Document zzMMgq9j8mq4JVKY4Q3Q50RZ3

Interoffice Communication To C. L. Whetstone, M.D., - Ponca City From D. A. Kuhn - Houston Date Subject May 16, 1979 c CERTIFICATION OF RESPIRATOR FIT In response to your IOC of 5-11-79 I have three major concerns: main tenance inspection of respirators, certification of respirator fit and certification of the employee for respirator wear. Let me address them separately. Each chemical plant has a respirator use program designed; to comply with 29CFR1910.134, the OSHA Respirator Projection Standard. jLn it there are provisions for proper maintenance and care. When we learned earlier of the NIOSH warning you attached to your IOC, each plant saFety director was notified and encouraged to make his own inspection of; the SCOTT AIR PAK equipment found defective. A company-wide alert with: a strong recom mendation to make the necessary inspections is certainly appropriate. I believe the time and effort to return reports that such ah inspection has occurred to the medical department is unneeded and wasteful. It should be left to the operating managers of the Conoco units involved to institute their own checks and follow-ups. j As part of Conoco Chemicals aforementioned respirator protection program, each plant has taken steps to assure proper fit. We are using the socalled qualitative technique where the worker determines if he can smell an irritant gas while wearing the proper respirator. This testing is, of course, time consuming for a safety staff that already has more than enough to do so there is a possibility that AHP's offer could have some benefits on a selected basis for those plants which wanted to use it. I could not recommend, however, that it be instituted Chemicals-wide because it may not have universal benefits. Of course, we could never accept the program without knowing its cost and there may be ways to reduce whatever it is. For instance, it seems to me costly to have the testing performed by physicians who are hand somely paid and may not be well-trained in the respirator testing process. It seems more appropriate that the testing be carried out by a competent AHP technician who has been qualified for this task. There may be real value in having this repeated annually to assure that workers are getting the protection they are suppose to from respirator wear and to remind them once again the importance of using the respirator properly. My final concern is not addressed in your letter or the attachments. I believe Conoco Chemicals1 workers, through their medical surveillance program, must be certified that they are healthy enough to wear respirators. SAL. 0000 Li 70 5 8 CERTIFICATION OF RESPIRATOR FIT May 16, 1979 Page 2 It is my understanding that this is already being done during our regular, annual medical testing program. I believe that it is very important that every worker required to wear a respirator has been fully capable of doing so without impairment to his health. avid A. Kuhn DAK/nl cc: J. R. Drumwright, M.D. - Ponca City J. J. Hall - Houston R. E. Lehmkuhl - Houston R. L. Lembke,. M.D. - Ponca City 0. D. Steffey - Ponca City JOHN PROCTOR QRC 1 EYE ST.