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MSA -..Vi;} t .mm-' Bulletin 1000-16 Key Elements of a Sound Respiratory Protection Program Introduction Proposed OSHA safety and health regulations could have a major impact on both the users and manufacturers of respiratory protective devices. During the past two years, OSHA has proposed numerous standards developed under a Standards Completion Project. The purpose of this joint OSHA-NIOSH (National Institute for Occupational Safety and Health) project is to issue complete health standards for the some 400 toxic substances listed in the OSHA regulations. In addition, NIOSH continues to prepare substance criteria documents for OSHA to promulgate as standards. These efforts closely follow a decision logic system in setting permissible exposure limits and in the selection of respiratory protective devices. The purpose of the decision logic system is to bring some uniformity to the standards setting process. If adopted in their present form, theproposed standards will affect the NIOSH-MESA (Mining Enforcement & Safety Administration) respirator testing and certification procedures, commonly referred to as 30 CFR, Part 11. The present OSHA regulations governing respiratory protection programsfwould also be affected....- Hopefully, some.ci6pffcatiorcof the background andcdmentof thei.~ proposed standards and the decision logic system employed in their formulation will help users understand the impact of the requirements on environmental surveillance and respiratory protection programs. QUESTIONNAIRE GAS MASK AND RESPIRATOR RECOMMENDATION NAME AND ADDRESS OF COMPANY SEEKING RECOMMENDATION______ NAME OF INDIVIDUAL. HIS PHONE NUMBER- 1. Material-- a. Chemical Name. b. Trade Name___ : c. Formula__ ____ d. TLV or TWA OSHA 1910.1000- .CurrentACQIHT~r Form in which it will be used-- a. Liquid?:__________b. Solid?--_____ _^c. Gaseous d. If gaseous, is it an organic vapor?, : oracid g) other?______________!____ ,__ ____ . 3. Maximum expected concentration--- " ' - a.______ ___ __ __ parts per million, or b.____ _____ ~ milligrams per cublctneter *.', =&, ,, 4. Will material be heated?. a. If so, to what temperature? 5. What is the odor threshold'of the materl 6. At what concentration is the material consi gerous to life or health?^ . 7. Can the substance be absorbed through the 8. Irritant to eyes?--_______ . respiratory tract?. 9. At what concentration is it an irritant? 10. If the substance is known to be flammable, what are the lower and upper flammable limits, in percent hy - 11.. What is the vapor pressure of the 12.. Will material be mixed with other chemicals?^Ratyy;-' - 7--' v"; .If so; give dot ills 13. Any possibility of oxygen deficiency?^ 14. Can good ventilation of the area be ms 15. Will exposure be continuous?16. Will the respiratory device be used for used as an escape device?____ .a..,.... ^intermittently or will it be 17. Provide as much detail as possible concerning exposure conditions; c 003353 LAM023014 VT"' "* tv~ _. -A----1 . ' ` *^.-%r' j|>;4S3 < ~ - *-' *&r * 'fi~i i J Hazard A . '- -' /-* -.' ' -"-lb* "TTtallg^eHij protection^ an hazards the nap and or Mil A pagifet)c_,, gatheringthepfrtii about theair exposure - r ust:~Tr Hazard Co Respiratory Plot ........ ~ Proper assessment* the first step to ppof expiwureconT therecoi engineei controlsahotifd belowthe] respffatOi the basis of?*S~ Toxicity (XEV'dr Maximum Expi Concentri Oxygen.De: IDLH Warning Property , or nqtkr Sdrbeni Facepic Mobility Require ^Typeof Use (; norai Permissible Exposure Limits And Action Levels Permissible exposure limits, time* weighted averages (TWAs), and threshold limit values (TLVs) all mean approximately the same "thing. In the latest revision of the QSHA regulations (July 1,1975), the TWAs ere found in tables Z-1, Z-2, and Z-3 of Section 1910.1000. lit earlier editions, the TWAs can be EfOund by checking the index for air ^ contaminants. But remember, these exposure limit tables have not been - ohanged since the ACGIH : (American Conference of "Governmental Industrial Hygienists) Sse-r TLVs were adopted by OSHA in ,1968, so it is a good idea to cross check the OSHA permissible .^ exposure limit with the current "ACGIH TLV. >SHA feels it is necessary to begin employee exposure measurements and medical surveillance before dncentrations reach the TWA or permissible exposure limit, and S^refore, OSHA is proposing an ictfon level for each new substance standard. The action level is One-half of the permissible exposure limit. For example, OSHA's TWA, or issible exposure limit, for ZButanone is 200 ppm, so the action level would be 100 ppm. HA reasons that an action level well below the permissible sure limit will provide imum employee protection with himum employer burden. Where the results of environmental surveillance show that no employees are exposed to concentrations above the action level, employers are