Document YrYDqBj8oa9o97kvGN3RpbgqK

JigecIaJJSectlon^ Stricter Respiratory Protection Is Required by New Asbestos Rules NIOSH/EPA guidelines call for even lower exposure limits than the tough new standards PLAINTIFF'S EXHIBIT ST0081086 egulation of workplace exposure Rto asbestos has been a controver Table for Respiratory Protection sial issue for several years--both legally and technically. A host of federal Airborne Concentration Required Respirator agencies and contenders from all cor ners of labor and industry participated in the debate, creating confiiaion about proper respiratory protection for em ployees involved in asbestos-related Not in excess of: A. 21/cc {10 x PEL) A. Half-mask air-purifying respira tor equipped with high effi ciency fitters. work. The Occupational Safety and Health Administration sought to reduce the controversy and consolidate conflicting B. lOf/cc (50 x PEL) B. Full facepiece air-purifying res pirator equipped with high effi ciency filters. viewpoints by issuing its long-awaited amendment and new standard for expo sure to asbestos (along with termolite, anthophylite and actinolite) on June 20, C. 20f/cc (100 x PEL) Cl. Any powered air-purifying res pirator equipped with high ef ficiency filters 1986. The standards were immediately challenged in federal court by several parties. While OSHA defends its 7-month- C2. Any supplied-air respirator operated in continuous flow mode. old asbestos standards, the asbestos abatement industry and safety profes sionals must comply by implementing new respiratory protection programs, D. 200 f/cc (1000 x PEL) D. Full facepiece supplied-air res pirator operated in pressure demand mode. among other measures, which the E. Greater than 200f/cc (1000 x E. Full facepiece supplied-air res standards require. OSHA regulations are and always have been the only legally binding regu lations regarding the use of respiratory devices in non-government asbestos abatement work. PEL) or unknown concentra tion pirator operated in pressure demand mode equipped with an auxiliary positive pressure self-contained breathing appa ratus.* Exceptions are state and local or in dividual job specifications that are more stringent than OSHA require * Pressure demand airline respirators with auxiliary pressure demand self- ments, and Environmental Protection contained breathing apparatus are combination units consisting of a sup Agency regulations concerning federal plied air respirator operated in the pressure-demand mode with a small and state employees not covered by the compressed air cylinder included within the system. The cylinder acts as OSH Act. PEL REDUCED. The new OSHA standards, announced last June and ef an escape device, allowing the user to switch to the cylinder in the event of an air flow reduction or cessation of the hose supplied air. fective since last July, set the permissi ble exposure limit (PEL) for asbestos at 0.2 fibers per cubic centimeter (f/cc) over an eight-hour time-weighted average--a tenfold reduction from the previous 2.0 f/cc PEL that had been in effect since 1976. In addition to the PEL, the stand ards specify a 0.1 f/cc "action level," which requires a series of monitoring, worker training and medical surveil lance programs. There are actually two standards: an amended one for general industry (29 CFR 1910.1001) and a completely new one for construction (29 CFR 1926.581-- the first health standard issued solely for the construction industry. Construction, as defined by the 1926.58 standard, includes (but is not limited to) structural demolition or sal vage; removal or encapsulation of mate rials; construction, alteration, repair, maintenance or renovation of struc tures: installation of products contain ing asbestos; asbestos "spill" or emer from the general industry standard mainly by outlining a number of job site requirements. These requirements include a "com petent person" to supervise the site; negative pressure enclosures; clearly marked regulated areas (where expo sures are above the PEL and where only authorized personnel wearing appropri ate respiratory protection are permit ted); and decontamination areas, includ ing clean rooms, shower areas, By Roy H. Miller, Training ana Development Manager. Willson Safety Products. Reading, Pa. gency cleanup; transportation, disposal and storage or containment of asbestos on-site. The construction standard differs equipment rooms and decontamination entry/exit procedures. COMBINED SOLUTIONS. Both standards generally require a combina- JANUARY 1987 3 1302-1 ST008I 081 tion of engineering controls--where practical--and work procedures to re duce exposure to within the PEL. Both standards call for the use of respirators where engineering con trols and work practices cannot feasi bly reduce exposure to the PEL. The adapted table from the new standards on page 39 shows the types of respirators required under the new standards vis-a-vis airborne concentrations of asbestos fibers. While the table shows required res pirators for various levels of asbestos exposure, only those intimately famil iar with the requirements of the old standard can recognize immediately the major changes in respirator selec tion imposed by the new standard. Two of the key differences are these: Respirators approved by NIOSH/MSHA for dusts and mists and asbestos-containing dusts and mists (that is. approved for dusts and mists having a TWA not less than 0.05 mgW) are no longer legally ac ceptable for use against asbestos since 0.2 f/cc converts to a concentra tion lower than 0.05 mg/m5. LOWEST PROTECTION. .Vow the lowest level of acceptable protection is the half-mask air-purifying respira- < tor with high efficiency filter (ap proved for dusts, fumes and mists having a TWA less than 0.05 mg/m5). This change makes filters and dispos able respirators of the "non-high effi ciency type" unacceptable to OSHA for asbestos protection. New levels of protection have been established for certain catego ries of respirators. From 10 to 50 times the PEL, full facepiece, negative-pressure respirators with high efficiency filters are the mini mum protection accepted. Between 50 and 100 times the PEL. either pow ered air-purifying respirators with high efficiency filters or continuous flow airline respirators are the mini mum accepted. This represents a reduction in the protection factors for continuous flow airline respirators. Now, only fullface pressure demand airline respirators (or presumably self-contained breath ing apparatus) are acceptable for con centrations more than 100 times the PEL. Whether OSHA's asbestos standards--as written--will survive the various court challenges now in pro gress remains to be seen. Some observ ers anticipate at least one revision--the addition of a short-term exposure limit (STEL) to the standard. OCCUPATIONAL health i SAFETY A STEL would specify procedures and appropriate respira tory protection for workers exposed to potentially high levels of asbestos in jobs of short duration. Meanwhile. ERA. with NIOSH-written guidelines, is recommending standards for respiratory protection that are even more stringent than the OSHA standards. ...... FEDERAL RECOMMENDATIONS. In the newly published A Guide to Respiratory Protection for the Asbestos Abatement Industry. NIOSH and EPA recommend a full facepiece, pressure-demand type "C" airline respirator with either emer gency egress bottle or high efficiency backup filter for expo sures above 0.1 f/cc. This emergency egress bottle type of respiratory system already is available from a number of major respirator manu facturers. The high efficiency backup filter type, designed spe cifically for asbestos abatement work, is under accelerated de velopment by a number of major respirator manufacturers. One model already has received NIOSH approval. The new OSHA standards specify higher levels of respira tory protection for workers than did the previous standard. However, the new standards still are noticeably less stringent than the joint NIOSH/EPA respiratory guidance document. While both sources continue to stimulate improvements in respirator technology and programs, it seems obvious that there will not be a unified OSHA, NIOSH and EPA position on respirators in the near future. Thus, professionals within the asbestos detection and con trol industry still will be faced with some tough decisions con cerning respirator selection and use. 1302-2