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CBRN Respirators4

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Title: CBRN Respirators4


1
SCBA Technicals
22nd U.S. Navy Joint Safety
Occupational Health Professional Development
Conference, Cloud-Based Training March 10-14,
2014 Terrence K. Cloonan National Personal
Protective Technology Laboratory Pittsburgh,
PA
2
IH Track SCBA Overview
  • NPPTL Introduction
  • Mission standards
  • Respirator approval program
  • SCBA Technicals
  • Definition description
  • New publications and letters
  • OSHA selection criteria
  • Required use, recognition, maintenance standards
    levels, ECBC, NFPA, cautions limitations,
    EBSS, technician training, and field observations

3
Agency Hierarchy
HHS
Department of Health and Human Services
CDC
Centers for Disease Control and ATSDR
National Institute for Occupational Safety and
Health
NIOSH
NPPTL
National Personal Protective Technology Laboratory
4
Personal Protective Technology (PPT) Standards
  • NPPTL activity focus
  • national
  • international standards
  • Enables research 2 practice (R2P)
  • Relevance of research
  • Impact of research
  • Quality science
  • Peer-reviewed science
  • Published

5
Respirator Approval Program
More than 8500 approvals issued
93 manufacturers 102 manufacturing sites 22
countries
US, Australia, Brazil, Canada, Chile, China,
Columbia, Denmark, England, Finland, Germany,
India, Israel, Italy, Japan, Korea, Latvia,
Mexico, New Zealand, Taiwan, Thailand, Sweden
6
Open-Circuit, Pressure Demand, Self-Contained
Breathing Apparatus (SCBA) Respirator
  • The term Respirator is defined in 42 CFR Part
    84, 84.2 - means any device designed to
    provide the wearer with respiratory protection
    against inhalation of a hazardous substance.
  • SCBA written description is in 84.70, (13F
    schedule) - includes all completely assembled,
    portable self-contained devices designed for use
    as respiratory protection during entry into and
    escape from, or escape-only from, hazardous
    atmospheres and provides a local source of grade
    D breathing air to the user while maintaining a
    positive pressure in the facepiece-to-human
    face sealing surfaces

7
CBRN SCBA Approvals
  • Based on
  • Compliance with all relevant 42 CFR 84
    requirements
  • Demonstrated resistance to chemical warfare
    agents through laboratory testing
  • Successful completion of a laboratory respirator
    protection level (LRPL) test
  • Quantitative fit tested with corn oil particulate
  • Compliance to most recent version of NFPA 1981
    standard for open-circuit SCBA respirators

8
New Publications Letters
  • CIB 66, Derivation of IDLH Values, Publication
    No. 2014-100 http//www.cdc.gov/niosh/docs/2014-10
    0/
  • Respirator Users Notice, Use of After Market
    Component Parts, February 27, 2014
  • Letter to All Interested Parties, Evaluation and
    Acceptance of Emergency Breathing Support Systems
    (EBSS) Incorporated into SCBA Approvals, February
    18, 2014
  • Respirator Users Notice, CWA Testing for NIOSH
    CBRN Respirator Approvals, 11/27/13

9
OSHA Permissible Practice
Hierarchy of Controls
10
SCBA Required Recommended Use
  • OSHA 29 CFR 1910.134, RP Standard
  • OSHA Pub 3352-02, 2009, APFs
  • OSHA 29 CFR 1910.146, Confined Space
  • OSHA 29 CFR 1910.156, Industrial Fire Brigade
  • FEMA USFA-TR-088, Prev. of SCBA Failures
  • NIOSH/OSHA/USCG/EPA Pub 85-115, OSHWS
  • NIOSH Pub 87-116, Guide to Industrial RP
  • CDC NIOSH Alert, September 1994
  • NIOSH Pocket Guide to Chemical Hazards
    698 compounds listed SCBA selection
    listed for 514

11
Selection Criteria
  • Use a national rule, standard, or guide.
  • ID Evaluate Hazards OSHA 29 CFR 1910.134
    (d)(1)(iii) The employer shall identify and
    evaluate the respiratory hazard(s) in the
    workplace
  • Reasonable estimate of the employee exposures and
    an identification of the contaminants chemical
    state and physical form.
  • Where the employer cannot identify or reasonably
    estimate the exposure, the employer shall
    consider the atmosphere to be IDLH.
  • Select a NIOSH-certified Respirator OSHA 29 CFR
    1910.134 (d)(1)(ii) The employer shall select a
    NIOSH-certified respirator. The respirator shall
    be used in compliance with the conditions of its
    certification.
  • Select/Offer Multiple Sizes, Models, and Makes
    OSHA 29CFR 1910.134 (d)(1) (iv) The employer
    shall select (offer) respirators from a
    sufficient number of respirator models and sizes
    so that the respirator (selected) is acceptable
    to correctly fits the user.
  • 2004 NIOSH Respirator Selection Logic
    http//www.cdc.gov/niosh/docs/2005-100/
    Paragraph B, (7) and Section III
    Respirator Selection Logic Sequence, Step
    1 Is the respirator intended
    for use during firefighting?