exempt from certain measurement, medical, and training requirements of the standard unless, of course, there is a change in production, process, or control methods that could increase concentrations. Exposure Determination And Measurement ;: In conjunction with the action level concept, the exposure determination and measurement sections of,the proposed standards are designed in a step-by-step fashion to make compliance easier for those workplaces where only low concentrations are present. There are four steps in the measurement process/. Step 1 -- An initial determination of workplace conditions must be * taken. This is a simple calculation \ of exposures and does not reqmrei the employer to sample the jp 7 environment. Normally, this written report covers the size of..the* workplace, the amoiitQtTh^:^r: regulated substance piresent,jthei; > type of operation performed, the. proximity of the workers to the* source of emissions, and the.; ' ventilation system being used. Such an initial determination must be made even" if none of the workerr are exposed above the actlorvleveL * and the initial determination must ' be made for each operation involving a regulated substance. For example, in dip tank and spray-finishing operations, an initial determination must be made for both operations. Step 2 -- When the initial exposure determination; indicates that any-- employee may be exposed hfesg..). excess of the action level, the employer must measure the exposure of the employee most , likely to have the highest exposure. If the results indicate that the employee is exposed to concentrations in excess of the action level, the employer must measure the exposures of all employees similarly affected. C 003354 LAM023015 2 rMf?-' ' r"- Step 3 -- Exposure measurements of concentrations above the action level, but below the permissible v exposure level, must be made every two months. If the results of two consecutive measurements, taken at least one week apart, show that the exposure is below the action level, the surveillance program for that employee can stop. As ; mentioned before, OSHA's stated intent is to provide adequate protection for employees while minimizing the employer's administrative and financial burden. Step 4 -- If measurements show that an employee is exposed to concentrations above the permissible limit, the exposure must be monitored at least monthly and measures must be taken to reduce the exposure. Monthly measurements are also required even when the employees wear respirators routinely, because the type of respirator selected is determined by the concentration of the regulated substance in the workplace air. It should be noted that the entire measurement process must begin again, with the initial determination, if there are changes in the production, process, or control measures that could result in new or increased exposures. Methods of Measurement Methods of Compliance The methods of measurement ; , OSHA's proposed methods of ; section of the proposed standards compliance are pretty straight- v does not specify the duration or ;', forward? Theetandards require the number of samples to be taken in usd of engineering or work-practice order to determine individual :: controls to reduce exposu res to employee exposures. A * - - the permissible limit or below. combination of long-term or short However, if such controls cannot term samples would be acceptable, 4 get exposures down to the although the proposals require that permissible limit, they have to be exposures be calculated on an used anyway to reduce the exposure 8-hour time-weighted average to theiowestleveipossible.At this (TWA) basis. The 8-hour exposure * point, the controls can bo V can be determined from a single supplemented by respirators. , sample or from two 4-hour samples. Naturally, OSHA prefers - Measurement methods are not engineering controls because , specified either. However, the airborne concentrations&re ~ method used must meet specified reduced at the source and the precision and accuracy require controls are not highly subject to ments. This gives the employer human errors. As a check,,though, some flexibility in selecting the mechanical ventilation systems method that best fits his particular used as engineering controls must situation. be tested at least once every three The accuracy requirements are ' months.. - ~^ related to the concentration being, Work-practice controls, on the measured. Above the permissible r other hand, are only as good as the exposure limit, the accuracy is plus supervision they get. Good or minus 25% . At or below the, housekeepingmayreduce spills, permissible exposure and above ; and empfpyees cSh reduce their the action level, the accuracy is exposure by staying out of high plus or minus 35%. At or below the concentration areas when work action level, the accuracy is plus or does not require them to be there, minus 50%. Such accuracy but these are not foolproof requirements let the employer use NIOSH-certified detector tubes measur..e..s. . ..