Document O37MBoOpkBgM9zBV3yMXpgwYL
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Federal Register / VoL 51. No, 119 / Friday, June 20. 3986 / Rules and Regulations
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t' pliability and minor'surface defects--will
OSHA believes that employers should
i 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 requirementsfor respirators (Exs. 263; 330; 123-A; 90233; 302; 322; 328; Trs. 8/21, p. 75; 0/29, 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 commenters requested that the respirators cannot be ignored. OSHA
testing be required. For example. NIOSH
selection of respirators be dictated by
believes that respirators should be
commented, ", . . we want to reiterate
the exposure levels that exist in the
selected that both provide adequate
our position that we recommend a
workplace environment (Exs. 90-160; 90-173. 90-182; 339; Tr. 7/12. p. 338). For example, the Industrial Safety
protection from exposure to airborne, asbestos fibers and minimize the risk of accident and injury potentially caused
quantitative respirator fit-testing program as previously stated in comments on the proposed lead
Equipment Association staled:
by the use of cumbersome supplied-air standard" (Ex. 117-A).
respirators. In addition, OSHA has
Conversely, the Asbestos Information
i The type of respirators to be required for employees engaged in spraying, demolition, and removal operations should depend on the airborne exposure levels measured for each
historically used a tiered approach to the application of respiratory protection in nearly all standards governing
Association/North America (A1A/NA) stated that the record does not support that quantitative flt-testing procedures
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exposed person and the proper type of respirator should be selected accordingly. If
occupational health hazards. (See, for example. 29 CFR 1910.1047. ethylene
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
nir respirator should be required.. . .
and 29 CFR 1910.1045. acrylonitrile).
commented that 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
Therefore. OSHA has developed the protocol contained in Table D-4 of the standard for the application of respirators, which:
(1) Allows the use of negative-
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
correspond to the highest concentration of
pressure air-purifying respirators
respirator be worn in a test atmosphere
asbestos anticipated in the particular
equipped with high-efficiency filters for as part of the training
workplace. (Ex. 99-182)
concentrations, of asbestos Fibers less
program . . . would allow employers
Similarly, Richard Roll, Assistant Vice than 10 times the PEL.
the 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).
The requirements of the present standard
$
for a supplied air respirator whenever asbestos is removed are over restrictive in
many work situations. Almost alb
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.
respirators operated In the positive-
Work practices (wet methods, enclosure, vacuum systems) have been developed to minimize the potential for employee exposure-
pressure mode for concentrations of asbestos fibers less than 100 times the
in those situations. It makes no sense to-
. PEL.
require supplied air respirators in these work
(4) Requires the use of full-facepiece
operations merely on the technicality that
Bupplied-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 will 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
airborne fiber concentration rather than
operated in the positive:pressure mode
category of work. (Ex. 90-173)
for concentrations of asbestos fibers
half-mask negative-pressure respirators. An article published in the American Industrial Hygiene Journal in February, .
Julia L. Phillips, an Attorney with the that exceed 1(M tigies the PEL.
1983 (K. E. Hardis, C. A. Cadena, C. A. j
Environment, Materials and Logistics
Data presented by the Building and
Carlson, R. A. da Roza, and B.). Held; |
Division of E. f. DuPont de Nemours and Construction Trades Department, AFL- ' American.Industrial Hygiene . .
j
Company noted that air line respirators CIO (Exl 330) indicated that the proper Association Journal (44) February, 1983) '
and self-contained breathing apparatus had significant disadvantages when
Juse of respirators may depend, to a large presented data on the effectiveness of I
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 j
339). Ms. Phillips stated:
respirators. Therefore OSHA has
protection factors greater than 10. This 1
Air line respirators or. selbconlained breathing apparatus (SCBA) create safety
required that employers provide powered air-purifying respirators for
article reported that for a fit-factor of 10, 93 to 100 percent of poorly fitting'half
hazards in a complicated (asbestos| removal employees who request them for
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 than 100 times the PEL. OSHA believes
oecause of the increased risk of tripping and that this provision will increase the
i 4, tailing. (Ex. 339)
effectiveness of respiratory protection
reported that, when used to test for a fit factor of 100, qualitative.methods were capable of detecting only 23 to 48
OSHA agrees that positive-pressure programs while allowing employers to percent of the inadequately fitting full-
supplied-aif respirators provide a
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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