These regulations will potentially have a very large impact on small and mid-sized employers.

Page 4 of 4

What's Ahead for Respiratory Protection in 2018?

2017 turned out to be a quite a year as respiratory safety needs came into the spotlight in multiple ways. A myriad of natural disasters across the United States brought a renewed focus on safety and health concerns for first responders, workers, and citizens alike. The OSHA silica standard went into effect, welding fumes were classified by the World Health Organization as a Group 1 carcinogen, and respiratory technology took another step forward.

So, what is ahead for 2018? It appears likely that the focus for respiratory protection in 2018 will revolve around two key areas:

1. The implementation and adoption of the OSHA silica standard

2. The growing awareness of the respiratory risks associated with welding fumes and the growing adoption of respiratory safety with welders and welding organizations

Let's take a look at each of these two areas in more detail and what we can expect in 2018.

OSHA's Silica Standard: What's Next in 2018?
On March 25, 2016, OSHA published a long-awaited respirable crystalline silica standard. OSHA claims the standard will affect 2 million construction workers who drill, cut, crush, or grind silica-containing materials, such as concrete and stone, and 300,000 workers in general industry operations, such as brick manufacturing, foundries, and hydraulic fracturing. That's a lot of workers who previously just wore an N95 dust mask, if they wore any type of protection at all.

At the safety industry trade shows my company attended in 2017, we constantly received a chorus of comments and concerns from employers visiting our booth related to the practicality of compliance, exactly what they need to do to achieve compliance, and how they would actually implement the standards in their particular industry.

Another common question we receive is whether workers need a PAPR APF 50 respirator like we manufacture, or can they get by with a disposable N95 or half mask—an APF 10 mask. The answer to this question is, "it depends." With some jobs, such as using hand-held grinders for mortar removal, a protection level of APF 25 is required to meet the new regulations, while with other jobs an APF 10 mask may be sufficient.

On the plus side, while we have seen delays in enforcement and some confusion over PPE and compliance, we have also seen sincere interest from employers in complying and helping workers become better protected going into 2018. In addition, according to OSHA, the new regulations should save 600 lives and prevent up to 900 new cases of silicosis each year.

Now let's take a look at a few more details and what impact the new standards will have in 2018.

The OSHA standards took effect on June 23, 2016 with a one-year compliance period before enforcement being in place for some industries. However, there was a stay/delay until Sept. 23, 2017, and the latest OSHA Interim Enforcement Guidance for Regional Administrators is dated Oct. 19, 2017.

Most recently, according to the National Law Review, on Dec. 22, 2017, the U.S. Court of Appeals for the D.C. Circuit dismissed all industry legal challenges against the new silica dust exposure standard implemented by OSHA, so at this point it appears to be "game on" for the OSHA regulations.

The specific compliance deadlines by industry are outlined below. The bottom line is that all industries are expected to be in compliance by the middle of 2018.

 Industry  Deadline for Compliance
 Construction  June 23, 2017, one year after the effective date
 General Industry and Maritime
 June 23, 2018, two years after the effective date
 Hydraulic Fracturing
 June 23, 2018, two years after the effective date

OK, so what does it mean to be in compliance? This is where it gets a bit more complicated.

Regardless of which exposure control method is used, all employers covered by the standard are required to:

  • Establish and implement a written exposure control plan that identifies tasks that involve exposure and methods used to protect workers, including procedures to restrict access to work areas where high exposures may occur
  • Designate a competent person to implement the written exposure control plan
  • Restrict housekeeping practices that expose workers to silica where feasible alternatives are available
  • Offer medical exams, including chest X-rays and lung function tests, every three years for workers who are required by the standard to wear a respirator for 30 or more days per year
  • Train workers on work operations that result in silica exposure and ways to limit exposure
  • Keep records of exposure measurements, objective data, and medical exams

These regulations will potentially have a very large impact on small and mid-sized employers. Many employers currently have some sort of safety program in place, but few if any have a program (or the budget) that includes medical exams, written programs, etc. With more than 2,000,000 American workers impacted by this regulation, safety and industrial hygiene professionals are certain to have their plates full in 2018 helping companies comply.

Respiratory Protection for Welding Fumes Takes Center Stage
In April 2017, the International Agency for Research on Cancer (IARC) classified both welding fumes and UV radiation from welding as a Group 1 carcinogen, the agency's designation for agents that carry sufficient evidence of carcinogenicity in humans. The IARC is the specialized cancer agency of the World Health Organization.

According to the IARC, the new classification for welding fumes is based on "substantial new evidence" from observational and experimental studies (UV radiation from welding was previously classified as a Group 1 carcinogen in 2012). In addition, they stated that up to 1 percent of the world's workforce may be exposed to welding fumes while on the job. The study also noted that certain workers were more likely to develop cancer, depending on the chemicals and fumes to which they were exposed. The health consequences of welding fumes and gas exposure include damage to workers' lungs, kidneys, and even their nervous systems.

Sounds pretty serious, doesn't it? However, even though this classification occurred last April, there has been very little fanfare about the reclassification and, to date, OSHA has taken no steps since then to introduce new research, studies, or rulemaking related to welding fumes as they have done with silica.

That said, over the last few months we have seen significantly increased concern and interest from welders and welding organizations related to respiratory protection. In particular, we are seeing a strong demand for PAPR respiratory solutions that can provide a high-efficiency (HEPA P100) particulate filter to protect against mechanically and thermally generated particles and that are light, comfortable, and compact and easily fit under existing welding hoods and grinding visors. This demand for PAPR solutions mainly stems from the fact that disposable masks do not provide the necessary protection levels when working around welding fumes, can often restrict breathing, do not respond well to heat or hot environments, and can frequently force a welder to stop work to cool down or get a breath of fresh air.

Looking forward in 2018, we expect to see the awareness of the IARC welding fume reclassification to continue to grow and more welders looking to utilize respiratory protection on the job. We also expect at least to see discussions and receive some announcements and guidance from OSHA on regulations related to worker respiratory protection when welding or working around welding fumes. Finally, we expect that welders and welding organizations will continue to require and expect respiratory and PAPR solutions that are highly mobile and not restrictive to utilize.

Looking Ahead—2018 and Beyond
So there we have it: Two big issues in 2018 that will impact millions of additional American workers and employers. The good news is that PPE technology and specifically respiratory protection technology are keeping pace to help companies comply and workers stay safe. It is critical that respiratory protection vendors continue to bring to market new, cost-effective solutions that fit the worker’s job and needs and not just attempt to shoehorn old technology to new standards and worker requirements.

Looking beyond 2018, what else is coming? Connected workers? Internet of Things interoperability between respiratory protection and other PPE products? We will likely see some interesting technology and solutions come to market over the next 12 to 24 months. For now, however, the industry will be focused on the implementation of the silica standard and understanding how to protect workers from harmful welding fumes.

Have a wonderful 2018, and we'll check back later in the year to see how things are progressing with the implementation of the silica standards across the various industries and the adoption and visibility of respiratory protection in the welding industry.

This article originally appeared in the February 2018 issue of Occupational Health & Safety.

About the Author

Ken Henry is Director of Sales-Americas for CleanSpace Respirators Australia Pty Ltd. He has an educational, technical, and professional background in industrial hygiene and safety and health, having worked as a CIH and corporate safety director. He also has been involved in the safety products marketplace for more than 30 years, with more than half of his career involved in the product development, sales, and marketing of respiratory protection equipment. Distributing its products worldwide, CleanSpace Respirators has developed revolutionary and game-changing solutions in PAPR respiratory protection.

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