Chemical spills vary from incidental to deadly. No matter the spill type, as a responder, you risk overexposure. When entering a hot zone, you must be protected against the actual or potential hazards. The good news is, personal protective equipment (PPE) and chemical protective clothing (CPC) may work to shield, isolate or otherwise protect you from not only chemical hazards but also physical and biological hazards when other control measures are not enough.
It’s important to know, though, this gear has its limits. No single set of PPE and CPC will guard against all hazards. These suits may even pose their own threats to wearers, such as heat illness; psychological/physiological stress; muscle fatigue; and impaired mobility, dexterity, tactility, vision, and communication.
Therefore, choosing the right PPE-CPC combination is a critical part of any spill response operation. Your goal, however, is to reach an adequate level of protection and avoid over- and under-protection.
Examples of PPE
PPE minimizes your exposure to chemical, physical and/or biological hazards that cause injuries, illnesses and/or fatalities. Examples of PPE include—but are not limited to—respiratory, head, eye, face, hearing, hand, foot and fall protection.
Examples of CPC
CPC protects your skin and/or body from chemical splashes, dusts, gases and vapors. Thoughts of CPC may conjure images of the fully encapsulating chemical-protective suit, which looks like an astronaut suit. However, there are plenty of other sorts of CPC, including hooded one- and two-piece chemical-protective suits, long-sleeved jackets/coats, chemical-protective gloves/over-gloves, protective sleeves/leggings, aprons, coveralls/pants, hoods and disposable shoe/boot covers.
Technically, CPC is a subcategory of personal protective clothing (PPC), or any wearable item designed to protect the well-being of the worker. A protective garment could potentially qualify as PPC, CPC and PPE at the same time. For instance, a glove that protects the hands from chemical contact (and subsequent skin absorption, chemical burns, etc.) would fall under all three terms.
Levels of protection
PPE and CPC are worn together in a “PPE ensemble,” informally called a “hazmat suit.” The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPA) have long referred to four ensemble levels — A, B, C and D. Table 1 describes the protection provided as well as the typical and optional types of PPE and CPC that make up each level.
Table 1: OSHA/EPA ensemble levels
|
Level A |
Level B |
Level C |
Level D |
|
Highest degree of respiratory, skin and eye protection |
Highest degree of respiratory protection but a lower degree of skin protection |
Lower degree of respiratory and skin protection |
No respiratory protection but the lowest degree of skin protection |
|
Typical components: · Positive-pressure, full-facepiece self-contained breathing apparatus (SCBA) or a positive-pressure, supplied-air respirator with an escape SCBA · Fully encapsulating chemical-protective suit · Inner and outer chemical-resistant gloves · Chemical-resistant safety boots
Optional components: · Cooling unit · Coveralls · Long underwear · Hard hat · Disposable suit, gloves and boots worn over the suit |
Typical components: · Positive-pressure, full-facepiece SCBA or a positive-pressure, supplied-air respirator with an escape SCBA · Hooded chemical-resistant clothing · Inner and outer chemical-resistant gloves · Chemical-resistant safety boots
Optional components: · Coveralls · Chemical-resistant, disposable boot covers · Hard hat · Face shield |
Typical components: · Full-face or half-mask, air-purifying respirator with appropriate cartridge · Hooded chemical-resistant clothing · Inner and outer chemical-resistant gloves
Optional components: · Coveralls · Chemical-resistant safety boots · Chemical-resistant, disposable boot covers · Hard hat · Escape mask · Face shield |
Typical components: · Coveralls · Chemical-resistant safety shoes or boots · Safety glasses or goggles
Optional components: · Gloves · Chemical-resistant, disposable boot covers · Hard hat · Escape mask · Face shield |
Table 1 sources:
29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.
OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.
Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.
EPA’s Personal Protective Equipment webpage within the agency’s Emergency Response homepage.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities(DHHS publication no. 85-115).
Hazard assessment
Before you try to work out which PPE ensemble level is appropriate for the spill at hand, size up the situation. Consider:
- The chemical(s) involved (or suspected) and its state, concentration, hazard(s) and exposure route(s);
- Oxygen deficiency and immediately dangerous to life or health (IDLH) conditions;
- Actual exposure levels and the required/recommended exposure limits;
- The chemical container(s) type, size, location and condition;
- The temperature, weather and changing conditions;
- Site hazards, such as uneven surfaces, confined spaces, electrical hazards and falling objects;
- The physical requirements of each response task and duration to complete them;
- Any engineering, administrative and work practice controls that will be in place;
- The relative risk (severity plus probability) for damage to people, property and/or the environment; and
- Available PPE and CPC (and their limitations), along with other resources.
Selecting levels of protection
Based on the hazard assessment, your next step is ensemble selection. This is complex, but the more you know about the hazards, the easier it becomes. OSHA and EPA suggest a starting point: a list of hazardous conditions under which each of the levels may be appropriate. These are described in Table 2.
