Document Ra32vMzoEpR1QaDOdLxB3RO8z

**> PLAINTIFFS EXHIBIT 05HA Changes to 1910.134 On February 10, 1984, OSHA published a final rule on the Revocation of Advisory and Repetitive Standards. One of the standards affected was 29 CFR 1910.134 entitled "Respiratory Protection." The changes to 1910.134, which were . put into effect immediately, are as follows: (a) paragraph (b)(4) is removed O (b) the second sentence of paragraph (b)(5) is removed (c) the fourth, fifth, and sixth sentences of paragraph (e)(2) are removed (d) the second and third sentences of paragraph (f)(3) are removed Items (a), (b), and (c) refer to the issuance or permanent assignment of respi rators to individuals for their exclusive use. Items (b) and (d) refer indirectly to the cleaning of respirators by the individual wearer. /<(Editor's Note: These amendments to 1910.134 are a large leap forward- in assuring adequate protection to the 'respira tor wearer. The Respirator News has been of the opinion for a long time that personally issued respirators, especially where the user is responsible for his or her own cleaning and maintenance, can seldom O work. The user is almost never adequately trained in, or cognizant of, the need for proper respirator inspection, cleaning, and maintenance. These functions can best be carried out efficiently anct properly in a central location by person(s) who are thoroughly knowledgeable about respirators and their parts. Also, a central facility can be used to stock all of the replacement parts for respirators, and can have a fully functioning cleaning operation.) Asbestos ETS Invalid On November 4, 1983, OSHA had published an Emergency Temporary Standard (ETS) for Occupational Exposure to Asbes tos. The ETS was to have become effective on its publication date. However,. on November 23, 1983, the U.S. Court of Appeals for the Fifth Circuit granted the Asbestos Information Association's request for a temporary stay of the ETS. (Editor's Note: See The Respirator News, Vol. 2, No. 1 for a description of the respirator protection requirements of the ETS.) On March 7, 1984, the Court stayed the enforcement of the asbestos ETS, stating that ". . . OSHA did not invoke its ETS powers properly." OSHA had based its 1983 ETS lower ing the PEL for asbestos to 0.5 fiber fee on data which led OSHA to conclude that "a grave danger" exists, necessitating immediate action, rather than promulgation of a new permanent rule through the normal rulemaking process. However, in the decision of the Fifth Circuit in "Asbestos Information Association et al vs. Occupational Safety and Health Administration," the judge states that ". . . although asbestos doubtless may DPMC-13522 LAM 012151 present a grave danger to workers, the record considered as a whole does not substantially support OSHA's conclusion that an ETS lowering worker PEL from 2.0 fibers/cc to 0.5 fibers/cc is necessary-to alleviate a grave risk of worker deaths during its sixth-month term." The judge also states that . . the probable practical effect of the ETS, which allows compliance through 'any feasible combination of engineering controls, work practices, and personal protective equipment and devices,' would be that employers would require employees to wear respirators." In summary, the Court stated, "We determine the Emergency Temporary Standard to be invalid because the record, considered as a whole, does not Indicate that the risk the ETS seeks to eliminate is 'grave1; as OSHA itself has defined it, or that the ETS is 'necessary' as those terms are used in the ETS statute." On April 10, 1984, OSHA published a proposed rule entitled "Occupational Exposure to Asbestos," which, together with the ETS of November 4, 1983, constitute proposed revisions to OSHA's permanent asbestos standard. The proposed revisions apply to all workplaces, including general industry, construction, and maritime. Two alternative permissible exposure limits (PEL's) of 0.2 or 0.5 fibers/cc are set forth as the 8-hour time-weighted average (TWA) concentration of asbestos fibers longer than 5 microns. OSHA proposes to permit any feasible combination of engi neering controls, work practices, and personal protective equipment to reduce exposures from 2 f/cc, the present PEL, to the new PEL. However, OSHA is maintain ing the existing provision in the asbestos standard that requires the employer to implement feasible engineering and work practice controls to achieve the 2 f/cc exposure limit. Because OSHA recognizes the exis tence of problems inherent with using respirators in the workplace, new provisions are being considered that may increase the effectiveness of respirator use to achieve compliance with the new PEL. Qualitative or quantitative fit testing may be required, as in the lead standard. OSHA may require the employer to provide several sizes of respirators to employees so that the best fitting may be chosen. Also, OSHA may require the use of powered air-purifying respirators (PAPR's) or supplied-air respi rators in some circumstances, such as spraying, demolition, and removal operations. OSHA is also considering requiring the use of high-efficiency filters when air-purifying respirators are used. As in the ETS, section (k) of the new proposed standard contains a table for selecting respirators when these devices will be used to achieve compliance with the new PEL of 0.2 or 0.5 f/cc. According to the table, which is entitled "Respiratory Pro tection for Airborne Concentrations of Asbestos," the following respirators are specified for different airborne concentra tions of asbestos fibers: (1) reusable or single use air-purifying respi rators for concentrations not in excess of (2 or 5) f/cc (10 x PEL); (2) full facepiece air-purifying respirators or PAPR's for concentrations not in excess of (20 or 50) f/cc (100 x PEL); and, (3) type "c" continuous flow or pressure demand, supplied air respirators for concen trations greater than (20 or 50) f/cc. In addition, a respirator specified for high concentrations may be used at lower concentrations. The proposal also requires in para graph (1) that employees be informed and trained about asbestos exposures, including: the health effects of asbestos exposure; the importance of using protective controls, such as respirators; and the purpose, proper use, fitting instructions, and limitations of respirators permitted by the standard. Rulemaking hearings were held during September, 1984 at the Department of Labor, Washington, D.C. Written comments on any aspect of the asbestos standard may continue to be submitted to the Docket Officer, Docket