12
How to Recognize a CBRN SCBA
  • 5 indicators of compliance
  • Manufacturer operations manual/user instructions
    (UI) with new respirator
  • NIOSH Full Approval Label
    (paper version) in UI of new respirator
  • Back frame and harness assembly Entire label
    NIOSH Respirator Approval 13F Label (adhesive)
  • Back frame and harness assembly decals NFPA
    compliance SEI decals (adhesive)
  • Back frame and harness assembly abbreviated
    protections label CDC/ NIOSH CBRN Agent
    Approved label with and without
    Retrofit (adhesive)

13
SCBA Maintenance Standards Levels
  • OSHA 29 CFR 1910.134 (h)(4)(i) Repairs or
    adjustments of respirators are to be made only by
    persons appropriately trained to perform such
    operations and shall use only the respirator
    manufacturers NIOSH-approved parts designed for
    that respirator. 1910.134 (h) to (i) and (k)
    paragraphs apply.
  • OSHA Pub 3352-02, 2009, APFs Table 1, Assigned
    Protection Factors (APF) awards 10,000 APF value
    to pressure demand or other positive pressure
    mode SCBA. APF is only effective when the
    employer implements a continuing effective
    respiratory protection program to include
    training, fit testing, maintenance, and use
    requirements. The APF does not apply when used
    solely for escape.
  • 42 CFR Part 84 84.31 (b) The certificate of
    approval shall specifically set forth any
    restrictions or limitations on the respirators
    use in hazardous atmospheres. NIOSH caution and
    limitation (CL) statements I, J, M, N, O S all
    directly/indirectly refer to maintenance. For
    example, CL J Failure to properly use and
    maintain this product could result in injury or
    death.
  • NIOSH/OSHA/USCG/EPA Pub 85-115 Maintenance
    Levels 1,2, 3
  • NIOSH Pub 87-116 Figure 4-3 is a model SCBA test
    bench facility diagram

14
SCBA Voluntary Standards
  • National Fire Protection Association (NFPA)
  • 1852 Selection, Care Maintenance of OC-SCBA
  • 4.3.6 SCBA maintenance in RPP is per chapter 7
  • 1404 Fire Service Respiratory Protection
    Training
  • 1500 FD Occupational Safety Health Program
  • 1981 OC-SCBA for Emergency Services
  • 1982 Personal Alert Safety Systems (PASS)
  • SEI Inc. http//www.seinet.org/search/search.php
  • ANSI Z88.2 Respiratory Protection(w) Z88.10
    Fit Testing
  • IAFF Dispatch - SCBA Use Medical Requirements

15
CWA Testing for NIOSH CBRN User Notice
  • NIOSH employs the U.S. Army ECBC to conduct the
    chemical warfare agent (CWA) testing portion of
    the NIOSH chemical, biological, radiological, and
    nuclear (CBRN) respirator evaluation and testing
    program
  • ECBC notified NIOSH on November 18, 2013, of US
    Army ECBC errors in the live-agent challenge
    concentrations generated from 07/2012 to 10/2013
  • NIOSH issued a user notice on 11/27/13. CBRN SCBA
    compliant to the NFPA 1981 standards issued as
    1997, 2002, and 2007 editions are not adversely
    impacted.
  • Since 12/12/2013 NPPTL, the ECBC Office of the
    Director, and the ECBC Protective Equipment
    Testing Branch (PETB) have been verifying
    validating corrective actions retesting
    submitted respirators

16
NFPA 1981/1982 SCBA Compliance Labels
  • SEI sticker markings demonstrate compliance
  • Multiple adhesive stickers
  • SEI labels on the SCBA indicate which edition of
    the NFPA standard was in effect
  • Technology improvements are made every 5 years
  • SCBA of 19811997 2002 editions may have NIOSH
    CBRN protection but. ? NFPA 19812013
    requires SCBA be NIOSH CBRN protected

