Voluntary Respirator Use

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Voluntary Respirator Use Respirator Cartridge
Change Schedules - C. D. Jones, 4/28/00

• Everything you wanted to know, in less than one
  hour Ill primarily review OSHA material and
  some Navy stuff
• Most of the OSHA information comes from two
  sources
• (a) 29 CFR 1910.134 - OSHA Respirator Standard
  (http//www.osha-slc.gov/OshStd_data/1910_0134.htm
  l) (effective 4/8/98) and
• (b) OSHA Directive CPL 2-0.120 - Inspection
  procedures for the Respiratory Protection
  Standard (http//www.osha-slc.gov/OshDoc/Directive
  _data/CPL_2-0_120.html)
• Most of the Navy stuff comes from the OPNAVINST
  5100.23E

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How do you determine if respirator use is
necessary? You need to evaluate your workplace

• 29 CFR 1910.134 (d)(1)(iii) - The employer shall
  identify and evaluate the respiratory hazard(s)
  in the workplace this evaluation shall include a
  reasonable estimate of employee exposures to
  respiratory hazard(s) and an identification of
  the contaminant's chemical state and physical
  form. Where the employer cannot identify or
  reasonably estimate the employee exposure, the
  employer shall consider the atmosphere to be
  IDLH.
• So, youve got to look at your workplace and see
  if you need them.

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How do you determine if respirator use is
necessary? You need to evaluate your workplace

• The Navy implies this be done in Chapter 8 (not
  Chapter 15) of the 23E and spells it out in
  Chapter A3 of the 19C

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So youve checked your workplace and .

• You determined that respirators arent necessary
• Some folks may want to wear respirators anyway
  (because they like to ?)
• You can consider allowing voluntary respirator
  use
• What exactly is voluntary respirator use?

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Voluntary respirator use -

• OSHA - 29 CFR 1910.134 (c)(2)(i) - an employer
  may provide respirators at the request of
  employees or permit employees to use their own
  respirators, if the employer determines that such
  respirator use will not in itself create a
  hazard. If the employer determines that any
  voluntary respirator use is permissible, the
  employer shall provide the respirator users with
  the information contained in Appendix D
  (mandatory appendix) to this section
  ("Information for Employees Using Respirators
  When Not Required Under the Standard")

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1910.134 (Mandatory) Appendix D -

• If your employer provides respirators for your
  voluntary use, or if you provide your own
  respirator you should do the following
• 1. Read and heed all instructions on use,
  maintenance, cleaning and care, and warnings
  regarding the respirators limitations.
• 2. Choose respirators certified for use to
  protect against the contaminant of concern. NIOSH
  certifies respirators (more on this in a few
  minutes).

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1910.134 (Mandatory) Appendix D -

• 3. Do not wear your respirator into atmospheres
  containing contaminants for which your respirator
  is not designed to protect against. For example,
  a respirator designed to filter dust particles
  will not protect you against gases, vapors, or
  very small solid particles of fumes or smoke.
• 4. Keep track of your respirator so that you do
  not mistakenly use someone else's respirator.

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Voluntary Respirator Use -

• (And) 29 CFR 1910.134 (c)(2)(ii) - In addition,
  the employer must establish and implement those
  elements of a written respiratory protection
  program necessary to ensure that any employee
  using a respirator voluntarily is medically able
  to use that respirator (c)(1)(ii), and that the
  respirator is cleaned, stored, and maintained
  (c)(1)(v) so that its use does not present a
  health hazard to the user.
• The medical evaluation is described in part (e),
  cleaning etc. in part (h)
• There is an exception to the above

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Voluntary Respirator Use -

• 29 CFR 1910.134 (c)(2)(ii) - Exception Employers
  are not required to include in a written
  respiratory protection program those employees
  whose only use of respirators involves the
  voluntary use of filtering facepieces (dust
  masks).
• Filtering facepieces - those inexpensive masks
  that all the hardware stores sell? Maybe. For
  dusts only? Maybe.
• OSHA Directive CPL 2-0.120 states that use of
  elastomeric facepieces, even when voluntary,
  requires inclusion of all of the elements of a
  respirator program

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Voluntary use - what kind of respirator can you
use if you dont really need one? Hmmm .

