Combination Unit Rulemaking Planned

A NIOSH regulation for CBRN combination unit respirators is coming in FY2012 and is being timed to coincide with the 2013 edition of NFPA 1981.

• By Jerry Laws
• Feb 01, 2011

Could there be a faster way to enact changes in the standard by which the National Institute for Occupational Safety and Health certifies protective respirators? NIOSH conducted a stakeholder meeting Dec. 9 in Pittsburgh, Pa., that offered some ideas, such as considering ISO and NFPA consensus standards and also using this type of meeting to get stakeholders' feedback earlier in the rulemaking process.

The meeting, offered as a live webcast and reported throughout the day on the National Personal Protective Equipment Technology Laboratory's Twitter site, covered three main topics:

• updating the standard (42 CFR Part 84) to improve respirators' performance and reliability
• work on a standard for CBRN (chemical, biological, radiological, and nuclear) combination unit respirators for emergency responders, which would mean any combination of an air-purifying and an air-supplied respirator
• work on a standard for buddy breathing with a self-contained breathing apparatus

"We're going to try to use material out of other standards . . . as to how we evaluate respirator performance, in particular for the use of work rates," the lab's Jon Szalajda said as he previewed FY2011 rulemaking plans. Szalajda, who is NPPTL Policy and Standards Development Branch chief, also said NPPTL's fees will be raised in FY2011 and reaffirmed that NIOSH will raise the required end of service time indicator (EOSTI) activation level to 33 percent of open-circuit SCBA cylinder capacity. Currently, section 84.83 of Part 84 requires indicators to give an alarm when 20-25 percent of capacity is reached.

Szalajda's presentation included a timeline of respiratory standards development that shows a powered air-purifying respirator/supplied air respirator proposed rule, a rule to change the fees, and the EOSTI proposed rule all will be issued in spring 2011.

The timeline includes a proposed rule scheduled for the FY2012 that would specify performance parameters for CBRN combination respirator units. "I think this is the next generation of respiratory protection -- the use of respirators that can work in multiple modes," Szalajda said. "Historically, when you look at what we've done in the past 10 or 20 years, we've looked at technologies where we have improved the capabilities of respirators as currently certified in Part 84. We've done things to make them rugged, to enhance human performance. But we haven't come up with a new technology. . . . I think the combination unit is a step in the evolution of respiratory protection.

"I'm considering this to be a blank slate," he continued. "We're going to use part 84 and any other national or international standard that's appropriate to identify the performance requirements for the protection that needs to be addressed with this type of respirator."

Szalajda said dockable systems that receive air from a supplied air line might be feasible, and he asked whether it would be possible to develop an industrial respirator that protects against multiple hazards, similar to current CBRN respirators.

Combination Units' Benefits
Combination units already exist, including one with three separate NIOSH approvals, and NIOSH held a meeting about them in October 2006 and opened a docket about them. Jon Nelson, regional sales manager, West North America for Avon Protection Systems, spoke during the Dec. 9 meeting about multiple-function PAPR and SCBA units that were developed for the military and for law enforcement units concerned with potential terrorism.

The company developed a mask that operates in five modes: APR, SCBA, PAPR, closed circuit breathing apparatus, and hybrid SCBA/PAPR combination. Its ST53 respiratory system is for military and law enforcement markets; Nelson said after the meeting that he sees NIOSH's plans as an "excellent opportunity" for its products. He said NIOSH wants its rule changes to be completed at the same time the NFPA 1981 standard is updated in 2013; NFPA 1981-2007 is the key consensus performance and certification standard for firefighting respiratory protection, both SCBAs and combination SCBA/supplied air respirator units.

The current FEMA Authorized Equipment List (https://www.rkb.us/mel.cfm?subtypeid=549) allows grantees to purchase combination respirators, as long as they are certified by NIOSH to Part 84. Thus, it's important to Avon Protection Systems that NIOSH begin certifying products for multi-functional, combination use as planned.

The military combination units were created to meet the needs of U.S. forces deployed in Iraq and Afghanistan who required multiple modes of operation from respirators that could be used for longer periods than industrial respirators permit. Service members needed to be able to select whatever mode was required for the operation involved and to combine when necessary.