- . when available, because these accuracy levels are the same as those used by NIOSH when they test detector tubes for a specified, compound. Each measurement method must have a confidence level of 95%. This means that out of a long series of tests, 95% must be within 25%, 35%, or 50% of the true concentration. c 003355 3 LAM023016 Respiratory Protection OSHA feels that respirators are the least satisfactory means of exposure control, because they provide good protection only if they are properly selected, properly fitted, worn by employees, and replaced when their service life is over. In addition, some employees may not be able to wear a respirator. Despite these difficulties, respirators are the only form of protection available when engineering and work-practice controls are inadequate. The proposed standards also permit respirators to be used to control employee exposure in certain other specific situations, including operations where respirators are needed for not more than 1 hour a day, 1 day a week, or in emergencies. OSHA has not explained why they chose 1 hour per day, 1 day per week. The new standards list respiratory protection equipment for various concentrations of a substance. This is called the Respirator Selection Guide. To provide additional protection, an employer may always select a respirator prescribed for concentrations higher than those found in his workplace. He may not, however, use respirators that are not listed. The proposed standards also call for a respiratory protection program as spelled out inq|j|prir 1910.134 of the OSHA regufa^HS and ANSI standard Z88.2-1968FOf course, the respirators musfbe NIOSH-MESA-approved or carry a Bureau of Mines approval still valid under the``grandfather''clause. t Decision Logic The respirator selection guides are prepared by outside consultants who use the strict guidelines of a decision logic system. The purpose of this decision logic system is to; assure that the respiratory protection selection guides for the various substances are uniform. The system works by eliminating, in a step-by-step fashion, respirators that are Inappropriate until only r those types which are acceptable remain. To do this, the necessary . toxicological, safety, and research , information on the substances is. assembled in order to answer six basic questions. 1. Skin Absorption -- Personal protection requirements for splashes or spills that may cause Where information indicates -- systemic injury or death from absorbing a gas or vapor through ^ the skin, the standards say: "Use of supplled-alrsuits or other ;;. ; Impervious coverings may be necessary to prevent skin contact with the substance when the concentration of the substance Is unknown or greater than the IDLH. Supplled-alrsuits should be ; setected,usediand maintained /. under thelmmedlatasupervislohot persons kndwIedgeabldMthjbS^r limitations andpotpntt&'lifdM^-1 : endangering characteristicabtf^ .. ' supp//ec^afeau/f3.'ft~?g ,c ~: - - I rrespectiveofthe use ofsupwtad^alr suits, theentry-and.-escapfe from-unknown-conceritKttiqf^:?;; -' category of the respiratory ^^ -~ . 'pr6tecti0ff;'guides*sas^&i^Ss:H::': contain^dbi^aplngappai^u^/ith the substance to be through the skin are not covered, as respirator selection criteria are: based primarily on the Inhalation pressure demand orother positlvepressuce mc^^r Or a comblnatlotr ' - . resplratsmm^e^ hazard.' It is possible that a supplied-ajf suit may provide both skin and respiratory protectionfrom extremely toxic substances that may be absorbed through the skin. Supplied-air suits, however,... are not covered in NiOSH-MESA Approval Regulations, 30 CFR, J Part 11, and the data needed to recommend such suits for all types of exposures simply is not available. facepiecebpbratedimtitepreasure dem^d^'moiMrpb^fvdd^11^ ofcontinuousdowm^ auxiliary self-contained breathing apparatus operatedin the pressure demandorother positive-pressure mode." Translated, this section of-----the iesplratoTy'tabfe;means a pressure demand self-contained breathing apparatus or a pressure demancfworfejnaskmaybeused. 