No. H-033C, Room S-6212, USDOL, 3rd Street and Constitution Avenue. DPMC-13523 LAM 012152 N.W., Washington, DC 20210. OSHA wi^l review all information gathered at the hearings and submitted in writing, and ex pects to issue a final standard at some ^ future date. (Editor's Note: A copy of the Ohio Monitor is enclosed for paid subscribers. Other readers may obtain a copy of the article by contacting The Respirator News). (Information Source: Occupational Safety and Health Reporter, Bureau of National Affairs, March 15, 1984; Federal Register Volume 49, No. 70, April 10, 1984). Technical Manual On March 30, 1984, OSHA issued Instruction CPL 2-2.20A, establishing the new Industrial Hygiene Technical Manual. The Technical Manual replaces the Industrial Hygiene Field Operations Manual (IHFOM), and reflects current OSHA industrial hygiene practices and procedures. The Oregon Lung Association has recently published a document entitled "Warning Properties of Industrial Chemicals." The document lists data from various sources for odor thresholds and irritation levels for a variety of chemical substances. This document can serve as a useful refer ence for the respirator program supervisor who must select suitable respiratory protec tive equipment for a workplace. Copies may be obtained from: Occupational Health Resource Center, Oregon Lung Association, 319 S.W. Washington, Suite 520, Portland, Oregon 97204. To Chapter V is entitled "Respiratory Protection,", and provides instruction to the OSHA compliance officer in issuing citations for violations of respirator standards. Ex planation is provided for respirator program --' elements such as written standard operating procedures, respirator selection, training, fit testing, etc. Much of its content is taken Q from ANSI Z88.2-1980. According to an OSHA spokesperson, copies of the new Manual can be obtained from local OSHA area offices. PUBLICATIONS The Industrial Commission of Ohio published an interview with Darell Bevis, the editor of The Respirator News in the May, 1984 issue of their publication, the Ohio Monitor. The interview article was written by Bob Crackel, Industrial Hygienist; and is entitled, "Imposing Questions Require Straightforward Answers." In the article, Mr. Bevis answers a series of -questions about the elements of a respirator program, respirator certification; beards and respira tors, single-use respirators, and about other topics of interest to the respirator program supervisor. (Editor's Note: Paid subscribers to The Respirator News will find this document as an insert in this issue.) A paper has been developed by NIOSH entitled "Experimental Design and Research Protocol to Investigate the Relationship Between Fit Factors and Workplace Protec tion Factors for Half-Mask Respirators." The study protocol has been designed to collect the following respirator performance infor mation: quantitative facepiece fit test data; qualitative fit test data; and workplace protective factor data. Data and results obtained from the study will be used to determine if a relationship exists between quantitative fit factors and workplace pro tection factors for chemical cartridge, half-mask respirators used in various work place activities and environments, and to provide information upon which to base additional research efforts for estimating the workplace performance of a respirator from laboratory tests. Copies of this study may be obtained from Warren R. Myers, NIOSH, Testing and Certification Branch, 944 -Chestnut Ridge Road, Morgantown, West Virginia 26505, (304) 599-7331. (continued) O 3- - DPMC-13524 LAM 012153 The January, 1984 issue of the 'Inter national Society for Respiratory Protection (1SRP) contains an article entitled "Respi rators: How Well Do They Really Protect?" written by Edwin C. Hyatt of Los Alamos, v New Mexico. The author states -that advances in respirator technology as well as laboratory QNFT studies, have provided data which indicates that high protection factors are achievable with respiratory protective devices. However, laboratory fit factors are not equivalent to the level of protection afforded in the workplace, even when a good respirator program is in use. The author cites results from numerous studies to illus trate performance evaluations during actual use for supplied-air and air-purifying respi rators as well as self-contained breathing apparatus (SCBA's). To summarize, the author states that, except in non-routine or emergency use situations, respirators cannot protect workers as well as'suitable engineer-ing controls. "The Effect of Facial Hair on the Face Seal of Negative-Pressure Respirators" by Orrin Skretvedt and Joseph Losciavo was published in the American Industrial Hygiene Association Journal of January, 1984. This' article provides results of a study performed on 370 male employees, 67 of whom were bearded. The employees were tested wearing both half-masks and full facepieces, and were fit tested with qualitative and quantitative methods. Results indicated that the presence of a beard greatly increases the leakage through the respirator face seal, and supports the position that facial hair should not be permitted with respirator use. Darell Bevis Associates, Inc. now has available a slide presentation entitled "The Elements of a Respirator Program." This slide package was prepared for the respira tor program supervisor for use in respirator user orientation sessions to gain employee participation. The presentation is also suitable for showing to upper level manage ment to obtain support for the adoption of a compliance respirator program. The slide presentation is accompanied by an Instruc tor's Manual with complete script and copies of OSHA's 1910.134 and ANSI Z88.2-1980. LEGAL Decision Affirmed Tn.Vol. 1, No. 3 of The Respirator News, a synopsis of an order by the Occupational Safety and Health Review Commission regarding the Bethlehem Steel Corporation was provided in the "Legal" column (No. 11 OSHC 1247). Bethlehem Steel had petitioned the U.S. Court of Appeals for the Fourth Circuit for a review of the order. Recently, the Court reaf firmed the Review Commission's order which found that Bethlehem Steel had violated 29 CFR 1915.33(c)(1) involving burning and welding operations on ste^J surfaces coated with Rust-Ban 191, a metallic coating con taining zinc. The employer had contended that the requirements of 1915.33(c), for the -use of airline respirators by employees per-; forming welding in enclosed spaces on' surfaces covered with toxic coatings, would be triggered only when the level of zinc, oxide exceeds the TLV of 5 mg/nA The recent decision by the Court of Appeals affirmed the Review Commission's finding that 1915.33(c) does not apply only to situations where a TLV has been exceeded, and does not specify level of contaminants as necessary to trigger worker protection. (Information Source: Occupational Safety and Health Reporter, Bureau of National Affairs, March 15, 1984. 