Nelson said the benefits of a combination unit included these:

• It gave the U.S. Department of Defense the ability to change on the move and allowed operational flexibility.
• If service members knew biological agents were the threat, they were prepared for that. If IDLH environments were expected, they also were prepared for them.
• The unit minimized training time.
• It uses proven and operational technology.

Recognizing combination units as single respirators in the regulation would mean each of their functions would not need its own approval -- the entire unit would get a single approval. Representatives of respirator manufacturers attending the meeting pointed out the advantage of having one mask and/or system for every mission, but one said allowing for dynamic manual changing of protective modes would introduce the possibility of user error. Another question is how users would know the contaminant concentrations around them, which may fluctuate. At a minimum, an oxygen sensor capability might have to be included.

One representative suggested separate approvals should continue for each essential component of a respirator. Another noted many responder agencies rely on a U.S. Department of Homeland Security (DHS) grant program to obtain their PPE, but combination breathing apparatus work has stalled within DHS because no standard for such respirators yet exists. There are differences of opinion within FEMA about it; this representative said end users must stand up and say they want it, if they indeed do.

Szalajda asked attendees and those listening live to the meeting to help NIOSH understand the operational characteristics needed by end users. The lab staffers will translate those into the performance requirements for which NIOSH will test during the certification process. He said the lab plans to conduct a public meeting in mid-2011 to discuss other respiratory topics.

He said it's possible NIOSH may base its respiratory regulations on the performance needed by specific industry sectors: health care and public service, for example. In this scenario, there would be no "one-stop shop" regulation; the agency would tailor its standards for the use of particular sectors.

Rulemaking information is available at http://www.cdc.gov/niosh/review/public/. Three dockets are open with comment periods for the work now under way:

• NIOSH-221, regulatory agenda for updating 42 CFR Part 84, comments due by 5 p.m. EDT March 31, 2011
• NIOSH-082A, CBRN combination respirator unit, comments due by 5 p.m. EDT Feb. 12, 2011
• NIOSH-147, Reevaluation of NIOSH policy on emergency escape support breathing system ("buddy-breather") device used with open-circuit self-contained breathing apparatus, comments due by 5 p.m. EDT Jan. 30. 2011

HSE Targets Respiratory Hazards in Major Sectors
During 2010, Britain's Health and Safety Executive sought to raise awareness of respiratory diseases in several large industry sectors and to increase protections of workers at risk in those industries.

In a Dec. 15, 2010, briefing delivered to the HSE executive board, agency staffers said an estimated 12,000 deaths per year result from exposure to hazardous substances at work. They also said 90,000 construction workers are exposed to silica and other substances on the job, with 8,000 illnesses and more than 600 deaths resulting from this exposure annually. Other employee groups of concern are foundry workers (an estimated 22,500 exposed to nickel compounds, silica, and other substances), welders (79,000 exposed to welding fume), quarry workers (35,000 potentially exposed to silica), stone masons (8,000 potentially exposed to silica above the Workplace Exposure Limit), and building maintenance workers (1.8 million workers overall, with at least 500,000 commercial buildings containing asbestos.)

The HSE efforts include conducting a survey of workers about respiratory risks, creation of training packages to be shown to workers in these industries as they're being hired, increased training to make HSE inspectors more aware of employers' duty to control airborne exposures through local exhaust ventilation or respiratory protection, updating HSE's guidance on medical surveillance of respiratory illness, and establishing partnership teams with influential individuals and businesses in each targeted industry.

An initiative by HSE's Construction Division to address the dangers of respirable crystalline silica in concrete cutting caused a major equipment manufacturer to launch a new cut-off saw for cutting stone and concrete that features a novel electronic control system to optimize water supply for dust suppression, according to HSE. The division also is developing a set of risk management standards in partnership with Constructing Better Health (the national scheme for occupational health in the construction industry) and conducting research to identify the specific construction tasks that produce the highest respiratory risks.

This article originally appeared in the February 2011 issue of Occupational Health & Safety.