17
NIOSH CBRN SCBA Cautions Limitations
NIOSH SCBA 13F Approval SCBA User Instructions SCBA harness label shown
Master paper or e-document Issued with each new SCBA Required by NIOSH. Shows TC-Number
Located in official US files Normally paper copies Located on SCBA
Proprietary drawings Multiple pages w/legal review Lists types levels of protection
Quality control plan One master UI per SCBA type Traditional CL statements
Parts assembly matrix Accessories have UIs also CBRN CL Q, R, T, U
Master user instructions Warranty is found in UI U 6-hour mark use limitation
jjjjjK
18
NIOSH EBSS Letter
  • Published February 18, 2014, to all interested
    parties
  • Applicable only to SCBA meeting the requirements
    of NFPA 1981, 2013 edition, or subsequent
    editions
  • NIOSH will recognize NFPA 19812013 compliant
    EBSS subcomponents as a part of the NIOSH SCBA
    approval for users who have received the
    appropriate level of training
  • The letters EBSS will appear on the NIOSH label
  • NIOSH will require the manufacturers user
    instructions to provide EBSS training information
    until such time that NFPA 1404, NFPA 1500, and
    OSHA requirements are revised
  • e
  • orms

19
NIOSH EBSS Letter Continuum
  • NIOSH caution and limitation statement impact
  • EBSS letters on the NIOSH label with statement
    words that read activation or engagement of
    EBSS in either the donor or receiver mode changes
    the SCBA use to ESCAPE-ONLY. The approved
    service time of the rated cylinder for either the
    donor or the receiver is no longer applicable.
    etc
  • S EBSS may not be engaged or activated in donor
    mode after the EOSTI has activated.
  • S Users must be fully trained per NFPA
    1404/1500
  • S Simultaneous connection of more than two
    users (one donor and one receiver) is not
    permitted

20
Training for Technicians
  • Approval holder is primary training resource
  • Found in DoD, DOJ, DOE FEMA
  • Periodicity
  • Day-In-Day-Out SCBA experience
  • Level II Fire Department
  • Level III- Service Center
  • NFPA 1852, 4.9.3. Reads AHJ shall
    maintain evidence of
    technician training and competency

21
Credentialed SCBA Technician
  • Serviceability Guru
  • Recognized certificate
  • Operates a breathing machine test device
  • NFPA 1852 allowable maintenance focus
  • Upgrades/retrofits
  • Fair-wear-and-tear
  • Experience factor
  • Primary alternates
  • Hand-tool centric

22
NFPA 1852 Key Actions Summary
  • 5.1.8. SCBA selection for purchase criteria
    from AHJ
  • 7.1.1 7.1.2. SCBA user inspection frequency
    inspection specification checklist covering 47
    actions
  • 7.2.1- 7.2.4.6. Technicians conduct inspections
    and maintenance actions that require all SCBA to
    be tested on a breathing machine as defined
    in NFPA 18527.5.6 in accordance with AHJ
    SOPS, or manufacturer UI, whichever is more
    frequent, but in all cases, annually.
  • 7.3.- 7.4. Breathing air cylinder filling
    Hydro-Test
  • 7.5. Testing of SCBA 7.5.1 to 7.5.6 - SCBA
    shall be tested at least annually on a breathing
    machine capable of performing 12 tests listed in
    7.5.2-.6 in a 99 step sequence, at 103 L/min,
    85 L/min, 40 L/min work rates.

23
Maintenance
  • Daily inspection and repair
  • In-Service status retention
  • Parts O-ring lubrication
  • Storage, cleaning, sanitization, disinfection,
    reuse
  • Fit testing, cylinder service, EOSTI values,
    EBSS use
  • PPE compatibility with SCBA
  • Maintenance levels
  • 1/I User or Wearer
  • 2/II Shop Technician
  • 3/III Factory/Overhaul

24
Qualifications for Level 1 Maintenance
  • Firefighter 1 Certificate covers 23 tasks. SCBA
    use is task 7. Within task 7, IFSTA/NFAA
    require 5 inspection and maintenance sub-tasks,
    to include servicing cylinders
  • Firefighter 2 Certificate covers 23 tasks, plus
    17 additional tasks, with specialty areas
  • SCBA User Instructions (UI) NIOSH does not
    certify the use of the SCBA, only the technical
    requirements it is built to

25
Level 1/I Maintenance Training
  • Who trains the actual wearer of the SCBA?
    Initial purchase, fire academies, on-station,
    self training/reading the UI, You-Tube viewing,
    OJT.
  • Who conducts approval holder private industry
    courses for refresher training?
  • Who trains the DOT re-tester?
  • Periodicity?
  • Senior trains the novice
  • SCBA technician linkage

26
User Instructions Relate to Level 1/I
  • New SCBA are shipped with
    10-15-25 paper documents
  • The master user instructions have a litany
    of specific actions written in
    legal language
    ? Regular operational inspections
  • ? Use of the respirator data logging
    guidance
  • ? RIC UAC emergency use
  • ? Low temp operations emergency operations
  • ? Cylinder replacement procedures
  • ? Cleaning storage respirator markings,
    etc.
  • But performance of maintenance beyond the routine
    cleaning regular operational inspections
    requires a specialist level maintenance trained
    individual (P/N 595118-01)