2. Wamliigjlraj;^^ properties such as odor; eye irritation; arid'respiratory irritation - that rely upon-human Senses are ~ not foolproof; Howeyer,:thegrdqr~ provide some indication to the. - wearer that the service life of the cartridge orqanister is reaching the end, the facepiece.is not fitted properly, or there is some other respirator malfunction. Warning properties may be assumed to be adequate when odor, taste, or irritation effects of the substance can be detected and are persistent at concentrations at or below the permissible exposure limit. >ri -'H |-4 i 'T 4 C 003356 LAM023017 If the odor or irritation threshold of the substance is many times greater 5. IDLH (Immediately Dangerous to Life or Health) - NIOSH-M ESA If the concentration is above the iIDLH, only highly reliable breathing : than the permissible exposure limit, approval regulations define IDLH apparatus such as pressure -] the substance is considered to as: - `Conditions that pose an demand is allowed. Since the IDLH - have poor warning properties, and immediate threat to life or health or tiihits are conservative, any ^ air-supplied respirators would be conditions that pose ah immediate approved respirator may be used specified. threat of severe exposure to V 4' uptotits maximum use concentre* , Borderline cases are governed by other rules. This same thinking is reflected in NISOH-MESA approvals for organic vapor chemical cartridge respirators and gas masks which prohibit their use against organic vapors with poor contaminants such as radioactive materials which are likely to have*. adverse cumulative or delayed,, effects on healthi This definition represents a significant change from the previous "Immediately Dangerous tlon, as listed ln the respirator seiection guide, but below the IDLH. Respiratory protection for : substances vrithout an IDLH- \ : cc^cer^ill<^i8 selected strictly on the baslsoftherespirator's protec- j tion factor and use limitations?- - warning properties. to Life" terminology used by the 6. Lower Flammable Limit (LFL) 3. Sorbent Efficiency -- Where evidence shows immediate or less than three minutes' breakthrough time at or below the IDLH concentration for a chemical cartridge or canister, these airpurifying devices will not be allowed for any use, including escape. Only air-supplied devices are permitted. 4. Eye Irritation -- For routine work operations, any perceptible eye irritation is considered by OSHA to be unacceptable. Therefore, only full-facepiece respirators are allowed in concentrations that produce eye irritation. In escape situations, some eye irritation is permitted if it does not inhibit escape or result in permanent injury. ^ Bureau of Mines. The addition of' and;nre^FIghflng:|r'Ceh6entrat|ons-' ' "or Health" was based on the fact inexcess ofthelowerMmmable J that a worker could escape from an limit (LFL) areconsiders to be:. ^ irrespirable atmosphere in the immediately dahgefouMd^lifeand event his respiratory protective, : h^stth; AI equipment failed, but might be feels that respiratorsmuatprovide i affected so severely that his health ; maximum protectionSuch devices | could be impaired:.:. __ v. include pressure demand self- * Two factors are considered when w; establishing IDLH concentrations: 1. The worker must be able to escape without losing his Ijfe or suffering permanent health contaihed breathing apparatusand combination positive pressure supplied-alrrespirators with egress , cylinders (wqrft maskafe^;. Afclif ,s|8^^tSZ8ft5.defines'fire- ] -damage within 30 minutes. Thirtyiciv- fightingasimmediaterty dangerous t minutes is considered by OSHA to life, so forfire-flghtlng, OSHA i as the maximum permissible feels that the only device providing exposure time for escape.: adequate protection is pressure 2. The worker must be able to demand self-contained breathing . escape without severe eye or apparatus^- / respiratory irritation or other reactions that could inhibit escape. 1 i C 003357 5 LAW1023018 RESPIRATOR PROTECTION FACTORS Type Respirator . / :3 ' :i??-' Facepiece Pressure Protection Factor 1. Air-Purifying A. Particulate Removing Single-Use. Dust Quarter-Mask, Dust . Half-Mask. Dust Half- or Quarter-Mask, Fume Half-or Quarter-Mask, High-Efficiency Full Facepiece. High-Efficiency Powered. High-Efficiency, All Enclosures Powered, Dust or Fume, All Enclosures B. Gas and Vapor-Removing Half-Mask . * 3 3" Full Facepiece 4 --3 : / "3 3 ,3 t ;v ' .+ + 5' 5 10 10 10 50 1,000 X Ifl . 10 ; 50 II. Atmosphere-Supplying A. Supplied-Air 3 Demand, Half-Mask Demand, Full Facepiece Hose Mask Without Blower, Full Facepiece ^ Pressure-Demand, Half-Mask ? Pressure-Demand, Full Facepiece Hose Mask With Blower, Full Facepiece Continuous Flow, Half-Mask Continuous Flow, Full Facepiece Continuous Flow, Hood, Helmet, or Suit B. Self-Contained Breathing Apparatus Open-Circuit, Demand, Full Facepiece Open-Circuit, Pressure-Demand Full Facepiece Closed-Circuit, Oxygen Tank-Type, Full Facepiece ; 3 33,^ 3 3^ $#* ' ' ` /V + -?:'-3 + + +1 ^ 10 50 50 1,000 , 2,000 50 3 1.000 - 2.000 " 2,000 * 50 ` ' _ 10,000 1 " ~ - 50 4 ' 1 III. Combination Respirator A. Any Combination of Air-Purifying and Atmosphere-Supplying Respirator -- ----------- 4- Use Minimum Protection Factor Listed Above for Type and Mode of Operation; -' B. Any Combination of Supplied-Air Respirator and an SCBA 33;3-*3.33>v?;i:`'3.3 . z * * * <j Protection Factors Protection factors, a very important part of. the decision logic system, are simply a measure of the overall effectiveness of a respirator. The protection factors being used by OSHA are based on fit tests performed at Los Alamos Scientific