Document aBKdQ4rQNm13pEkQoyRRLazmb

3LK V IVES November 27, 1984 Director, DSDTT Director, DSR NIOSH Policy oo Respiratory Protective Device Selection for Use Against Asbestos Regional Office Directors i <r. Memorandum PLAINTIFF'S EXHIBIT It has came to our attention that you have been receiving many calls requesting information on S10SH recommendations for the selection of respirators for use against asbestos, the following Institute position on this subject was provided as NIOSH* a official policy during the OSHA informal public bearing concerning their proposed rule on occupational exposure to asbestos on June 21, 1984. This statement on respirators is based on a consideration of the ability of aabastos to cauae cancer and other diseases in humans as we stated in our testimony. Data available to data provide no evidence for the existence of a threshold level. Virtually all levels of asbestos exposure studied to date demonstrated an excess of asbestos related disease. 0e of single-use or dust and mist respirators for protection against-asbestos Under Title 30, Code of Federal Regulations, Part 11 (30 CFR 11), NIOSH is required to test and certify respirators within the categories specified therein when such devices are submitted to NIOSH by applicants. Currently, 30 CFR 11, Subpart R defines a number of duet, fume, and aiat respirators which may be used for protection sgainat certain hazardous particulate atmospheres. Among the respirators defined in Subpart K are single-use dust respirators dasigned aa respiratory protaction against pneumoconiosisproducing sad fibrosis-producing dusts, or dusts end mists. The Subpart goes on to list eabeatos ea ona of the dusts against which the single-use dust respirator is designad to protect ISubpart R, sec. 11.130(h)]. Though at the time of the promulgation of Subpart R, it may have been assumed appropriate to list asbestos as a fibrosis-producing particulate against which the single-ute disposable respirator could be reasonably expected to provide adequate protection, NIOSH is no longer confident that such an assumption is reasonable because asbestos is also potent carcinogen. The current requirements of 30 CFR II for approval of a single-use dust respirator or dust an mist respirator do not include any teats with a fibrous challenge. NIOSH is currently in the process of undertaking a comprehensive revision of 30 CFR 11 and intends to address the issue of appropriate respiratory protection for use against asbestos and to require that any respirator for which such approval is sought be proven to provide effective protection against asbestos. NIOSH may change the regulations included in 30 CFR 11 only in accordance with procedures set forth in the Administrative Procedures Act. In the interim, NIOSH will continue to approve single-use and Page 2 - Regional Office Directors replaceable dust/mist respirators for use against asbestos when such approvals are applied for only because of the legal requirement in the current approval regulations. However, KIOSH does not recoound the use of such respirators where exposures to asbestos may occur on the basis that such is not a prudent occupational health risk. Wj also want to reiterate the Institute's position that a quantitative respirator fit testing progrsa as previously stated in consents on the proposed lead standard is more protective than a qualitative fit test program. Finally, in our testimony, we eoamented on OSHA'a proposal to allow high efficiency air-purifying respirators. As we stated, high efficiency air-purifying respirators, although an improvement over the respirator requirements of the existing standard, may not adequataly protect exposed workers given the fact that proper respirator fit may not be possible end that a threshold level, below which asbestos-related disease does not occur, has not been found. If you have questions, plaase contact either John Moran at FTS 923-4595 or Dick Lemen at FTS 684-8302. aft