27
UI Comparison to Level 1/I
  • SCBA UI contain a NIOSH approval
    label, sequential user actions,
    technology diagrams for a r for a trained
    wearer to interpret
  • Typical SCBA user instructions
    have a litany of specific actions, i.e
    ?Regular operational inspections
  • ? Use of the respirator and data logging
  • ? RIC UAC emergency use
  • ? Low temp emergency operations
  • ? Cylinder replacement procedures
  • ? Cleaning storage respirator markings
    etc.
  • Butperformance of maintenance beyond the routine
    cleaning operational inspections requires a
    certified technician

28
Breathing-Air Technicians Level 2/II
  • Found in Authorized Service Centers
  • Private industry training courses
  • Periodicity initial fielding and follow-ups
  • Upgrades vs cost pricing
  • Calibration hydrostatic test specialists
  • High level of pneumatic air science knowledge

29
Level 2/II or 3/III
  • Usually geared to one or two brands of SCBA as a
    brand specific authorized service center/PPE
    distributor
  • DOT licensed cylinder re-tester Hydro
  • Repairs/spare parts
  • Apply upgrades
  • Local business
  • Seasoned owners

30
Approval Holder Maintenance Level III
  • Level 3/III or higher Respirator
    manufacturer writes the maintenance requirements
  • Does all warranty work not done by authorized
    service centers
  • May build a breathing device
  • Manages a quality control plan
  • Trains all maintenance techs
  • May rent-out SCBA and kits
  • Publishes SCBA test data log forms and tool kit
    lists

31
Maintenance Using Devices and Kits
  • Locations Kits breathing devices are found at
    local service centers, municipality public safety
    departments, approval holder factories.
  • Breathing device for annual 1981/1852 SCBA flow
    tests
  • NIST traceable
  • Calibration requirements
  • SCBA static-test kits are available from the
    approval holder.

32
Field Observations of SCBA
Observations SCBA Part/Condition Analysis and Remedy
1) Not properly cleaned and disinfected before each use Facepieces and regulators Level I user gig. Normally remedied by user/wearer, with or without field technician/tech supervision
2) Missing parts during pre-inspection Chest straps nose cups, inlet discs User gig. Remedied by tech parts resupply repair
3) Damaged or worn-out indicators on respirator during pre- and post-use Straps, lenses, nose cups, regulators, backpack assemblies Maintenance deadline gig causes field replacement of part by SCBA technician
4) Structural or thermal damage during pre-inspection or while in-use Regulators, backpack assemblies and harnesses, cylinders Maintenance deadline gig that requires SCBA technician inspection, repair and/or part replacement
5) Components that are out-of-specification or are after-market parts Cylinders out of hydro. Cylinders beyond service life or overfilled SCBA technician inspection and warranty review. Requires factory level fix

33
Publications Specific to SCBA
  • NIOSH Fact Sheet Whats Special
    About CBRN SCBA? Publication No. 2011-183 August
    2011 http//www.cdc.gov/niosh/docs/2011-183/
  • NIOSH Fact Sheet NIOSH Approval
    Labels Key Information to Protect Yourself,
    Publication No. 2011-179 May 2011
    http//www.cdc.gov/niosh/docs/2011-179/

34
Software Data Base of Approvals
  • NIOSH certified equipment list (CEL)
  • NIOSH CBRN SCBA CEL http//www2a.cdc.gov/drds/cel
    /cel_cbrn_results.asp?startrecord1maxrecords50
    SearchQScbrncbrn_scba

35
SCBA Technicals
  • Session retention thoughts
  • Does it have an EBSS?
  • Is there an EBSS training program in place?
  • Are more than two users, (one donor and one
    receiver) permitted when EBSS is in use?
  • Are SCBA maintenance personnel factory trained
    technicians? How recent?
  • Are SCBA facepieces and hardware flow tested/
    Posi-checked together?

36
Thank you!!!
  • Disclaimer A majority of the findings and
    conclusions in this presentation have not been
    formally disseminated by the National Institute
    for Occupational Safety and Health (NIOSH) and
    should not be construed to represent any agency
    determination or policy.

The speaker thanks Harold Zedd and CDR Greg W.
Cook for their support. Source of instruction
presentation NIOSH, The National Personal
Protective Technology Laboratory (NPPTL) 626
Cochrans Mill Road P.O. Box 18070 Pittsburgh, PA
15236 (412) 386 - 4000 www.cdc/gov/niosh/npptl
Author Terrence K. Cloonan tcloonan_at_cdc.gov (412)
386 - 6701
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