Laboratory and elsewhere, and in some instances, on professional judgment. Protection factors are determined? by dividing the ambient airborne , concentration by the concentration inside the facepiece. The new standards use protection factors that range all the way from 5 to 10,000. This simply means that the maximum use concentration for the respirator is determined by multiplying the TLV of the substance by the protection factor. Changes to 30 CFR, Part 11 There are certain conflicts between 30 CFR, Part 11, and the decision logic system. OSHA has stated that they plan to make at least five changes to 30 CFR, Part 11, so that; it will mesh with the decision logic. In the first place, 30 CFR, Part 11,; does not have protection factor requirements. An amendment is planned that will include protection factors for dust, fume, and mist respirators. In the future, amendments are to be planned for other types of respiratory protection. The second change to 30 CFR, Part 11, would eliminate approval of Type A supplied-air respirators; - 1 commonly known as a boss mask^ with blower, for IDLH atmospheres. Although this device is currently allowed for IDLH situations, OSHA feels that an air supply of 50 liters per.jnihuje^sB ii|i`ulfedin-36jSfr^.:: nfain a positive pressure iii the facepiece. under <11 working conditions. 3 Therefore, OSHA feeis this device should have the same protection factor as other air-purifying and atmospheric-supplying respirators with a negative pressure in the j facepiece. 33133 The third amendment to 30 CFR, Part 11, will eliminate the use of gas masks for entry and use in immediately dangerous to life and health atmospheres. In the decision logic system, gas masks are not allowed in concentrations greater than the IDLH or for entry and escape for unknown concentrations. 4 1 ri C 003358 LAM023019 o The fourth amendment Wilt elimi Current OSHA nate maximum use.conceiitratipns Respiratory Standard ; from the gas mask approvai labels. The decision logic is consistent with this amendment However, it's Important to remember that canisters approved prior to this amendment will have a maximum use concentration specified on the label. This will not be consistent with most of the proposed/ standards. OSHA evidently feels that the new standards themselves should control the use of gas masks and that the user should not be made aware of the maximum use concentration limitations".:" associated with such devices. . Finally, 30 CFR, Part 11, does not The OSHA General Industry Safety and Health Regulations, Part 1910.134, state: "In the control of those occupational diseases caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors, the primary objective shall be to prevent atmospheric contamination. This shall be accomplished as far as feasible by accepted engineering control measures (for example, enclosure or confinement of the operation, general and local ventilation, and substitution of less toxic materials). When effective engineering controls allow the approval of escape gas are not feasible or while they are masks for acid gases or organic. being instituted, appropriate K\ vapors with poor warning proper- respirators shall be used pursuant ; ties. A change is planned to permit to the following requirements. ] the use of gas masks ftii escape from these substances regardless of their warning propertite^ ? Respirators shall be provided by the employer when such equipment is necessary to protect the health of ,, ~ the employee. The employer shall : .v.. . provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protective program which shall Include the require ments outlined in paragraph B of this section." ^> - ^ Paragraph B lists the requirements for a minimal acceptable program which include: *; I J 1. "Written standard operating procedures governing the selection and use of respirators shall be established. f i 2. Respirators shall be selected on the basis of hazards to which the worker is exposed. i 3. The user shall be Instructed and trained In the proper use of p respirators and their limitations.' s 4. Where practicable, the respirators ! should be assigned to individual. workers tor their exclusive use. .. *' ,, 5. Respirators shall be regularly - cleaned and disinfected..Those Issued for theexclusive use of one worker should be cleaned after each ~ day's use, or more often If neces- ^ sary. Those used by more than one worker shall be thoroughly cleaned and disinfected after each use. 6. Respirators shall be stored in a I convenient, clean, and sanitary j location. .p 7. Respirators used routinely shall be Inspected during cleaning. Worn or deteriorated parts shall be replaced. Respirators for emer gency use such as self-contained devices shall be thoroughly Inspected at least once a month and after each use. - -....... - : . -. -i 3 i I I Il C 003359 * LAM023020 8. Appropriate surveillance of work area conditions and degree of employee exposure or stress shall be maintained. 