# N , w , * A 5 h I N G T G N, DC 20006 MJEEIi T SERS WARNING 1H NATIONAL INSTITUTE PCw OCCUPATIONAL SAFETY AND HEALTH CNIOSHJ w.uiVTb ru ADVISE USERS OF SCOTT AIH PAK II/IIA AND PHE6UK-HAK 1 I/I IA StLF-CONrAINEO BREATHING APPARATUS OF THE OCCURRtNCtS UF SPLII UR PUNCTURED REGULATOR DIAPHRAGMS, NIOSH TESTS INVESTIGATING THE EFFECT UF SUCH DEFECTS SHORED REDUCED respihaiuky protection on demand-mode apparatus, TutSE samc. tests also showed no loss in protection# but a loss in SbKViCt Tint *hEN IN THE PRESSURE DEMAND-MODE, NOTE] THE PWtSSUKt Demand UNIT IS NUf APPkUVEO while in The demand MuDEj iHt u t. m a in D MODE IS TO BE USED FOR DONnING PURPOSES ONLY, NIOSH BEGAN TrilS INVESTIGATION FOLLOWING THE RECENT DEATH OF IhRtt FIREFIGHTERS wnC *tRE WEARING THIS TYPE OF RESRIRail'K# ALTHOUGH IT HAS NUT BEEN ESTABLISHED THAT THE OEAlrtS * t R t Dbt TO DAMAGED REGULATOR DIAPHRAGMS, A 5AMPLInG OF The APPARATUS IN THE FIELD HAS SHUwN AT LEASH 10X OF Tht UNITS EXAMINED HAVE RUPTURED OR PUNCTURED DIAPHRAGMS. USERS ShUULD c.X AMI NE THEIK SCOTT APPARATUS FOH, POSSIBLE# DAMAGED UiAPHKAGHSilN ACCURDANCE wlTH MANUFACTURER'S instructions, the user should check the diaphragm before EACH Dot 6Y CLOSING OUTH THE MAIN LINE AND BYPASS VALVES anu blowing through the regulator outlet port, it should be possible to maintain a slight positive pressure in the REGULATOR, The user SHOULD CHECK THE REGULATOR DIAPHRAGM AFTER EACH USE AND DURING MONTHLY INSPECTIONS OF THE C U M p l t T t APPARATUS, IT IS NUT KNGwN IF FAILURE OCCURS DURING ASSEMBLY# storagl# OR USE of the respirator regulator, THEHrUKc EXTREME CAUTION MUST BE EMPLOYED WHEN USING Tht RESHIKAIUR, In CHECKING THE OPERATION OF THE RESPIRATOR, USEkS Ahfc CAUTIONED NOT TU BLOCK THE FLOW OF AIR FRqm THE REGuLAlUh whEN THE B-YPASS VALVE IS OPEN, BECAUSE SUBSTANTIAL OBSTPUUIUN MAY RUPTURE OK DISLODGE 1H DIAPHRAGM, IF THE USER OoStRVES A LOOSE UR DISLODGED REGULATOR COVER# ThE COVER MUSI BE _R^MH_VbO and '_THE DIAPHRAGM INSPECTED BEFORE K_EAS_$E.M3LY OF ThE regulator. PENDING DETERMINATION OF THE REASON FOR AND NECESSARY CORRECTIVE ACTION TO PREVENT DIAPHRAGM FAILURE, FOR FURIHER TECHNICAL INFORMATION CONTACT: MR, RICHARD HONK, mosh# vau chestnut ridge road# mqrgantown, wv 2bSQ5. PRUNE; 130MJS99-7337. ANTHONY ROBBINS# DIRECTOR# NIUSH ROCKVILLE MO M,D 00 0 01 ^ESPi^ORTJt^r ECTION FACTORS TYPE RESPIRATOR FACEPIECE2 PRESSURE AIR-PURIFYING A. PARTICULATE3 REMOVING SINGLE-USE,4 DUST5 QUARTER-MASK, DUST6 HALF-MASK, DUST6 