Document bO0d8QqeZJDOxo95Z1MG9RBMD

CELANESE CHEMICAL COMPANY, INC. TECHNICAL CENTER Corpus Christi, Texas To: From: *As Listed D. A. Chadwick February 8, 1985 DAC-110-85 Respiratory Protection Policy and Program ABSTRACT CCCTC respirator policy states that employees wearing respirators must be clean shaven in facial areas forming a seal with the respirator. A qualitative fit test is being set up, and all employees wearing respirators will be tested for proper fit for each respirator issued. Employees needing or requesting a respirator need to contact me before a respirator will be issued to them. Reasons for this change and for instituting a clean-shaven policy for respirator users is explained in an attachment. Uniterms Health Safety Respirator Respiratory Protection Policy S-563 QUALITY MAKES A WORLD OF DIFFERENCE PLAINTIFF'S EXHIBIT CEL-719 008643 DAC-110-85 -2- February 8, 1985 BACKGROUND A copy of DOA-289-84 is attached which contains the respiratory protection policy for the Tech Center and a cover letter by David Anderson. As well as setting up procedures to support the policy, we have made some changes and will probably make other changes in the future to increase the strength of our overall respiratory protection program. Since there have been many questions about the policy and other changes, I have given some basic information about respirators, legal requirements, and respirator programs in an attachment. An extra copy of the attachment is included to circulate to your employees who wear respirators. DISCUSSION Interpretation of the Policy The policy is based on the company respiratory protection policy and requires that employees wearing respirators be clean shaven in the area where the respirator forms the facial seal, that facial hair not interfere with the exhalation valve, and that a quantitative fit test be performed for each type of respirator issued to a person. This policy has been adopted as a result of court decisions which concluded that a good seal cannot be obtained with facial hair. The policy applies not only to employees required to wear respirators but also to employees who request respirators as an additional form of protection in situations such as working in hoods or equipment enclosures. The air-fed acid hoods are not respirators since there is no seal. They are splash protection equipment with an air supply primarily for personal comfort although the air does offer some level of respiratory protection against a sudden release of contaminant. However, the acid hoods are not acceptable protection for continuing to work in a contaminated area after a release or for entering a contami nated area. Quantitative Fit Test The SH&E Department is setting up a quantitative fit test for respirators, and all employees who wear a respirator will be fit tested - this will be done for employees required to wear respirators and those requesting respirators. Meanwhile, employees wearing respirators should be clean shaven as described above. 008644 DAC-110-85 -4- February 8, 1985 Attachment to DAC-110-85 RESPIRATORS Basic Types of Respirators \ There are many variations but basically we have on-site air purifying and atmosphere supplying respirators. Air purifying respirators use cartridges or canisters to filter the air. Atmospere supplying respirators use several different types of valve units to deliver supplied air: demand, pressure-demand, and continuous air. When you inhale with an air purifying or demand type atmosphere supplying respirator, you cause the inside of the facepiece to become negative in pressure compared to the outside. This negative pressure is what causes the air to be sucked into the facepiece through the cartridge or canister on an air purifying respirator or trips the air feed valve on demand type atmosphere supplying respirators. The pressure inside the facepiece is positive compared to outside for pressure-demand and continuous atmosphere supplying respirators. For pressure-demand type respirator the positive pressure is maintained by opening the exhalation valve when the pressure is too high or opening the air feed valve when the pressure is too low. Air is constantly fed into the facepiece in a continuous atmosphere supplying respirator. Restrictions on Use For some contaminants there are guidelines and for others legal requirements that specify what type of respirator or variation of a respirator type that can be used for different levels of contamination. There are also specifications about the types of canisters or cartridges that can be used on air purifying respirators for different contaminants. The type of respirator used is also dependent upon whether the chemical has good warning properties - if you can't smell it then you won't know if it has broken through the filtering material in an air purifying respirator. Some basic restrictions are that air purifying respirators cannot be used in oxygen deficient atmosphere, and air purifying and demand atmosphere supplying respirators cannot be used when the concentration of a contaminant is high compared to its safe concentration. Since continuous type atmosphere supplying respirators use large quantities of 008645 DA'C-110-85 -6- February 8, 1985 Although there isn't a law about being clean shaven when using a respirator, there have been court cases where it was concluded that a good seal couldn't be obtained if there was facial hair in the area of the face that contacts the respirator. Respiratory Protection programs Along with the respirator policy and the qualitative fit test for respirators there are other parts of an overall respiratory protection program. A respirator selection and bookkeeping procedure is required which assures that you aren't unknowingly using a respirator that offers little or no protection against a contaminant, that you aren't using a respirator which is in need of repair, and that the cartridges are fresh and appropriate for the contaminate. We have set up a bookkeeping procedure to track what respirators and/or cartridges have been issued, what they're being used for, how long you've had them, when the cartridges were last changed, when they were last inspected for wear-and-tear and worn parts replaced, etc. 008646 DAC-110-85 4- Pebruary 8, 1985 Attachment to DAC-110-85 RESPIRATORS Basic Types of Respirators There are many variations but basically we have on-site air purifying and atmosphere supplying respirators. Air purifying respirators use cartridges or canisters to filter the air. Atmospere supplying respirators use several different types of valve units to deliver supplied air: demand, pressure-demand, and continuous air. When you inhale with an air purifying or demand type atmosphere supplying respirator, you cause the inside of the facepiece to become negative in pressure compared to the outside. This negative pressure is what causes the air to be sucked into the facepiece through the cartridge or canister on an air purifying respirator or trips the air feed valve on demand type atmosphere supplying respirators. The pressure inside the facepiece is positive compared to outside for pressure-demand and continuous atmosphere supplying respirators. For pressure-demand type respirator the positive pressure is maintained by opening the exhalation valve when the pressure is too high or opening the air feed valve when the pressure is too low. Air is constantly fed into the facepiece in a continuous atmosphere supplying respirator. Restrictions on Use For some contaminants there are guidelines and for others legal requirements that specify what type of respirator or variation of a respirator type that can be used for different levels of contamination. There are also specifications about the types of canisters or cartridges that can be used on air purifying respirators for different contaminants. The type of respirator used is also dependent upon whether the chemical has good warning properties - if you can't smell it then you won't know if it has broken through the filtering material in an air purifying respirator. Some basic restrictions are that air purifying respirators cannot be used in oxygen deficient atmosphere, and air purifying and demand atmosphere supplying respirators cannot be used when the concentration of a contaminant is high compared to its safe concentration. Since continuous type atmosphere supplying respirators use large quantities of 008647 DAC-110-85 -6- February 8, 1985 Although there isn't a law about being clean shaven when using a respirator, there have been court cases where it was concluded that a good seal couldn't be obtained if there was facial hair in the area of the face that contacts the respirator. Respiratory Protection Programs Along with the respirator policy and the qualitative fit test for respirators there are other parts of an overall respiratory protection program. A respirator selection and bookkeeping procedure is required which assures that you aren't unknowingly using a respirator that offers little or no protection against a contaminant, that you aren't using a respirator which is in need of repair, and that the cartridges are fresh and appropriate for the contaminate. We have set up a bookkeeping procedure to track what respirators and/or cartridges have been issued, what they're being used for, how long you've had them, when the cartridges were last changed, when they were last inspected for wear-and-tear and worn parts replaced, etc. 008648