'Also see Vol. 1, No. 3 of The Respirator News.) Employee At Fault The Occupational Safety and Health Review Commission recently issued a final order in a case involving an employee death at Lockheed Shipbuilding and Construction Company (OSAHRC Docket No. 81-2173). An employee of Lockheed had been assigned to spot clean a crane cab using the cleaning solvent Naccolene, and was over come by vapors. After their inspection following the fatality, OSHA issued a cita tion for a serious violation of 29 CFR 1916.21(a) for failure to use adequate DPMC-13525 /. LAM 012154 natural ventilation or mechanical exhaust ventilation or to use suitable respiratory protective equipment. (This standard is now contained in the new part 1915.32.) An inspection of the work area, made immedi ately after the employee was taken to the hospital, indicated that the employee had dismantled the spray gun he had been using to apply the Naccolene, and had emptied a five-gallon can of the solvent in a extremely short time. The evidence shows that this employee's acts not only violated Lockheed's safety rules and procedures for use of the solvent and the work equipment, but were contentious of ordinary good sense. According to the Review Commission Judge's report, prior to the accident, Lockheed had in place an effective safety program for its employees, including instruc tions dealing with the use and application of toxic substances and significant instruction on the proper use of safety equipment, including respirators. Lockheed rules, communicated through employee training sessions, provided, for example, that if an employee recognized the odor of Naccolene - coming through the respirator, he must dis continue work, leave the area, and contact a supervisor who would determine how to rectify the situation. Lockheed also had well-established safety practices governing the use of Naccolene, and its use with a spray gun was limited. The judge's report also states that the employee who was over come was experienced and trained, and that on the night of the accident, there was no indication that he would, at the end of his work shift, deviate from his past conduct and embark on a successive series of viola tions of Lockheed's safety procedures. The Review Commissioner felt that the Secretary of Labor had failed to prove his case that the ventilation present at the time was insufficient to render the work place safe, and that the employee's respi rator was insufficient to protect him from the toxic substance. Rather, the Commis sioner felt that the evidence failed to show that the employer created or allowed an unsafe or .non-complying condition to exist, or that the quantity of natural ventilation was insufficient for the usual or prescribed use of the solvent. In addition, the respirator worn was suitable for the proper use and application of the solvent. The Commissioner felt that the alleged violation was caused solely by the isolated act of a trained employee, contrary to established and communicated rules, and must be con sidered as idiosyncratic in nature. Thus, the Secretary failed to show that the employer knew or should have anticipated the unsafe condition caused by the employee's idio syncratic behavior. (Information source: Occupational Safety and Health Reporter, Bureau of National Affairs, January 12, 1984.) Respirator Instruction A citation for several violations was issued by OSHA following an investigation into a fatal accident at Kenco Casing and Pulling, Inc. The accident occurred at the employer's well site when certain compo nents (valves, nipples, and unions) failed under pressure, causing an explosion. The OSHA compliance officer noted that a warning at the well site indicated the presence of H2S gas, exposure to which could result in fatal injuries if employees have not had proper training in the use of SCBA's (self-contained breathing apparatus). Company representatives told the OSHA compliance officer that they had no com prehensive safety training program, but that they did prescribe to on-the-job training, films, and verbal communications to em ployees. Thus, the company was cited for an alleged violation of 29 CFR 1910.134 (b)(3) in that the users of respirators were not instructed and trained in the respirators and their limitations. The Review Commission issued a final order which vacated the alleged violation of the respirator standard because it appeared that the employee who was thought not to have had training with SCBA respirators actually had had training in their use under another employer. The Review Commission felt that the standard does not require that the employee's specific employer must have given him the training. (Information source: Occupational Safety & Health Reporter, Bureau of National Affairs, May 17, 1984.) DPMC-13526 LAM 012155 NUCLEAR Information Notices Recently, the Nuclear Regulatory Commission (NRC) published four Information Notices related to respiratory protection. The Information Notices of April 23, 1984 and Duly 10, 1984 are described in this issue under the NIOSH column since they incor porate two NIOSH Respirator Users Notices. On April 5, 1984, NRC published Information Notice No. 84-24: Physical Qualification of Individuals to Use Respi ratory Protective Devices. The purpose of the Notice is to discuss the death of a 24-year-old individual, who had been medically qualified to wear respirators, and who collapsed while wearing an air-supplied hood. The Notice provides guidance to the licensee to aid physicians in making a medical determination of a worker's ability to wear respirators, to comply with 10 CFR 20.103(c)(2). On August 6, 1984, NRC published Information Notice No. 84-60: "Failure of Air-Purifying Respirator Filters to Meet Efficiency Requirements." The purpose of the notice is to notify addressees of the failure of approximately 5 percent of MSA Ultra Filters used in negative-pressure respirators, and filters used In powered air-purifying respirators (PAPR's). These filters failed to meet NIOSH/MSHA certi fication requirements in 30 CFR 11 that high-efficiency filters be at least 99.97 percent efficient against a thermally gen erated, monodisperse 0.3 micron aerosol of dioctyl