9. There shall be regular inspection and evaluation to determine the continued effectiveness of the program. 10. Persons should not be assigned to tasks requiring use of respirators unless it has been determined that they are physically able to perform the work and use the equipment. The local physician shall determine what health and physical conditions are pertinent. The respirator user's medical status should be reviewed periodically (for instance, annually). . ~ *iiS*:i 11. Approved or accepted Training shall provide the men an respirators shall be used when they opportunity to handle the respirator, are available. The respirator have it fitted properly, test its, furnished shall provide adequate facepiece-to-face seal, wear it in respiratory protection against a normal air for a long familiarity particular hazard for which it is period, and finally to wear it in a test designed in accordance with atmosphere. Every respirator standards established by competent wearer shall receive fitting authorities. The U.S. Department of instructions; including demonstra the Interior, Bureau of Mines, and tions and practice in how the the U.S. Department of Agriculture respirator should be worn, how to are recognized as such authorities. adjust it, and how tQ determine if it Although respirators listed by the fits properly. U.S. Department of Agriculture continue to be acceptable for protection against specified pesticides, the U.S. Department of the Interior, Bureau of Mines, is the agency now responsible for testing and approving pesticide respirators." Respirators shall not be worn when conditions prevent a good {... face seal. Such conditions mm be a growth of beard, sidebUrnsM skull cap that projects under we facepiece, or temple pieces oj| glasses. Also the absence of one or both dentures can seriously It should be noted that NIOSH- affect the fit of a facepiece. The MESA is now testing and certifying ... workers,diligence In observing respirators. these factors shall be evaluated That is the end of the OSHA require ments for a minimal acceptable program and that whole section was picked up from ANSI Z88.2-1969.What was not picked up, however, were the ANSI Z88.2 references that refer you to other sections of the by periodic checks. To assure proper protection, the facepiece fit shall be checked by the wearer each time he puts on the respirator.* This may be done by following the manufacturer's facepiece- ,, fitting instructions." documentfor additional require These requirements were obviously ments. For instance, the ANSI meant to be a part of the minimal paragraph states: "The user shall acceptable program when ANSI be instructed and trained in the published their document, but they proper use of respirators and their became separated when OSHA limitations, see paragraph 7.4 and promulgated Part 1910.. 7.5. "These reference sections specify minimum training and face- piece fit test requirements." OSHA includes these requirements under paragraph E5 titled "Use of Respirators'' and states: "For safe use of any respirator, it is essential that the user be properly instructed in its selection, use, and mainte nance. Both supervisors and workers shall be so instructed by competent persons. : 'i C 003360 ^n 1r LAM023021 AMMONIA Respirator Maximum Uise Concentration ; ( ppm) ' .. Existing Proposed Standard Standard Facepiece TLV 25 ppm TLV 50 ppm "C" Chem. Cart. Chem. Cart. Gas Mask SCBA Demand SCBA Press. Demand 1/2 Full Full Full Full 300 300 30,000 Unlimited Unlimited Not Allowed 500 1,250 (IDLH) 1,250 (IDLH) Unlimited Comparison of Present And Proposed Standards So a comparison of the present standard to the proposed standards indicates that the pfesent require- ments for respirator selection and facepiece-fit testing will be meaningless although still required, and all respirators will have to be selected and used In accordance with the new respirator selection guides. The new standards appear less complex and somewhat easier to understand, but here are some of the changes they will require, using the proposed Ammonia standard as an example. The first major difference in the standards is that half-mask chemical cartridge respirators, presently approved for use to 300 ppm, will not be allowed. Another change is that a fullfacepiece chemical cartridge respirator may be used up to 500 ppm instead of the present 300 ppm. However, this conflicts with 30 CFR, Part 11, because the IMIOSH-MESA approval limits the cartridge to a maximum of 300 ppm. Gas masks are downgraded from their present 30,000 ppm status to 1,250 ppm which is the IDLH level proposed by OSHA. Finally, the demand self-contained breathing apparatus that has been used in emergency rescue and fire-fighting on an unlimited basis for years has been reduced to 1,250 ppm. Impact of Proposals On Respiratory Protection This basic example shows that the eye