Document mpmgqnj6xBEXNxroxEpXddo5g

SM-32 (KEV. 5-78) Shell Oil Company Interoffice Memorandum PLAINTIFF'S EXHIBIT >/ 6 APRIL 2, 1990 FROM: STAFF INDUSTRIAL HYGIENIST, PRODUCTS HEALTH & SAFETY TO: SEE ATTACHED DISTRIBUTION LIST SUBJECT: RESPIRATOR INFORMATION NOTICE ON CHEMICAL CARTRIDGE RESPIRATORS Attached for your information is a copy of "Respirator Information Notice on Chemical Cartridge Respirators." P. J. Snyder PJS:1fb Attachment BJTF9009201 lam 003542 DPMC-09639 In 1972, the National Institute for Occupational Safety and Health (NIOSH) and the Bureau of Mines (BOM) initiated the respirator certification program conducted under Part 11 of Title 30 Code of Federal Regulations (30 CFR Part 11). Currently, NIOSH and the Mine Safety and Health Administration (MSHA) jointly certify respirators that meet the requirements of 30 CFR Part 11. These regulations provide a description of chemical cartridge respirators that include maximum use concentrations (MUCs) for certified cartridges (Section 11.150). These maximum use concentrations are based on the acceptable exposure limits at the time 30 CFR Part 11 was promulgated. They were calculated by multiplying the assigned protection factor of 10 for half mask chemical cartridge respirators by the exposure limit accepted in 1972 for each specific contaminant. Although not specifically required in 30 CFR Part 11, NIOSH has included these maximum use concentrations on all chemical cartridge approval labels. OSHA recently revised the permissible exposure limits (PELs) for 212 substances and established permissible exposure limits for an additional 164 substances (Air Contaminants Standard, 29 CFR 1910.1000). The revised permissible exposure limits affect the maximum use concentrations for three of the substances listed in 30 CFR Part 11 (ammonia, chlorine, and sulfur dioxide). Compliance with the new permissible exposure limits became mandatory on September 1, 1989. Other regulatory agencies have established exposure limits that vary from the new OSHA permissible exposure limits. Future standards may further revise acceptable exposure limits. Thus, NIOSH has decided to eliminate maximum use concentrations from chemical cartridge approval letters and labels. NIOSH has sent a letter to all manufacturers of MSHA/NIOSH-certified chemical cartridge respirators requesting a modification to approval labels and user instructions. However, respirator and cartridge labels and instructions with the old maximum use concentrations are already in use. Therefore, NIOSH is advising that all users of chemical cartridge respirators of the change in maximum use concentrations. The following table lists substances for which OSHA does not have specific substance standards and for which NIOSH has specifically certified chemical cartridges. This table only applies to respirator users who are covered by OSHA regulations. LAM 003543 DPMC-09640 Substance Current OSHA PEL Maximum Use Concentrations Half Mask Full Facepiece Ammonia 35 ppm 350.0 ppm'!' 500.0 ppm* Chlorine .5 ppm 5.0 ppm 25.0 ppm Chlorine dioxide . 1 ppm 1.0 ppm 5.0 ppm Hydrogen chloride 5 ppm 50.0 ppm 100.0 ppm* Hydrogen Sulfide (escape only) 10 ppm 100.0 ppm 300.0 ppm* Mercury .1 mg/m^ 1.0 mg/m^ 5.0 mg/m^ Monomethylamine 10 ppm 20 ppm+ 100.0 ppm* Sulfur dioxide 2 ppm 20.0 ppm 100.0 ppm NIOSH REL is 25 ppm. Maximum use concentration recommended by NIOSH for half masks is 250 ppm. * MUC based on immediately dangerous to life and health concentration. + MUC based on eye irritation level. If you are covered by a regulatory agency other than OSHA or if your workplace has contaminants other than those listed in the table, you must review specific substance standards to determine which respirators are permitted by your regulatory agency. If there is no standard which specifically addresses which respirators can be used for protection against the contaminants used in your workplace, then determine the exposure limit established by the applicable regulatory standards or the recommended exposure limit (REL) established by NIOSH for all substances in your workplace. Then use the NIOSH Respirator Decision Logic [DHHS (NIOSH) Publication No. 87-108] to determine which classes of respirators can provide adequate protection. Where chemical cartridge respirators can be used, calculate the maximum use concentrations based on the applicable exposure limits. For example, OSHA and MSHA currently accept an assigned protection factor of 10 for half mask respirators. Therefore, the maximum use concentrations for half mask chemical cartridge respirators should never exceed 10 times the exposure limit (e.g., OSHA or MSHA permissible exposure limits, NIOSH recommended exposure limit). All other respirator selection criteria remain unchanged. Sincerely yours, N Thomas R. Bender, M.D., M.P.H. Director Division of Safety Research LAM 003544 DPMC-09641 INDUSTRIAL HYGIENE REPRESENTATIVES ANACORTES REFINERY F. J. KING BELPRE CHEMICAL PLANT M. W. HERSHMAN DEER PARK MANUFACTURING COMPLEX W. B. AUSTIN GEISMAR PLANT T. L. RODEHEAVER MARTINEZ MANUFACTURING COMPLEX M. B. LEEDS NORCO MANUFACTURING COMPLEX A. K. MENARD ODESSA REFINERY J. M. EMBLETON TAFT PLANT J. J. DELAUNE WILMINGTON MANUFACTURING COMPLEX A. FARID WOOD RIVER MANUFACTURING COMPLEX W. M. CUNNINGHAM BT8419904 LAM 003545 DPMC-09642