phthalate (DOP). The notice also provides guidance for establishing a Quality Assurance (QA) program for respiratory equipment used in a nuclear facility. Copies of Information Notices 84-24 and 84-60 are included as inserts in this issue. NEW PRODUCTS Silicone Facepieces North Safety Equipment, (formerly Norton, Siebe Norton) has_announced the availability of their new 7700 series, silicone rubber facepieces. The half-mask facepieces are available in three sizes. The North 7700 series respirator uses a cradle suspension system which includes a rather innovative top headband. Although the 7700 series respirators are quite different in configuration from North 7500 series respirators, both series use the same filters and cartridges. For additional information, contact North Safety Equipment, 2000 Plainfield Pike, Cranston,- Rhode Island 02920; (401) 943-4400. THE RESPIRATOR NEWS Editor: Darell A. Bevis The Respirator News is published by Darell Bevis Associates, Inc., Route 2, Box 311, Sterling, Virginia 22170, (703) 430-7100. Subscription rates are $375.00 for 12 issues or $210.00 for 6 issues (between 6 and 12 issues are published per year). The Respirator News is protected under jthe copyright laws of the U.S. and Virginia. Re production in whole or in part without the written permission of the publisher is prohibited. Unless otherwise stated, those columns entitled "Letters to the Editor," "Technically Speaking," "Prod ucts Review," and "From the Editor" may contain information which ex presses the opinion of the editor and/or author. The Respirator News is printed in the U.S.A. Copyright, 1984 Darell Bevis Associates, Inc. _ c _ DPMC-13527 LAM 012156 PRODUCTS REVIEW ' Smoke Tubes For many years, there has been con siderable confusion with the use of irritant smoke for respirator facepiece fit testing. That confusion has not been helped by the fact that, until recently, there has been no definition of acceptable qualitative respi rator fit test protocols. Until about five years ago, most respirator users were unaware of OSHA's requirement for fit testing respirators by exposure to a test atmosphere. This requirement is found in OSHA's General Industry Standards, 29 CFR 1910.134(e)(5) which states, in part: "Training shall provide the men an opportunity to handle the respirator, have it fitted prop erly, test its facepiece-to-face seal, wear it in normal air for a long familiarity period, and, finally, to wear it in a test atmosphere." This requirement remains un changed from its first publication in 1972. OSHA has recently begun to enforce the requirement for respirator fit testing and, -'more importantly, to define respirator fit testing. OSHA sets forth requirements in several standards for specific substances for either quantitative or qualitative fit testing. Quantitative protocols have yet to be defined; however, OSHA has defined quali tative fit tests protocols very recently in Appendix D to the lead standard (29 CFR 1910.1025). In Appendix D, OSHA accepted three test atmospheres, one of which was described as an "irritant fume." Use of irritant smoke in respirator fit testing dates back to the late 1950's or early 1960's when contractors to the Atomic Energy Commission began experimenting with venti lation smoke tubes as a means to generate a respirator fit test atmosphere. This experi mentation and research was applied to the original respirator protection factor studies done by the Los Alamos Scientific Labora tory, Lawrence Livermore Laboratory,, and Dow Chemical Company at Rocky Flats in Colorado. During that era of research, very few ventilation smoke tubes were available, and it was learned very early that only one, the MSA Part No. 5645, produced a smoke ~7 atmosphere with desirable irritating quali ties. Virtually all of the protection factor data for irritant smoke was based on the use of the MSA Part No. 5645 tube. Because of the results of the research and testing with these tubes, irritant smoke became a standard test atmosphere use"3 in qualitative fit testing of respirators. MSA Part No. 5645 ventilation smoke tube is a glass tube filled with pumice which is impregnated with stannic chloride. The tube releases stannic oxychloride, a primary irritant to the respiratory system, which produces a desirable result in respi rator fit testing. Ventilation smoke tubes from other manufacturers produce dense clouds of white smoke generated from sulphur trioxide or titanium tectrachloride. The smoke or fumes generated by such tubes produces very little or no irritation. As irritant fume fit testing became more popular, some users began to purchase any available ventilation smoke tube to perform their fit testing. However, fit tests done with smoke tubes other than the appro priate MSA tube produce results quite different from those published in the pro tection factor studies. American National Standard "Practices for Respiratory Protection," ANSI Z88.21969, added to the confusion. In a discus sion on facepiece fit tests and procedures, the standard described the use of the pumice tube impregnated with stannic chloride and then stated that a similar smoke was produced with a sulphur trioxide or titanium tetrachloride tube. That erron eous statement was deleted when Z88.2 was rewritten and published in 1980, and only tubes producing stannic oxychloride were referred to. OSHA also refers to this specific type of tube in the irritant "fume protocol in Appendix D of the lead standard. Directions state: "break both ends of the ventilation smoke tube contain ing stannic oxychloride such as the MSA Part No. 5645 or equivalent." At this point in time, there is no equivalent, to the MSA Part No. 5645 smoke tube. .If irritant smoke is to be used for respirator fit testing, only the use of stannic oxychloride smoke will assure acceptable results. DPMC-13528 LAM 012157 FROM THE EDITOR Sampling Breathing Air OSHA's General Industry Standard, 29 CFR 1910.134 entitled "Respiratory Protec tion," states in subparagraph (d)(1) that: "Breathing air shall meet at least the requirements of the specification for Grade D breathing air as described in Compressed Gas Association Commodity Specification G-7.1 - 1966." CGA pamphlet G-7.1 which has also been adopted by the American National Standards Institute and has been labeled ANSI Z-86.1, defines grades of air by listing the maximum concentrations of components. Grade D air, whether synthesized or compressed atmospheric air, must have between 19 and 23 percent oxygen (v/v), with the balance predominately nitrogen. While the allowable water content of Grade D