Document GK7KM1xLZm9K2NgyK5NnRJZgY
Federal Register / VoL 51t No. 119 / Friday, June -20, 1986 / Rules and Regulations . 22719 I
r* pliability and minor surface'defects-^wiU
' OSHA believes that employers should
\ also affect protection, as will'poor maintenance and conditions of temperature and humidity.. . . Insofar as comfort is likely to increase respirator wear, positive pressure
have the flexibility to use any of.the available respirators that provide' sufficient protection to reduce the
respirators are superior to negative-pressure exposures to levels below the PEL
because they are more likely to be accepted Furthermore, the safety problems
Many commenters presented information on fit-testing requirements. for respirators (Exs. 263; 330; 123-A; 90233: 302; 322; 328; Trs. 6/21, p. 75: 6/29. p. 232; 7/2, p. 25; 7/3, p. 48; 7/10, p. 299; 7/ 11, p. 119). Several commenters
by workers for regular use. (Ex. 330)
associated with the use of supplied-air recommended that quantitative fit
Many commenlers requested that the selection of respirators be dictated by
respirators cannot be ignored. OSHA believes that respirators should be
the exposure levels that exist in the workplace environment (Exs. 90-160; 90-173; 90-182; 339; Tr. 7/12, p. 338). For
. selected that both provide adequate protection from exposure to airborneasbestos fibers and minimize the risk of
example, the Industrial Safety
accident and injury potentially caused
Equipment.Association stated:
by the use of cumbersome supplied-air
respirators. In addition, OSHA has
The type of respirators to be required for
historically used a tiered approach to
employees engaged in spraying, demolition, and removal operations should depend on the airborne exposure levels measured for each
the application of respiratory protection in nearly all standards governing
exposed person and the proper type of
occupational health hazards. (See, for
respirator should be selected accordingly. If example. 29 CFR 1910.1047, ethylene
testing be required. For example, NIOSH commented, ", . . we want to reiterate our position that we recommend a quantitative respirator fit-testing program as previously stated in comments on the proposed lead standard" (Ex. 117-A).
Conversely, the Asbestos Information As6ociation/North America (A1A/NA) staled that the record does not support that quantitative fit-testing procedures are more effective in providing good respirator Fit than sound qualitative Fit-
such measures are not possible, a supplied-' oxide; 29 CFR 1910.1017, vinyl chloride; testing procedures. The AIA/NA
air respirator should be required.. . .
and 29 CFR 1910.1045, acrylonitrile).
commented (hat there is no need for
Techniques have progressed so that relatively low levels of asbestos can be maintained in the workplace. Rather than required air-supplied respirators in all removal and demolition operations, the type uf respiratory protection selected should correspond to the highest concentration of
Therefore. OSHA has developed the protocol contained in Table D-4 of the standard for the application of respirators, which:
(1) Allovys the use of negativepressure air-purifying respirators
fitting protocols to be rigidly specified in the final standard, because techniques are widely published in industrial hygiene publications and because the 29 CFR 1910.134 requirement that the respirator be worn in a test atmosphere
asbestos anticipated in the particular
equipped with high-efficiency filters for as part of the training
workplace. (F.x. BO-182]
concentrations, of asbestos fibers less
program . . . would allow employers
Similarly, Richard Roll, Assistant Vice than 10 times the PEL
Ihe flexibility to take advantage of
President for Bell Communications
(2) Allows the use of full-facepiece
improvements in fit-testing procedures
Research, stated:
air-purifying respirators with high-
in future years" (Ex. 328).
Ihe requirements of the present standard Tor a supplied air respirator whenever
asbestos is removed are over restrictive in many work situations. Almost all'
efficiency filters for concentrations of
asbestos fibers less than 50 times the PEL
(3) Allows the use of'powered air-
Many commenters favored the use of either quantitative or qualitative fit- . testing procedures or both. The BCTD's recommended standard requires
maintenance activities on asbestos covered purifying respirators with high-efficiency quantitative fit testing to be performed
piping and equipment involve the removal of filters or half-mask supplied-air
on an employee before he or she begins.
some of the asbestos insulation material. Work practices (wet methods, enclosure, vacuum systems) have been developed to minimize the potential for employee exposure in those situations. It ntakes no sense to; require supplied air respirators in these work operations merely on the technicality that
respirators operated in the positivepressure mode for concentrations of asbestos fibers less than 100 times the
. PEL (4) Requires the use of full-facepiece
supplied-air respirators operated in the
any asbestos-related work and'at least
annually thereafter, and whenever an employee's facial features change or
other conditions of wear affect fit. The BCTD's standard requires daily qualitative fit testing, using methods that
some'asbestos material wilt be removed.
positive-pressure mode or full-facepiece are adequate to ensure a proper fit for
Respirator selection should be a function of self-contained breathing apparatus
half-mask negative-pressure respirators.
airborne fiber concentration rather than category of work. (Ex. 90-173)
operated in the positive^pressure mode for concentrations of asbestos fibers
An article published in the American Industrial Hygiene Journal in February, .
Julia L. Phillips, an.Attorney with the that exceed 100 times the PEL
1983 (K. E. Hardis, C. A. Cadena, C. A. j
Environment, Materials and Logistics
Data presented by the Building Bhd
Carlson, R. A. da Roza, and B. ]. Held; {
Division of E. I. DuPont de Nemours and Construction Trades Department, AFL- American.lndustrial Hygiene . .
)
\Company noted that air line respirators C10 (Ex; 330) indicated that the proper Association Journal (44) February, 1983)
and self-contained.breathing apparatus use of respirators may depend, to a large presented data on the effectiveness of i
had significant disadvantages when
extent, on the workers comfort and
qualitative fit-testing protocols for
'
used in asbestos abatement projects (Ex. preference for various types of
detecting poorly Fitting facepieces with !
339). Ms. Phillips stated:
respirators. Therefore OSHA has
protection factors greater than 10. This I
Air line respirators of. sclfcontained breathing apparatus (SCBA) create safety hazards in a complicated [asbcstos| removal
required that employers provide powered air-purifying respirators for employees who request them for
article reported that for a fit-factor of 10,
93 to 100 percent of poorly fitting' half mask respirators could be detected by
operation where workers are constantly
concentrations of asbestos Fibers less
qualitative methods. The article also
climbing or descending ladders or scaffolding oecause of the increased risk of tripping and tailing. (Ex. 339)
than 100 times the PEL OSHA believes that this provision will increase the effectiveness of respiratory protection
reported that, when used (o'test for a fit factor of 100, qualitative.methods were capable of detecting only 23 to 46
OSHA agrees that positive-pressure programs while allowing employers to percent of the inadequately fitting full-
supplied-air respirators provide ar '"
select the most cost-effective respiratory facepiece respirators.
greater level of protection than do half protection options that will reduce
Therefore, based on these data.
mask negative-pressure respirators.
exposure to below the PEL
OSHA has allowed in paragraphs
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