HALF-OR QUARTER-MASK, FUME7 HALF-OR QUARTER-MASK, HIGH-EFFICIENCY8 - - PROTECTION FACTOR 5 5 10 10 10 FULL FACEPIECE, HIGH-EFFICIENCY POWERED, HIGH-EFFICIENCY, ALL ENCLOSURES POWERED, DUST OR FUME, ALL ENCLOSURES B. GAS AND VAPOR-REMOVING10 - 50 + 1000 + X9 . HALF-MASK FULL FACEPIECE II. ATMOSPHERE-SUPPLYING A. SUPPLIED-AIR DEMAND, HALF-MASK DEMAND, FULL FACEPIECE HOSE MASK WITHOUT BLOWER, FULL FACEPIECE PRESSURE-DEMAND, HALF-MASK11 PRESSURE-DEMAND, FULL FACEPIECE12 - 10 - 50 - 10 - 50 - 50 + 1000 + 2000 HOSE MASK WITH BLOWER, FULL FACEPIECE CONTINUOUS FLOW, HALF-MASK11 CONTINUOUS FLOW, FULL FACEPIECE12 CONTINUOUS FLOW, HOOD, HELMET, OR SUIT13 - 50 + 1000 + 2000 + 2000 B. SELF-CONTAINED BREATHING APPARATUS (SCBA) OPEN-CIRCUIT, DEMAND, FULL FACEPIECE OPEN-CIRCUIT, PRESSURE-DEMAND FULL FACEPIECE - 50 + 10,00014 III. CLOSED-CIRCUIT, OXYGEN TANK-TYPE, FULLFACEPIECE COMBI NAT ION RESPIRATOR A. ANY COMBINATION OF AIR-PURIFYING AND ATMOSPHERE-SUPPLYING RESPIRATOR. B. ANY COMBINATION OF SUPPLIED-AIR RESPIRATOR AND AN SCBA - 50 USE MINIMUM PROTECTION FACTOR LISTED ABOVE FOR TYPE OF MODE OF OPERATION EXCEPTION: COMBINATION SUPPLIED-AIR RESPIRATORS, IN PRESSURE-DEMAND OR OTHER POSITIVE PRESSURE MODE, WITH AN AUXILIARY SELF-CONTAINED AIR SUPPLY, AND A FULL FACEPIECE, SHOULD USE THE PF FOR PRESSURE-DEMAND SCBA. SAL 000OS USE OF TABLE REQUIRES ACCOMPANYING FOOTNOTES. ; COURTESY OF LAS ALAMOS SCIENTIFIC LABORATORIES Vhe overall protection afforded by a given respirator design (and mode of OPERATION) may BE DEFINED IN TERMS OF ITS PROTECTION FACTOR (PF). THE PF IS A MEASURE OF THE DEGREE OF PROTECTION AFFORDED BY A RESPIRATOR, DEFINED AS THE RATIO OF THE CONCENTRATION OF CON-- TAMINANT IN THE AMBIENT ATMOSPHERE TO THAT INSIDE THE ENCLOSURE (USUALLY INSIDE THE FACEPIECE) UNDER CONDITIONS OF USE. RESPIRATORS SHOULD BE SELECTED SO THAT THE CONCENTRATION INHALED BY THE WEARER WILL NOT EXCEED THE APPROPRIATE LIMIT. THE RECOWENDEO RESPIRATOR PF'S ARE SELECTION AND USE GUIDES, AND SHOULD ONLY BE USED WHEN THE EMPLOYER HAS ESTABLISHED A MINIMAL ACCEPTABLE RESPIRATOR PROGRAM AS DEFINED IN SECTION 3 OF THE ANSI Z88.2-1969 STANDARD. 2IN ADDITION TO FACEPIECES, THIS INCLUDES ANY TYPE OF ENCLOSURE OR COVERING OF THE WEARER'S BREATHING ZONE, SUCH AS SUPPLIED-AIR HOODS HELMETS, OR SUITS. Includes dusts, mists, and fumes only, does not apply when gases or vapors are absorbed on particulates and may be volatilized or for particulates volatile at room temperature. EXAMPLE: COKE OVEN EMISSIONS. 4ANY SINGLE-USE DUST RESPIRATOR (WITH OR WITHOUT VALVE) NOT SPECIFICALLY TESTED AGAINST A SPECIFIED CONTAMINANT. 5SINGLE-USE DUST RESPIRATORS HAVE BEEN TESTED AGAINST ASBESTOS AND COTTON DUST AND COULD BE ASSIGNED A PF OF TO FOR THESE PARTICULATES. 