air is not specified, any condensation moisture must be avoided during use of the respiratory protective device. Though not specified, totally dry air, such as instrument air, should not be used. Studies have shown that the extended use of dry air can cause distress in some respirator users. A maximum of 5 milligrams of condensed hydrocarbons per cubic meter (mg/m^) of gas is allowed at normal temperature and pressure. Five mg/m^ is the PEL for oil mists which are generally our prime concern. A maximum of 20 parts per million (ppm) carbon monoxide is allowed. Odor is a specific concern in breathing air. However, specific measurement of odor in air is impractical. Normally, air may have a slight, odor, but the presence of a pronounced odor should render the air unsatisfactory for breathing purposes. Finally, a maximum of 1000 ppm of carbon dioxide is allowed in Grade D air. In addition to specifying maximum concen trations of specific substances, we must also consider that any other substance present in the air in a concentration above its PEL would render the air unsuitable for breathing purposes. The logical and often frustrating question that follows the definition for breathing air is: "How can I determine or verify the quality of our breathing air?" It is impossible to answer this question completely since all users' capabilities and facilities will vary widely. However, 1 will discuss some general considerations and sampling methods which will apply to most workplace conditions. The first consideration must be for choosing a sampling location. "Building" air supplies require distribution piping which may well become contaminated. Thus, the air samples should be taken to represent not only the output from the compressor or cylinders but also the air that passes through possibly contaminated distribution lines. It is always recommended that air samples be taken from a manifold or con nection where the breathing air is distrib uted to the airline respirators or to the hose connecting to the pressure-reducing regula tor. The easiest and most accurate method to determine air quality is to take a sample into an evacuated cylinder or appropriate sample bag for delivery to a properly equipped laboratory. Analytical results from gas chromatographs or infrared spectrophoto meters will provide everything you always wanted to know about your breathing air and more. However, access to a properly equipped laboratory may not always be possible, particularly for smaller employers. The second most desirable method involves using a specially designed sampling kit which can be rented from a laboratory who will also perform the complete air quality analysis for a fee. The problems associated with this method are: 1) it does take time to mail the kit- back to the laboratory and to receive your sampling results; and, 2) we are aware of only one source for this type of service. The source that we have verified as being accurate and DPMC-13529 LAM 012158 reasonable in cost is Texas Research Insti tute, Inc., (TRI). Further information can be obtained by contacting TRI, Environ mental Division, 9063 Bee Cave Road, Austin, Texas 78733; (512) 263-2101. Now we can discuss some methods of sampling to obtain immediate results. Three basic rules must be followed. First, sample air which is representative of that air entering the approved respirator. Use a sample containment, such as a simple plastic bag purged with the air to be sampled, to collect the air from the cylinder or airline outlet. Second, use proper sampling tech niques. Follow the manufacturer's instruc tions for the sampling instruments exactly. Third, use reliable, and accurate sampling instruments. Detector tubes do not provide suf ficient accuracy for determining air Quality. When you consider ^hat detector tubes and the associated sampling pumps may produce error in access of 100 percent, it becomes very difficult to understand why so many respirator users place so much reliance upon them for determining air quality. I have yet to find a detector tube that will accurately measure oil mist in air. However, such tubes are marketed. The only use I have found for detector tubes for determin ing air quality is for quick determination of the presence of carbon monoxide. This requires the use of a sufficiently low range detector tube that will distinctly show the presence of 5 parts per million or less of CO. Portable direct reading electronic instruments are the only reliable and accurate type of instrument that can be employed for determining air quality in the field. With these three simple rules in mind, we can now discuss some sampling methods and instruments that might be used along with sound professional judgement to determine the suitability of your breathing air. To sample with any of the .direct reading instruments, follow this procedure: place the sample containment, such as a simple plastic bag, loosely over the end of the outlet. Flow sufficient air into the containment to purge the bag totally. Then adjust the air flow to a very low rate just sufficient to maintain a positive-pressure within the containment and place the samp ling probe from the instrument into the bag or containment.- To sample for percent oxygen a direct reading electronic instrument is most desirable, and is relatively inexpensive. As an alternative, a liquid oxygen indicator such as the "fyrite" indicator has been proven to be very accurate if maintained and used properly. For carbon monoxide sampling, the portable electronic direct reading instru ments are most desirable. However, as mentioned earlier, for a quick test a very low range carbon monoxide detector tube may be used. Remember that-when using the detector tube, you should hot attempt to quantitate the amount of carbon monoxide present. If any stain is noted, you should use better instrumentation for quantitating the carbon monoxide. To sample for condensed moisture or condensed hydrocarbons (oil mist), a simple impaction method of collection might be used. If collecting a sample from a cylinder air supply, the cylinder should be stored in an inverted position with the valve at the bottom for at least five minutes prior to performing the test. The test is performed by holding a shiny metal disk or clean mirror, equilibrated to room tempera ture, or an open dry container close to the air outlet and blowing the air at a very low flow rate against or into the collection device. The air flow should be barely audible since a rapid gas flow may cause any condensate to disperse and not to collect. The presence of any moisture