-lnch yellow stripe completely around the canister near the bottom. Black. Green. Green with Vi-inch white stripe completely around the canister near the bottom. Blue. Yellow. Yellow with Vi-lftch blue stripe completely around the canister near the bottom. Brown. Purple (Magenta). Canister color for contaminant, as designated above, with Vi-Inch gray stripe completely around the canister near the top. Red with V-lnch gray stripe completely around the canister near the top. Gray shall not be assigned as the main color for a canister designed to remove acids or vapors. Note: Orange shall be used as a complete body, or stripe color to represent gases not Included in this table. The user will need to refer to the canister label to determine the degree of protection the canister will afford. r 1910.135--OCCUPATIONAL HEAD PROTECTION Helmets for the protection of heads of occu pational workers from impact and penetration from falling and flying objects and from limited electric shock and burn shall meet the requirements and specifications established in American National Standard Safety Requirements for Industrial Head Protection, Z89->-1969- iqft) 1910.136--OCCUPATIONAL FOOT PROTECTION Safety-toe footwear for employees shall American National Standard for Men's meet the requirements and specifications in Safety-Toe Footwear, Z4l.1-1967. 1910.138 338 ca -o o 00 w o o> OSHA Instruction CPI 2-2.20 April 2, 1979 Office of Field Coordination properly selected, used, cleaned and maintained. If the employer is not making any effort to ensure that the respirator program is effective, by observing respirator use, soliciting user comments or conducting regular inspections, a citation shall be issued. ^Q^WedlcaV--ExamihatTon? 29 CFR 1910.134(b)(10) is an enforceable"requirement of the standard. A citation may be issued under this paragraph if appropriate medical deter minations have not been provided. 11. Approved Respirators. a. 29 CFR 1910.134(b)(ll) states "Approved or accepted respirators shall be used when they are available." A respirator is approved as the whole unit with specific components. (1) Mixing of components between different types or makes of respirators nullifies the approval. (2) The use of nonapproved components nullifies the approval -- - - - - (3) The use of an approved respirator in atmospheric concentrations for which it is not approved constitutes a violation. (4) Observation by the Industrial Hygienist that one or more employees are working in the contaminated area above the PEL without approved respiratory protection establishes a violation. (5) Use of nonapproved components such as incorrect hoses or regulators on self-contained breathing apparatus or air-line respirators may result in serious harm to the user due to possible malfunc tion of the system. b. In general, for air contaminants listed in 29 CFR 1910.1000, Tables Z-l to Z-3, either joint Mine Safety and Health Administration (MSHA) and NIOSH, MSHA alone, or Bureau of Mines approved respirators are recognized by OSHA to be adequate. W DUP 0831062 III--12