Table 2: Ensemble-level selection quick start
|
Level: |
Used when: |
|
A |
· High concentration of identified airborne substance requires highest level of protection for skin, eyes and respiratory system; or · Atmosphere is less than 19.5% oxygen (level B also acceptable); or · Substance with high degree of hazard to skin is known/suspected to be present; or · Operation is in confined or poorly ventilated area; or · Operation involves high potential for splash, skin immersion or exposure to suspected skin hazards; or · Direct-reading instruments indicate high levels of unidentified, potentially hazardous vapors/gases in air; or · Direct-reading instruments are not available to test air, but highly toxic substances suspected to be present. |
|
B |
· High concentration of identified airborne substance requires high level of respiratory protection but allows lesser level of skin protection; or · Atmosphere is less than 19.5% oxygen; or · Unknown hazardous substance, but not suspected to: (1) contain high degree hazard to skin, (2) be capable of being absorbed through skin, nor (3) readily penetrate level B suit. |
|
C |
· No hazardous substances present that would negatively affect skin nor be absorbed by skin; and · Airborne hazardous substances, if any, are completely identified; and · Air contaminant concentrations do not exceed Immediately Dangerous to Life or Health (IDLH) levels; and · Contaminants can be removed by available air-purifying respirator; and · Atmosphere is not less than 19.5% oxygen; and · All criteria for use of air-purifying respirators are met. |
|
D |
· Air contains no known hazards above the permissible exposure limits after site characterization; and · Work precludes splashes, immersion, unexpected inhalation or contact with hazardous levels of substances. |
Table 2 sources:
29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.
OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.
Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.
EPA’s Personal Protective Equipment webpage within the agency’s Emergency Response homepage.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (DHHS publication no. 85-115).
Regardless of Tables 1 and 2 , it’s important to tailor your ensemble to your specific situation. Also, review the respirator selection requirements at 29 CFR 1910.134, Respiratory Protection, and the ensemble selection recommendations in Appendix B to 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response.
Performance factors
Imagine this scenario: You just entered a hot zone with your level A ensemble. Suddenly, chemical vapors begin to seep into your suit through the zipper. Your facepiece clouds over, then melts. You’re unable to proceed with the response. That kind of suit failure is an example of a “performance” issue.
An ensemble must provide an adequate level of protection. Yet, relying solely on the OSHA/EPA level criteria takes you only so far. You also need to consider performance factors related to:
- Permeation or chemicals moving through a material on a molecular level;
- Degradation or material changes, such as fading, swelling, loss of strength and deterioration;
- Penetration or chemicals leaking inwardly through zippers, seams or imperfections in material;
- Breathability or heat transfer of the material;
- Strength and durability of the material and components;
- Resistance to cuts, punctures, tears, abrasion, cracking, etc.;
- Functionality in extreme cold and heat;
- Flame-resistance of the material and components;
- Degree of dexterity, mobility and visibility for the wearer; and
- Slip-resistance of footwear.
The National Fire Protection Association (NFPA) publishes standards used by PPE/CPC manufacturers and others to test the performance of products. NFPA divides ensembles into several standards and classes, but Annex A to NFPA 1990-2022 offers a table that compares these standards and classes to the OSHA/EPA levels. Look for a label certifying that a product is compliant with NFPA’s performance criteria.
Upgrading/downgrading ensembles
Be aware that ensemble selection and re-selection is an ongoing process. You may decide to upgrade or downgrade the protection level because:
- Spill conditions change,
- You gain more insight about site hazards and conditions over time,
- A change in response tasks brings an increase or decrease in chemical exposure, or
- A worker simply requests an ensemble change.
Other factors to consider
Note that some factors might be considered prior to or during an ensemble purchase. These are listed in Table 3.
Table 3: Ensemble-purchasing factors
|
· Sizes and proper fit · Compatibility with site chemicals · Compatibility with other PPE · Compatibility with accessories (e.g., flashlight, two-way radio, personal monitor and dosimeter) |
· Time needed to put on/take off · Likely duration of use · Decontaminating/laundering difficulty · Reusability · Storage and other instructions · Inspection and maintenance |
· Repair and replacement options · Expiration or service life · Disposal options · Manufacturer disclaimers · Warranty and return policy · Cost |
Table 3 sources:
NFPA 1891-2022, Standard on Selection, Care and Maintenance of Hazardous Materials, CBRN, and Emergency Medical Operations Clothing and Equipment.
J. J. Keller® Compliance Network – Institute Safety & Health: HAZWOPER subject.
29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.
OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.
Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (DHHS publication no. 85-115).
Final thoughts
A PPE ensemble is your last line of defense against hazards presented during spill response. As such, its selection is critical and complex.
OSHA and EPA give you a simple method for selecting a PPE-CPC combination. However, you must base this determination on a complete hazard assessment of the spill situation. You must also consider performance and other factors. There’s no substitute for paying attention to changing conditions and news to help you select (and re-select) the right gear for the task at hand.