on the impaction plate or container would indicate the need for further analysis to identify the nature and amount of the moisture. With the exclusion of laboratory analysis, the only accurate method of quantitating condensed hydrocarbon is to collect a sample on a pre-weighed filter paper. About the only field method for determining carbon dioxide concentration is the use of detector tubes. Realizing the inaccuracy of detector tube sampling, you DPMC-13530 LAM 012159 must consider the results obtained to be a very conservative estimate of carbon dioxide concentration. Carbon dioxide concentration is very seldom found to be a problem in breathing air. Finally, to determine a potential odor problem, one can only sniff the air from the sample containment. As you can see, it is extremely difficult to define a method of determining air quality that could be applied by all respirator users. My attempt has been to make you aware of some methods that have been used successfully by other respirator users and some methods that have been unsuccessful. May I offer a toast to adequate air quality for respirator users. Happy sampling! Dear Subscriber: We sincerely apologize for the long delay in publishing this issue of the newsletter. Darell Bevis Associates, Inc. is experiencing considerable growth, and we have found it necessary to totally upgrade our computer system. This has caused a three-month lag in virtually all of our activities. As always, we are striving to better serve our clients. We hope that the delay has not resulted in any major incon venience to any of our subscribers. We will again attempt to publish a new issue approximately every two months. Thank you for your patience with us. Sincerely, Darell A. Bevis Editor TECHNICALLY SPEAKING In Volume 1, No. 2, we published an article which had been submitted by Mr. Frank Tipton, formerly with the U.S. Department of Labor, Washington, DC. The article was entitled "Adjusting PF for Proximity of Exposure Level to IDLH." Mr. Tipton has written the following letter in response to questions posed by readers of The Respirator News: "Dear Darell: Thank you for publishing my note about adjusting the required respiratory protection factor as the exposure level gets close to the IDLH level. Unfortunately, it appears that the form in which I expressed the adjustment formula was overly compli cated. As a result, I would like to offer the same concept presented in a different manner mathematically equivalent to the original. The original expressions can be simplified by breaking them up into parts. To do so, we need some intermediate vari ables, which I label S for severity of ex posure and L for the logarithm term. Hence, Ca - PEL S =------------------ IDLH - PEL L = 9.21 + In PEL - In IDLH Then, the adjusted protection factor is higher than a simple multiple of the PEL'S according to Ca PF =----- Exp. (5 - L) PEL Perhaps in this form an adjustment to the PF would be more amenable to use by fellow professionals in field positions. Sincerely, - Frank Tipton" - 10 - DPMC-13531 LAM 012160 The following article was prepared by P. David Shafer, III who is well known for his work with the U.S. Environmental Protection Agency and as an instructor in HazMat response. Mr. Shafer currently serves as the course director for Darell Bevis Associates training entitled "Protecting HazMat Response Personnel." Levels of Protection ^ Over the last few years, with the advent of Superfund, respirators have left the traditional industrial workplace. Airpurifying respirators, self-contained breathing apparatus (SCBA), and airlines have become common on hazardous waste sites and on other hazardous materials incidents. Per sonnel from federal, state and local agencies, as well as engineers, geologists, well drillers, and clean-up contractors, have had to wear respirators as part of their normal site responsibilities. Response to hazardous materials incidents requires the use not only of respi rators, but also of specialized chemical protective clothing. To facilitate the selection of appropriate protective gear, the U.S. Environmental Protection Agency has devised what are called Levels of Protec tion. They are identified as Level A, B, C, and D, and indicate various degrees of hazard encountered during hazardous mate rials incidents. They range from ensembles with fully-encapsulating suits and pressure demand self-contained breathing apparatus (Level A) for extremely hazardous situations to basic work outfit without respiratory protection (Level D) for non-hazardous situations. Level A protection consists of pressure demand SCBA, fully-encapsulating chemical protective suit, steel toe and shank boots, disposable boots and gloves, and hardhat. This combination of equipment will provide the user with the highest degree of skin and respiratory protection. However, there are limitations. Level A equipment is very heavy and lacks ventilation, increasing the possibility of heat stress. Flexibility and vision range is also reduced making work more difficult to perform. Pressure demand SCBA is also used in Level B. Instead of the full suit, a one or two-piece splash suit is worn. Sleeved aprons are sometimes used as well. Other gear will include steel toe and shank boots, disposable boots and gloves, and hardhat. With Level B, the wearer has maximum respiratory protection, but skin protection is reduced. A splash suit with a hood will leave areas around the neck exposed to vapors and splashes. Two-piece suits will allow penetration at the waist. Generally, the EPA recommends that the cuffs of suits be taped to the sleeves and pants with masking or duct tape to reduce the chances of penetrations at those points. Level C protection maintains the same level of skin covering while reducing the respiratory protection to an air-purifying respirator. Obviously, the hazard is lower than for Level A or B. The EPA recom mends a full facepiece air-purifying gas mask. While a gas-mask canister provides a long service life, there are situations where twin-cartridge half and full facepiece respi rators are acceptable. The rest of the protective gear is the same as in Level B. In areas where no chemical hazards exist, respirators or chemical protective clothing are not required. Level D gear is specified for such areas and consists of a basic work uniform to provide protection against hazards. Included are steel toe and shank boots, coveralls, and eye, head and hand protection as necessary. Although each level*of protection specifies general components, the actual piece of gear used within a level can vary