• Depends on who you ask
• Since the OSHA standard says you can use a
  filtering facepiece, which may or may not be a
  respirator, does that thing on your face need to
  be approved by the National Institute of
  Occupational Safety and Health (NIOSH)?
• OSHA standard doesnt require this, but Appendix
  D (which is mandatory) seems to. Choose
  respirators certified for use against the
  contaminant of concern. It then states that
  NIOSH certifies respirators.

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Voluntary use - what kind of respirator can you
use if you dont really need one?

• OSHAs compliance directive CPL 2-0.120,
  Inspection procedures for the Respiratory
  Protection Standard, contradicts Appendix D
• It states NIOSH-approved respirators are
  strongly recommended, but they are not required
  for voluntary use.
• Good practice - only use NIOSH-approved
  respirators, and throw away the rest

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Does the Navy allow voluntary respirator use?

• Nope.
• 23E, Chapter 15, 1503 g. - Navy policy is that
  activities shall not establish voluntary
  respiratory use programs as provided for by
  reference 15-3 (29 CFR 1910.134)
• Thats too bad .

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Any questions about voluntary respirator use?

• When I asked for questions I meant easy ones .
• OK, what about change schedules .

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Respirator Cartridge / Canister Change Schedules

• Not required by 29 CFR 1910.134 when using
  respirators for protection against particulates
  (d)(3)(iv) you change these when you cant
  breathe through them
• Required when using respirators for protection
  against gases and vapors in most circumstances.
  Section (d)(3)(B)(2) states you either need an
  end of service life indicator (ESLI), or a change
  schedule based on objective info or data that
  will ensure that (they) are changed before the
  end of their service life
• There are very few ESLI cartridges available

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Respirator Cartridge / Canister Change Schedules

• OSHA has previously published change schedules
  for some chemicals in some of their specific
  standards for acrylonitrile, benzene, butadiene,
  formaldehyde, vinyl chloride, and methylene
  chloride
• Change schedules for all other gases and vapors
  must be established and implemented by the
  employer
• Once you implement an effective change schedule,
  you can use air-purifying gas and vapor
  respirators

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Change schedules - something new under the sun

• In the old days you changed chemical cartridges
  when you experienced breakthrough, when you
  detected odors or some other warning property
  inside the facepiece
• The new standard prohibits the use of warning
  properties as the sole basis for determining
  change schedules

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Change schedules -

• 29 CFR 1910.134 (d)(3)(iii)(B)(2) - If there is
  no ESLI appropriate for conditions in the
  employer's workplace, the employer implements a
  change schedule for canisters and cartridges that
  is based on objective information or data that
  will ensure that canisters and cartridges are
  changed before the end of their service life. The
  employer shall describe in the respirator program
  the information and data relied upon and the
  basis for the canister and cartridge change
  schedule and the basis for reliance on the data.

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Navys change schedule policy

• Section 1505 a. - Activities (the folks we
  survey) shall
• (1) implement a change schedule for chemical
  canisters / cartridges based on objective
  information or data that will ensure that
  canisters and cartridges are changed before the
  end of their service life. Activities must
  describe this data, along with the logic for
  relying on the change schedule, in their
  respirator programs.
• (2) Change chemical canisters / cartridges
  according to manufacturers directions, or based
  on objective data obtained as indicated in
  reference 15-4 (the NEHC Technical Manual)
• (3) Identify respirator cartridges and canisters
  by the information provided on the approval
  labels in lieu of color coding
• Activities must do it, not use (strange, isnt
  it?)

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Some things that influence cartridge life

• Single or multiple contaminants in the workplace
• Concentration of the chemical in the workplace
• Physical properties of the chemical
• Adsorbing capacity of the cartridge sorbent
• Relative humidity in the workplace
• Temperature in the workplace
• Workers breathing rate

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First step - determine the chemical concentration
in the workplace two ways to do this

• Air sampling - collect enough samples in the
  workplace to ballpark personnel exposures. Ideal
  situation - multiple samples on multiple people
  on multiple days multiple statistical tests can
  be used (geometric mean, 95th percentile, etc.).
  Worst case sampling is next best choice
• Modeling - cumbersome, not warm and fuzzy. Most
  are based on the exposure from a single
  contaminant
• Air sampling is (my) preferred approach
• Both air sampling and modeling are strongly
  influenced by high humidity

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Next step - estimate breakthrough time for the
calculated chemical concentration

