NIOSH Mulls SCBA Alarm Change, Air-Fed Suit Respirator Standard
Users and manufacturers of protective respirators will be interested in two comment requests from NIOSH that may lead to a change in how SCBAs alarm to signal only 20-25 percent of rated service time remains, as well as a possible change in the fundamental 42 CFR Part 84 standard. NIOSH's notice for the latter said the agency may add a new subpart to the standard for air-fed suits where the suit acts as the respirator; it could be a positive-pressure-inflated suit or a suit encompassing a supplied-air respirator or air-purifying respirator.
An SCBA End of Service Time Indicator (EOSTI) must alarm within the 20-25 percent range. The potential change results from a petition that asked NIOSH to eliminate the upper limit of the range and "allow each respiratory protection program manager to determine the most appropriate alarm setting, with 20 percent as the retained minimum, to provide SCBA users time to exit a scene," according to the notice posted by the head of NIOSH's National Personal Protective Technology Laboratory.
The notice says NIOSH has received several suggestions to change the EOSTI requirement. NIOSH provides this online comment form and asked for this feedback in comments submitted no later than 5 p.m. Eastern on Jan. 16, 2009:
1. Opinions on the current EOSTI performance requirement.
2. Opinions on modifying the current EOSTI performance requirement from a range to a minimum value.
a. Should NIOSH continue to interpret the provision to require the alarm to continue uninterrupted until the minimum value (20 percent) is reached?
b. If the petitioned change is adopted, what tolerance should NIOSH use to evaluate acceptable EOSTI performance at a specified setting rather than within a range?
c. If the petitioned change is adopted, should NIOSH evaluate EOSTI performance at settings other than the 20 percent minimum? If so, at what additional values?
d. Is there a rationale to distinguish Fire Service SCBA from those used for industrial applications for the evaluation of the EOSTI?
3. Identification of alternative approaches to address EOSTI performance.
4. Other comments on the subject.
Electronic comments should be formatted as Microsoft Word and reference docket number NIOSH-034-A.
The air-fed suit material includes a draft development plan that explains how this concept dovetails with the current work on a standard containing design and performance criteria for air-fed protective ensembles. ASTM Committee F23 on Protective Clothing's Subcommittee on Chemical Hazards (F23.30) is developing this standard, and NIOSH is participating in that work, according to the NIOSH notice. The reason for possibly adding such a subpsrt to 42 CFR Part 84 is to "be more responsive to future technological evolutions in the workplace that may impact the use of these suits," the plan states. The plan is available as a link from the notice, which seeks comments (referencing docket number NIOSH-148) by 5 p.m. Eastern Jan. 15, 2009.