greatly. There are fully-encapsulating suits and splash suits constructed with many different features and protective materials. Disposable clothing may or may not be used. Specific pieces of gear will be selected based upon the types of hazards present and the activity to be performed. EPA has guidelines for the selection of a particular level of protection. The National Fire Protection Association makes some protection recommendations in its 704M Standard for Identification of Fire Hazards. Selection of equipment requires a careful evaluation of the situation and the toxic properties of the materials involved. - 11 - DPMC-13532 LAM 012161 Although HazMat response operations are not carried out in the usual industrial work environment, the same OSHA standards must be followed to protect workers. Any private company or contractor must set-up and maintain a respiratory protection pro gram using the requirements set forth in 29 CFR 1910.13*/ and ANSI Z88.2. Complying with requirements for Level A, B, or C protection does not assure the health and safety of response personnel working with hazardous materials. STANDARDS ANSI ZS8.6 Recently, the American National Standards Institute published ANSI Z88.6198*? entitled: "American National Standard for Respiratory Protection - Respirator Use - Physical Qualifications for Personnel." The - purpose of the standard is to provide de tailed guidance to the physician in determining which individuals should and should not be assigned to wear respirators. Also, the standard is meant to identify the responsibilities of the physician, the employee, and management in determining the employee's ability to use the respirator. Examination requirements are set forth to provide the medical examiner with meaningful information. One requirement is for obtaining background information such as the type of respiratory protection to be used; physical exertion required; and presence of special environmental conditions, such as excessive heat. Another require ment sets forth information which should be taken using a medical history questionnaire. A third section describes conditions to consider during the employee's medical examination, such as facial deformities, hearing requirements, respiratory and tardiovascular diseases, etc. A fourth section suggests special testing, such as spirometry and exercise stress testing. A copy of ANSI Z88.6-198*? may be obtained from the American National Standards Institute, 1*?30 Broadway, New York, New York 10018. SUBSCRIPTION INFORMATION Price for issues of The Respirator News is $373.00. Price for issues is $2i0.00. (Between 6 and 12 issues will be published per year.) Each subscription includes a binder. The following discounts will apply to the total price: 2 subscriptions 3-5 subscriptions 6-10 subscriptions 11-25 subscriptions 26 and over 10% 15% 20% 30% 40% Please enter my subscription for The Respirator News: _____ Full payment of $375.00 is enclosed for 12 issues. _____ Full payment of $210.00 is enclosed for 6 issues. _____ Please bill my company at the following address: Co. Name_____________ Address ATTN: __________________ Mail my subscription to: Name____________________ Co. _____________________ Address Tel. (______ ) I l b i ii. r i. *. ii l 10 _ DPMC-13533 LAM 012162 NIOSH Luxfer Aluminum Cylinders On February 29, 1984, NIOSH issued.a Respirator Users Notice concerning 4,500 psi hoop-wrapped aluminum cylinders manufac tured by Luxfer USA Ltd. (see "NIOSH" in The Respirator News, Vol. 1, No. 3). In the Notice, NIOSH states that DOT has deter mined that the maximum cylinder charging pressure must be reduced from 4,500 to 4,000 psi on the cylinders manufactured by Luxfer under Exemption DOT-E 7235. Also, NIOSH states that Luxfer has determined that some 4,500 psi^hoop-wrapped cylinders manufactured pripr to May, 1981, may rupture or develop longitudinal cracks in the threaded section of the cylinder neck. In the Users Notice, NIOSH lists the manufacturers and model numbers of NIOSH/MSHA approved self-contained breathing apparatus which incorporate the 4,500 psi/DOT-E 7235 hoop-wrapped aluminum cylinders. NIOSH has temporarily reduced the certification rated service times for these units from 30 minutes to not less than 25 minutes, because of the necessity of reducing the maximum service pressure from 4,500 to 4,000 psi. NIOSH also states that users of the listed SCBA's which incorporate the Luxfer cylinders in question should physically examine these cylinders. According to Luxfer, most of the 30-minute cylinders in question are used by the fire service. Luxfer is offering a payment to owners of $7.00 for each cylin der inspected in accordance with the rec ommended procedure. Luxfer will also supply labels reading 4,000 psi to be applied over the existing labels on cylinders on which 4,500 psi is marked. Questions about this matter may be directed to Mr. James Ament of Luxfer USA Ltd. at (714) 684-5110. On March 15, 1984, Mine Safety Appliances Co. informed its customers that none of fully-wound composite air cylinders are referred to on the NIOSH Notice of February 29. MSA explains that while their name appears on the NIOSH notice, and while they have NIOSH/MSHA approval to use the Luxfer hoop-wound cylinder with the Custom 4500 Air Mask, MSA has only sold 30- and 60-minute rated fully-wound com posite cylinders with their units. The U.S. Nuclear Regulatory Commis sion issued Information Notice No. 84-34 on April 23, 1984 to alert licensees of the Luxfer cylinder problem. Attached to Notice No. 84-34 was the NIOSH notice of February 29, 1984, the DOT notice from the Federal Register, and other pertinent information. NRC expects licensees to review all the information of Notice No. 84-34 and its attachments to determine if their facilities are affected, and to take action, as required, to maintain NIOSH and DOT certification for affected equipment, and to minimize the probability of cata strophic cylinder failure. A copy of the entire NRC Information Notice No. 84-34, with the NIOSH Respi rator Users Notice of February 29, 1984, is included as an insert in this issue. RAM-5 Notice On May 9, 1984, NIOSH issued a Respirator Users Notice concerning the Robertshaw RAM-5 Combination SelfContained and Supplied-Air Respirator, MSHA/NIOSH, Approval Number TC-13F-64. In the notice, NIOSH urges all users of the RAM-5 to comply with Robertshaw Controls Company's voluntary recall of this emer gency escape device. A leakage problem found with several RAM-5 units will result in shortened service time of the selfcontained air supply; the unit