• Use respirator cartridge manufacturers chemical
  cartridge service life calculator. Here are two,
  there are more
• MSA Cartridge Life Expectancy Calculator http//w
  ww.msanet.com/safetyproducts/cartlife/index.html
• 3M Respirator Service Life Software Version
  2.0 http//csrv.3m.com/CSRV/SilverStream/Pages/pg
  CsrvUserProfile.html
• Use OSHAs Advisor Genius calculator
• http//www.osha-slc.gov/SLTC/respiratory_advisor/a
  dvisor_genius_wood/advisor_genius.html

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To determine cartridge change schedules, youll
need info about the chemical and the workplace

• Chemical information
• concentration
• occupational exposure limit
• molecular weight
• specific gravity or density
• boiling point
• vapor pressure
• Workplace information
• temperature
• relative humidity
• breathing rate of personnel
• safety factor for the workplace

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Example cartridge change schedule for single
chemical, toluene, using MSAs on-line calculator

• Personnel wearing MSA Comfo Classic facepiece
  with an Advantage 200 GMA cartridge want to
  protect against toluene estimated toluene
  concentration is 36 ppm PEL is 200 ppm
  workplace temp is 75 degrees F, relative humidity
  is 75, barometric pressure is 760 mm Hg
  moderate breathing rate of 60 lpm (low 30,
  high 85) breakthrough concentration ( of the
  PEL that triggers cartridge change) 10
• Estimated breakthrough time for this environment
  under these conditions is 1738 min, or 29 hrs

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Example cartridge change schedule for single
chemical, toluene, using MSAs on-line calculator

• That means 29 hours of use in this environment,
  if you select 10 of the toluene PEL of 200 ppm
  as the level when you change the cartridge
• What if you wanted to calculate a change schedule
  using the ACGIH TLV of 50 ppm as your standard
  instead of using the PEL? Or if you wanted to use
  a fraction of the PEL?
• MSAs calculator doesnt allow you to do this
• 3Ms calculator doesnt have much flexibility
  either
• Humidity presents a problem with most calculators

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Cartridge change schedules for a mixture of
chemicals are more difficult to calculate

• MSAs on-line calculator wont calculate them
• MSA rep says there are ways to derive them using
  the vapor pressure of the individual chemicals in
  the mixture
• 3Ms calculator will calculate a change schedule
  for a mixture of some chemicals probably does
  not have all the selections you are interested in
  on their pull-down menu
• Bottom line - a change schedule for a single
  stressor is difficult to do, and for a mixture is
  even more difficult

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Example cartridge change schedule for multiple
chemicals, using 3Ms downloaded calculator

• Try this at home or at your desk, after you
  download the software from 3M it (the download
  and the use of the software) is easy to do
• Your results probably wont be what you like them
  to be you wont get definitive answers, probably
  because more research needs to be done
• The default response of throw them away after
  initial use is probably the best position to
  espouse.

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OSHAs suggestions for mixed chemical environments

• For mixtures in which not all of the components
  are listed, calculate using the most
  characteristic component of the mixture
• Do not use chemical cartridges to protect
  personnel from chemicals that have breakthrough
  times less than 15 minutes
• Do not reuse cartridges if a chemical
  constituent has a boiling point of less than 65
  degrees C If b.p. lt65, the chemical tends to
  migrate within the cartridge (for example,
  acetone, which has a b.p. 56)

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OSHAs suggestions for mixed chemical environments

• If compounds in the mixture vary by two orders of
  magnitude, the service life may be based on the
  contaminant with the shortest breakthrough time

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The Navys official suggestions regarding change
schedule calculations

• There arent any. Surprise!
• Dave Spelce at NEHC proposed a very complicated
  procedure that involved sampling the work
  environment, using the 95th percentile plus a
  safety factor as an exposure number to hang your
  hat onto then sampling in the field behind the
  cartridge to determine if and when breakthrough
  occurred. This was not smiled upon by the powers
  that be
• Official NMCP IH Dept suggestions - see the top
  line
• Weve only had since 4/8/98 to come up with them
  .

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In conclusion .

• Remember Field of Dreams? If you build it, he
  will come
• Consider that OSHA built it when they built 29
  CFR 1910.134
• Well just have to wait until he gets here .
• Thank you. Any questions?