6DUST FILTER REFERS TO A DUST RESPIRATOR APPROVED BY THE SILICA DUST TEST, AND INCLUDES ALL TYPES OF MEDIA, THAT IS, BOTH NONDEGRADABLE MECHANICAL TYPE MEDIA AND DEGRADABLE RESINIMPREGNATED WOOL FELT OR COMBINATION WOGL-SYNETHETIC FELT MEDIA. 7FUME FILTER REFERS TO A FUME RESPIRATOR APPROVED BY THE LEAD FUME TEST. ALL TYPES OF -MEDIA ARE INCLUDED. 8HIGH-EFFICIENCY FILTER REFERS TO A HIGH-EFFICIENCY PARTICULATE RESPIRATOR. THE FILTER MUST BE AT LEAST 99.97% EFFICIENT AGAINST 0.3 pm DOP TO BE APPROVED. 9T0 BE ASSIGNED, BASED ON DUST OR FUME FILTER EFFICIENCY FOR SPECIFIC CONTAMINANT. 10FOR GASES AND VAP0R5, A PF SHOULD ONLY BE ASSIGNED WHEN PUBLISHED TEST DATA INDICATE THE CARTRIDGE OR CANISTER HAS ADEQUATE SORBENT EFFICIENCY AND SERVICE LIFE FOR A SPECIFIC GAS OR VAPOR. IN ADDITION, THE PF SHOULD NOT BE APPLIED IN GAS OR VAPOR CONCENTRATIONS THAT ARE: 1) IMMEDIATELY DANGEROUS TO LIFE, 2) ABOVE THE LOWER EXPLOSIVE LIMIT, AND 3) CAUSE EYE IRRITATION WHEN USING A HALF-MASK. ]1A POSITIVE PRESSURE SUPPLIED-AIR RESPIRATOR EQUIPPED WITH A HALF-MASK FACEPIECE MAY NOT BE AS STABLE ON THE FACE AS A FULL FACEPIECE. THEREFORE, THE PF RECOMMENDED IS HALF THAT FOR A SIMILAR DEVICE EQUIPPED WITH A FULL FACEPIECE. 12A POSITIVE PRESSURE SUPPLIED-AIR RESPIRATOR EQUIPPED WITH A FULL FACEPIECE PROVIDES EYE PROTECTION BUT IS NOT APPROVED FOR USE IN ATMOSPHERES IMMEDIATELY DANGEROUS TO LIFE. IT IS RECOGNIZED THAT THE FACEPIECE LEAKAGE, WHEN A POSITIVE PRESSURE IS MAINTAINED, SHOULD BE THE SAME AS AN SCBA OPERATED IN THE POSITIVE PRESSURE MODE. HOWEVER, TO EMPHASIZE THAT IT BASICALLY IS NOT FOR EMERGENCY USE, THE PF IS LIMITED TO 2,000.13 13THE DESIGN OF THE SUPPLIED-AIR HOOD, SUIT, OR HELMET (WITH A MINIMUM OF 6 CFM OF AIR) MAY DETERMINE ITS OVERALL EFFICIENCY AND PROTECTION. FOR EXAMPLE, WHEN WORKING WITH THE ARMS OVER THE HEAD, SOME HOODS DRAW THE CONTAMINANT INTO THE HOOD BREATHING ZONE. THIS MAY BE OVERCOME BY WEARING A SHORT HOOD UNDER A COAT OR OVERALLS. OTHER LIMITATIONS SPECIFIED BY fHE APPROVAL AGENCY MUST BE CONSIDERED BEFORE USING IN CERTAIN TYPES OF ATMOSPHERE. 14the scba operated in the positive pressure mode has been tested ON A SELECTED 31-man PANEL AND THE FACEPIECE LEAKAGE RECORDED AS LESS THAN 0.01* PENETRATION. THEREFORE, A PF OF 10,000f IS RECOMMENDED. AT THIS TIME, THE LOWER LIMIT OF DETECTION 0.01* DOES NOT WARRANT LISTING A HIGHER NUMBER. A POSITIVE PRESSURE SCBA FOR AN UNKNOWN CONCENTRATION IS RECOMMENDED. THIS IS CONSISTENT WITH THE lO.OOOf THAT IS LISTED. IT IS ESSENTIAL TO HAVE AN EMERGENCY DEVICE FOR USE IN UNKNOWN CONCENTRATIONS. A COMBINATION SUPPLIED-AIR RESPIRATOR IN PRESSURE-DEMAND OR OTHER POSITIVE PRESSURE MODE, WITH AUXILIARY SELF-CONTAINED AIR SUPPLY IS ALSO RECOMMENDED FOR USE IN UNKNOWN CONCENTRATIONS OF CONTAMINANTS IMMEDIATELY DANGEROUS TO LIFE. OTHER LIMITATIONS, SUCH AS SKIN ABSORPTION OF HCN OR TRITIUM, MUST BE CONSIDERED. ,0005