could also malfunction when used with supplied air. On July 10, 1984 the U.S. Nuclear Regulatory Commission issued Information Notice Number 84-56 on this same subject. Licensees were asked to review the informa tion contained in the notice, as well as in the NIOSH Respirator Users-Notice. A copy of the NRC Information Notice, with its attached NIOSH notice, is included as an insert in this issue. DPMC-13534 LAM 012163 LETTERS TO THE EDITOR ' Q: Can facial hair (beards) be worn with helmet-type powered air-purifying respira tors? A: I am frequently asked to comment on the safety and legality of allowing bearded individuals to wear helmet-type PAPR's. There are currently two approved helmettype PAPR's available. One is from 3M and the other from Racal. Both of the helmets on these apparatus have side shields made of rubber intended to seal against the face of the user. These rubber side shields are necessary to obtain* satisfactory test results for approval. In fact, at least one of the two manufacturers has multiple-sized side shields to allow for proper fitting of various individuals. Users of these apparatus seem to be of the opinion that since these devices are positive-pressure, the sealing surface need not seat to the face. However, lack of a proper faceseal can cause consid erable aspiration leakage to the inside of the hood. The aspiration leakage will depend on the size of the leakage at the sealing surface. These units, as well as any other respi rator that relies upon a seal against the face, are both illegal and unsafe to use when that seal is not proper. The OSHA regulation 29 CFR 1910.134(e)(5)(i) states: "Respirators shall not be worn when condi tions prevent a good face seal." A recent study conducted by NIOSH showed that 95% of a randomly selected group of individuals received protection factors of 33 or greater with these apparatus, and that the geometric mean protection factor was only 182 with a geometric standard deviation of 3.2. This study was done on individuals who were clean-shaven and who could get a proper seal with the helmets in place. In summary, all users of the helmet-type PAPR's should be aware that the protection factors afforded under the best conditions are very low, and that users who disturb the seal with facial hair, temple bars of glasses, or by any other means will probably cause additional leakage resulting in a far lower protection factor. Also, allowing users to wear these units when they cannot obtain a good seal, is a violation of the OSHA regulation, 29 CFR 1910.134(e) (5)(i). For additional information, see Vol. 2, No. 1 ("Attention: Users"), and Vol. 1, No. 2 ("Products Review") of The Respirator News. Q: Is it legal to use air-purifying respi rators for protection against benzene, based upon fit test results? A: Exposure to any level of a known or suspected carcinogen, such as benzene, is of tremendous concern. A corporate policy would be legal if air-purifying respirators were used for concentrations up to 100 ppm of benzene (10 x PEL), and if positivepressure atmosphere-supplying respirators were used for protection above 100 ppm. However, a safer policy would be to use positive-pressure, atmosphere-supplying respi rators for all_ work requiring protection from benzene, irregardless of the concentration present. It is a proven fact that all negativepressure respirators will leak in the facepiece-to-face seal during normal use in the workplace, even though fit testing has shown little or no penetration. The reason for this leakage is, of course, the vigorous move ments of the user in the workplace. These movements cannot be accurately predicted or simulated during laboratory-type fit testing. Legally, air-purifying respirators can be used up to 10 x the PEL of a substance when fit testing is performed. However, if an individual wearing that airpurifying respirator should contract leukemia, there is a strong potential that the individual could file suit charging negligence or gross negligence based upon the employer's not using the best possible respirator for protection against a known or suspect carcinogen. Said more simply, compliance with the law does not necessarily mean protection from litigation involving liability. DPMC-13535 LAM 012164 ATTENTION: USERS i Facial Hair and Respirators The controversy continues over the use of respiratory protective devices with facepieces by individuals with facial hair that protrudes into or through the sealing surface. The Respirator News has obtained another recent letter which reaffirms OSHA's interpretation of 29 CFR 1910.134 (e)(5)(i). (Editor's Note: See the "Atten tion: Users" column in The Respirator News, Volume 2, No. 1). In his letter of December 13, 1983 to Ms. Melodye Turek'of the Edison Electric Institute, OSHA's Edward 3. Baier, Director, Technical Support, states: "Yes, the em ployer is in violation of the standard [29 CFR I910.134(e)(5)(i) ] if employees are allowed to wear respirators over facial hair at the sealing surface of the respirator." The letter also states that: "Based on the information available, no bearded individual -' can achieve a consistent and satisfactory fit when any tight-fitting respirator is worn." A copy of this letter is enclosed as an insert in this issue of The Respirator News. MANUFACTURERS Norton Is Now North Siebe Norton, Inc., formerly Norton Safety Products, has announced that its new name is Siebe North, Inc. The Cranston, Rhode Island location which handles sales, service, and technical support for respirators is known as North Safety Equipment, 2000 Plainfield Pike, Cranston, Rhode Island 02920; (401) 943-4400. Company Contacts /- Following is a list of manufacturers who have agreed to supply us with the names, addresses, and telephone numbers of their representatives who will answer your technical questions about their products. The corporate headquarters for National Draeger, Inc. is: National Draeger, Inc. 101 Technology Drive P.O. Box 120 Pittsburgh, PA 15230 Contact: (1) Richard H. Weaver Production Manager (412) 787-8383 (2) Christopher Melvin Marketing Assistant (412) 787-8383 The corporate headquarters for Globe Safety Equipment, Inc. is: Globe Safety Equipment, Inc. 125 Sunrise Place (P.O. Box 7248) Dayton, OH 45407 Contact: Stephen Bates Executive Vice President (513) 224-7468 The corporate headquarters for Glendale Optical Company is: Glendale Optical Company 130 Crossways Park Drive Woodbury, NY 11797 Contact: (1) Joel Kaufman Quality Control Manager (516) 921-5800 (2) Ricardo Valdes, Jr. Marketing Manager (516) 921-5800 i c BPMC-13536 LAM 012165