irritation, protection factor, and warning property sections of the decision logic system will result in substantial changes in the types of respirators required in the future. It appears that large numbers of half-mask respirators will have to be replaced with full-facepiece respirators due solely to potential eye irritation that might well be handled by protective goggles. The protection factors being applied to respirators will require not only the replacement of many half-facepiece respirators but will also require the wholesale replace ment of negative pressure respirators with positive-pressure respirators. This includes the bulk of the self-contained breathing appa ratus and gas masks in use today. In the category of adequate warning ; properties, OSHA and NIOSH consider substances with no . published odor or irritation data to have poor warning properties. A ~ review of the StandardSpompletion Project indicates there tire probably ' more substances with no data ;; available than substances with data. .j This category arbitrarily eliminates ^ all gas sorbent air-purifying ] respirators and will require their ij replacement with air-supplied or | self-contained breathing apparatus. : It should be noted that the hew : standards, if adopted, will take 7 precedence over previous OSHA regulations and will replace the sections of the OSHA regulations covering persohalprotective equipment, 1910.132 (C); air contaminants, 1910.1000; eye and face protection, 1910.133 (A); as well as any other provision of Part 1910 not consistent with the new standards. i ij .f 1 -i i C 003361 9 LAM023022 j V" - ^Yi[ ' The ANSI Approach To Protection Factors Any discussion of facepiece-fit characteristics must recognize that the ideal way to achieve the highest degree of protection, or the least amount of leakage, would be to mold a facepiece to each wearer's face. However, this is not feasible with present technology. At this time, the best way to determine facepiece-fit character istics is to individually fit-test each respirator wearer. The next best method is to fit-test the wearer with several facepieces until it is determined which model provides the highest degree of protection. As stated previously, the current OSHA regulations require that both supervisors and workers have an opportunity to handle the respirator, have it fitted properly, test its facepiece-to-face seal, wear it in normal air for a long familiarity period, and finally wear it in a test atmosphere. Because the present standard requires that facepiece-fit testing be performed, the ANSI Z88.2 Committee developed an alternative proposal to the OSHA protection factors. The ANSI test procedures would, in effect, permit users to develop their own protection factors as part of a facepiece-fit testing program. Maximum Use Limits The ANSI Maximum Use Limits, or MULs, are based on three types of respi rator fit tests. The fitting methods recommended are qualitative, semi-quantitative, or quantitative. The first consideration in the MUL concept is to determine if the respirator Is permitted for use in oxygen-deficient atmospheres or IDLH atmospheres or not. Depending on the fitting method used (qualitative, semi-quantitative, o r q uantitative), a Respirator Fit Index is determined. See chart on page 11. The MUL is calculated by multiply ing the Respirator Fix index by the ' TWA of the contaminant. If no fit tests are performed, an MUL of 5 would be assigned. This Is considerably more stringent than the OSHA approach and is designed to encourage individual fit testing. .; The ANSI Z88.2 Committee feels that proper use of the fit-testing procedures wilt result in a much"- " higher degree of protection to the respirator wearer than the arbitrary assignment of protection factors based on the poorest fitting respira tors tested-. mines respirator MaxirnumUsef Limits based on the sii^tesittfi " testing. An irritant smoketube is used in this test and theweare, determines if the respirator /eai irritation. The Maximum Use Ui from this test are very close to protection factors propose&b OSHA The su^l^^^thmeitfpd ca/r afcd* be performed withaswab com ^ taming isoamyl acetate. J. The wearer would determine if the respirator leaked by odor of the "banana oil." C 003362 A 10 LAM023023 The semi-quantitative tit method is based on pre-screening the wearer to determine if 2 ppm of isoamyl acetate can be detected, and then exposing the wearer to a known concentration of at least 400ppm for a half-facepiece and 2,000 ppm for a full-facepiece in a test enclosure. If the wearer cannot detect the odor, the listedMULs are valid. The quantitative fit method is based on actual facepiece leakage meas- urements using DOP (dloctyi phthlate aerosol particles), sodium chloride, halogenated hydro- : carbons, or other test means, '' ; ~ '"" - - ? - '' ,'r The quantitative fit method meas ures facepiece leakage from inside , the facepiece, using a probe, sampling line, and analytical equips ment. In this test, Maximum Use Limits would be established for each individual who is fitted. Respirator 1. V* or Vi Facepiece Particulate Filter* 2. Va or Vz Facepiece Vapor Gas 3. Full Facepiece Particulate Filter* 4. Full Facepiece " Vapor Gas 5. Powered Air-Purifying Any Respiratory Inlet Cover)* ANSI Z88.2 PROPOSAL RESPIRATOR MAXIMUM USE LIMITS L Jl if ^ *' 'A wT-iU*:' Permitted for Use In Atmospheres 02 Oef. . IDLH MUL Respirator Fit Index Accordingto Fitting Method Ittedr.,, Qualitative Semi-QuantitativeSft. Quantfrativa.. No No ` ' 200 . ^ No No No Yes Lower of 10 or MUL-C i iook;-1 Lower of , 2001 o r MU-L-1C-- Y'* & . 