The National Institute for Occupational Safety and Health (NIOSH) is in the process of developing new regulations for several types of respirators, in particular, for closed circuit self-contained breathing apparatus (CC-SCBA), supplied-air respirators (SARs) and powered air-purifying respirators (PAPR or PAPRs). Each of these proposals not only updates existing industrial requirements, but also has a chemical, biological, radiological and nuclear (CBRN) component.
This article primarily will focus on the PAPR category, where a large amount of change is occurring and several new requirements are being considered. In the present respirator regulations (Title 42, Code of Federal Regulations, Part 84 — also known as 42 CFR 84), there presently is no subpart specifically for PAPRs.
Here's a little background: 42 CFR 84 was a carry-over from 30 CFR 11. The movement of the respirator requirements from 30 CFR 11 to 42 CFR 84 occurred in 1995 with the updating of the non-powered particulate filter criteria. As part of this update, there were a few small resultant changes for PAPRs, such as the HEPA filter (now designated by NIOSH as HE) becoming the only particulate filter that could be approved. Other than that, the requirements for PAPRs essentially remained unchanged. With the new subpart (proposed to be called Subpart P), there now will be a subpart specifically for PAPRs.
Along with updating and consolidating some now-antiquated industrial requirements, adding an additional particulate classification (tentatively called PAPR 95) and adding a CBRN option, two proposed requirements will bring PAPRs into the 21st century. These include a requirement that the pressure inside the facepiece must remain positive and real-time monitoring of battery life. The new PAPR 95 filter would allow manufacturers to offer a PAPR with particulate protection equal to a N95 filter, which is similar to that currently allowed in Europe.
While the PAPR 100 filter will be loaded with DOP (dioctylphthalate) that can degrade filter media, the intention is to expose the PAPR 95 only to an instantaneous exposure of DOP. So, like the N-95, the PAPR 95 will not be evaluated for degradation. If you are familiar with NIOSH testing, you probably are aware that the N-95 is tested with sodium chloride (salt). Salt is not used as the test agent for the PAPR 95 because it tends to collect inside the test instruments and cause problems.
Most users believe PAPRs to be positive-pressure units. But in fact, many existing models can and do go negative during inhalation and the user may or may not be aware of this, especially during high work rates when one's mind is focused on the task at hand. Many units monitor flow and/or battery life, but lack any type of substantial air boundary or buffer to protect the wearer from possible exposure — even during brief negative pressure spikes.
With the new requirements that NIOSH is proposing, PAPRs will have to remain positive during NIOSH testing. They will be tested on a machine that simulates breathing and the PAPRs will be required to monitor and warn users when or if the inside air pressure goes below ambient. PAPRs also will be required to monitor battery life and warn when the battery becomes low.
Some companies, such as Interactive Safety Products Inc. (ISPI) and Safety Equipment America (SEA) already have products that may meet or even exceed the proposed requirements with little or possibly no updating. Other companies offer products that monitor airflow and have low-battery alarms that can be updated without too much reengineering. But there are many other PAPRs that will need significant modification if they are to meet the proposed requirements. Several manufacturers are already gearing future product changes and developments toward these proposed requirements.
UNTIL THE REGULATIONS TAKE EFFECT
What about before these new regulations take effect? Efforts to promulgate the new regulations are ongoing. These proposals can be seen by visiting the NIOSH National Personal Protective Technology Laboratory (NPPTL) Web site at http://www.cdc.gov/niosh/npptl and looking under the “Respirator Standards Development” heading.
However, these new regulations will not take effect immediately because the promulgation of regulations is an involved process. Proposals are developed, public meetings are held and comments are submitted and reviewed. Then the proposals may be revised and the process cycles for a time. Once this process is completed and the proposal becomes a regulation, having new products evaluated and approved to a new standard by NIOSH will add additional time.
But there are some better choices that can be made today. As stated above, some PAPRs on the market today already offer airflow and battery monitoring along with low-pressure, low-flow and/or over-breathing indicators. Also, based on an OSHA Assigned Protection Factor (APF) Federal Register Notice (71:50121-50192, Dated 8/24/2006), PAPRs can claim an APF of 1,000 if the manufacturer has supporting test data to support the claim. Using a PAPR where the manufacturer has designed the unit such that it can provide the APF of 1,000 certainly would be a better choice. (See http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL _REGISTER&p_id=18846.)
WHAT ELSE IS NEW?
There are a wide array of PAPRs on the market today designed to protect the wearer in various environments and working conditions. Designs that eliminate air hoses and cords running down from the hood, helmet or facepiece to the wearer's belt can be a big plus for someone working in close quarters or where he or she may have to lie down and slide forward or backward (such as working under a piece of equipment). Also, hoses and cords can restrict movement and can get caught on obstacles. Designs that incorporate a hardhat or welding lens are very desirable for some work situations.
In addition, some designs offer an integrated cape that covers the neck and shoulders to protect from small debris. These capes also may provide a boundary zone, further distancing the inside purified air from the ambient air. This helps prevent the wearer from breathing unfiltered air in the event of short-term over-breathing. There are other situations where full facepieces may be best because — although they do not offer head protection — they shield the eyes, are lighter than a helmet and are less cumbersome. In addition, certain designs, such as a full facepiece, may be required by compound specific standards such as asbestos. In other situations, the half-mask unit may be best because it usually is less expensive and offers respiratory protection with a minimum of bulk in the face and head area, although the user's eyes are exposed to the environment. Welding fume exposure and the OSHA Hexavalent Chrome Standard make the PAPR and its APF of 25 or 1,000 ideal protection for many welding applications where engineering controls are not practical. Manufactures continue to offer more and more PAPR options for protecting for welder.
Regardless of the headpiece or facepiece type, many people prefer PAPRs over non-powered units because they find it is easier to breath and like the cooling effects of the moving air. This moving air also helps prevent the lens from fogging. So, before you buy one or several new PAPRs, it may be worth investigating what's on the horizon and what's available today to carry you through. And, no matter what unit you choose, evaluate your working situation for the type needed, make sure it is available with the appropriate filters or cartridges for the environment you are using it in, is NIOSH-approved and if available, is one that can been shown to have an APF of 1,000.
OTHER PROPOSALS
NIOSH is considering changes for CC-SCBAs and SARs, as well. For example, the testing of a CC-SCBA is being brought more in line to the way it is actually used. For the SAR, things are being considered such as evaluating complete portable systems. To briefly expand on this concept, many users believe the complete system from the compressor to the facemask is NIOSH-approved. In fact, only the parts from the airline to the mask are approved.
There even are some “0 hose length” systems were the airline is not included in the approval. These “0 hose length” systems are intended for workers performing tasks where they sit at a bench or are otherwise stationary and the airline would only serve to get in the way. While stationary compressors will continue to be required to provide Grade D air and can be inspected by OSHA, no one is evaluating portable compressors. As such, NIOSH is proposing to test and evaluate these portable systems from compressor or blower to the facemask. Also, both of these systems are being proposed to be approved with a CBRN component. Further discussion of the proposals for the CC-SCBA and the SAR are too involved for this article but may be the topic of a future article.
Bill Hoffman is the regulatory affairs specialist for Interactive Safety Products Inc.