1000 U.V-. & . 1 *" "**> ' fa. W Measured on Each ,, No Yes Lower of' 100 or MUL^C Lower of 1000 or MUL-C- Persorr ' . ' ot $ MUL-C : No No :: mul-c t < .7 i -*.i. ... r i j i 'Use High Efficiency Filters for Particulates with TLV Less than .OS mg/ml 6. Air-Line (Demand) Va or Vz Facepiece 7. Air-Line (Demand) Full Facepiece 8. Air-Line (Demand) Full Facepiece with Escape Provision 9. Hose Mask*- *- Full Facepfitifeofe' 10. Air-Line (Pressure*^ Demand or^Mstant& ______ Flow) 11. Air-Line (Pressure Demand with Escape Provision) 12. Air-Line (Constant Flow with Escape Provision) No No Yes* No .No Yes* Yes* NO No Yes . No No Yes Yes -10 100 idd- - .100 N/A N/A N/A 'Escape Provision Must Be an Auxiliary Self-contained Air Supply ------ : -r/r:--ryn , 'z 20Q T vV . ,:' >10' 0i-0, - t- ,, ,, ' _. As Measured - ** - i\*-**r " * . oh . . Each ^ Person, - ..A000 ; ' , #11111 . wl.. '' lit- ^ 4siz--.' ' _ - ... '' " . 13. Demand SCBA (Open or Closed Circuit) Full Facepiece or Mouthpiece 14. Pressure Demand SCBA Half or Full Facepiece 15. Combination Devices Not Listed Yes Yes Yes Yes r - As 100 iooo ; : Measured. i on Each - Person N/A N/A N/A Use Lowest MUL Listed ' LAM023024 .. V ' . r-.'; - .. A'? Note This presentation is intended for persons concerned with establish ing and maintaining a respiratory protection program. It presents certain basic information for guidance purposes. However, it is not intended to be all-inclusive in content or scope. Further, this presentation contains simplified interpretations of certain Federal regulations pertaining to respiratory protection and monitor ing. While these interpretations convey background information about the regulations, under no circumstances should they be used as the sole basis of a respiratory protection program. In all cases, the current Federal regulations, as published in the Federal Register, should be carefully studied, and the rules and procedures in those regulations explicitly followed. Only they define the specific require ments that are in force. For more complete information on specific problems, the reader is referred to the following publications:. : 1. American National Standard Practices for Respiratory Protec tion, ANSI Z88.2-1969-Available from the American National Standards Institute, 1430 Broadway, New York, NY 10018. A 2. Respiratory Protective Devices Manual--Available from the Committee on Respirators, P.O.Box 435, Lansing, Ml 48902. 3. Breathing Apparatus for the Fire Service--Available from the National Fire Protection Association, 470 Atlantic Avenue, Boston, MA 02110. 4. Threshold Limit Va/ues--Availa ble from the Secretary-Treasurer, The American Conference of ' Governmental Industrial Hygienists, 1014 Broadway, Cincinnati, OH 45202. nr 5. Basic Elements of Respiratory .. Protection--Available from Mine Safety Appliances Co., 600 Penn Center Boulevard, Pittsburgh, PA 15235. 6. Code of Federal Regulations, Title 29, Labor, Parts 1900-1917 and Code of Federal Regulations, Title 30, Mineral Resources, Parts 11-14A --Available from the Superintendent of Documents, U.S. Government Printing Office, Washington, DC 20402. This presentation contains only general descriptions of several MSA products that can be used to implementarespiratory protection program.While usesandperform- ance capabilities are described, only qualified, trained personnel, should use any respiratory protec tive device. Precautions listed on the labelsandcartohsmust be read, understood, and followed. Only theycontain the completeahd ; detailed information concerning' the products. ^ .. . For more complete InforniationT' '; about the respiratory protective r equipment described inthlsf |t-"~ presentation', contact Mine Safet#^' Appliances Co., 600 Penn Centei#^" Boulevard, Pittsburgh, PArt5235jr~ -X -r4 -' - , -- - - y-i MSA Mine Safety Appliances Company -- 600 Penn Center Boulevard Pittsburgh, Pennsylvania 15235 At your service: 25 branch offices in the United States; MSA CANADA Downsview, Ontario (Metro Toronto), Halifax, Montreal, Winnipeg, Saskatoon, Edmonton, Calgary, Vancouver; representatives In principal cities of the world. Cable address--"MiNSAF" Pittsburgh C 003364 Bulletin 1000-16 Printed in U.S.A. 771 (L) LAM023025