Braving the Challenge of CBRN
"They really are, in essence, changing the whole complexity of the PAPR, or the potential complexity."
- By Jerry Laws
- Nov 01, 2005
Editor's note: NIOSH's National Personal Protective Technology Laboratory continues to develop standards and test procedures for all classes of respirators that protect against chemical, biological, radiological, and nuclear (CBRN) agents. This project has included several public meetings and is being conducted with the U.S. Army Research, Development & Engineering Command and NIST, the National Institute for Standards and Technology. SCBA, APR, and escape hood standards have been completed; the agencies are working on the PAPR (powered air-purifying respirator) standard. Ken Bobetich, product group manager, Air-Purifying Respirators, for MSA Company (www.msanet.com) of Pittsburgh, discussed the project and the resulting standards in a Sept. 14, 2005, conversation with Occupational Health & Safety's editor. Excerpts from the conversation follow.
Ken Bobetich: There's a lot of confusion as to what CBRN is and means, and so I think it's important to get it out there in the public eye and get more people involved in the process.
At this stage, the manufacturers and the government are involved. Who else is?
Bobetich: I've been to pretty much all of the public meetings. There have been some representatives from the law enforcement community and there's occasionally some representation from the fire industry, unions. But generally, industrially, really very, very shallow sort of participation.
That's something we should talk about: how much the industrial community is interested in this or intends to use these.
Bobetich: The original scope of this was to start out with breathing apparatus, because that affected the most responders the most quickly, move into air-purifying respirators, then into escape hoods and PAPRs. And then look at combination-type devices. There are situations where a user of a breathing apparatus might also benefit by being able to change over to an APR or a PAPR device.
Do those combination devices exist?
Bobetich: They don't exist right now.
But the idea was the manufacturers would come up with them, and then they could be certified?
Bobetich: Yes. The expectation was that, through the full concept development process that they go through, you might be able to identify what the requirements and performance elements would be in order to gain approval.
How involved have your company and other respirator manufacturers been in developing these CBRN standards?
Bobetich: Being in Pittsburgh and having NIOSH's lab here has certainly allowed us to be very involved. We got the first NFPA 2002 CBRN breathing apparatus approval; we got the first APR approval--actually, the first and the third APR approval. . . . The way NIOSH has gone through this process, they actually had a basic concept. And that basic concept is, they have, within the jurisdiction of NIOSH, to take existing standards and add additional tests to form new classes or categories of devices. So in the case of the breathing apparatus, they took requirements from NFPA and the NIOSH 42 CFR approvals and added some additional live agent tests and fit tests and other things.
To the air-purifying system, they broke out of the original concept of organic vapors, or acid gases, or ammonia, or chlorine, and identified roughly 150 chemicals that would be potentially representative of the kinds of threats that might be out there. The thought is that you're probably more likely to have a terrorist put a pipe bomb on a chlorine truck than brew up a batch of sarin.
That makes sense.
Bobetich: They looked at what kinds of chemicals are out there in high volume in society, and on that basis came up with that list of 151. And from that list, they identified 10 TRAs--test representative agents. These were kind of the worst actors in each of the categories. And then set out the test protocols to test against those 10. Those 10 have pretty much remained the same for the air purifying, the escape hood, and the PAPR.
So really, the basic premise of these standards' development is take existing NIOSH standards, look at the prospective threats and the nature of the work the responder might encounter, and come up with a way of testing devices against those higher challenge concentrations in order to be able to provide a basis of performance.
The fact that NIOSH did not tackle PAPRs when they redid their standard a few years ago makes it difficult now to do what they're trying to do with CBRN?
Bobetich: What's difficult with PAPR is, the standard is 20 years old. There are a number of situations in the industrial workplace that people could use PAPRs, but because of the heightened test requirements of the old standards, it becomes somewhat prohibitive.
Because units have to be bulky in order to have the filters they need to pass the tests. They have to have bigger batteries on because of the run times that are required to pass the test. There are instances in the work environment where people would benefit from having the additional comfort and protection of a PAPR, but because of the in some places onerous requirements to meet the performance requirements, the filters wouldn't nearly get used up during the course of a shift.
One of the hopes and expectations of I think all communities is that as this PAPR standard is done, you can maybe take a lead from Europe, where they actually have classes of devices. So if you have a low-toxicity environment, you should be able to use a low-capacity filter and not throw away something that would last for three days--but you can't [currently] because of a changeout schedule.
The European setup is not CBRN-related?
Bobetich: The problem with CBRN is, if you take the CBRN requirements and add the current requirements that are proposed, what you end up with is an even more elaborate device. Now, you've established a new class of device, and you have to try to back into a lower-class device, which really is more difficult because if you're going to update a standard, it's supposed to be done through rulemaking. And if you're establishing these other classes of device outside of rulemaking and then you go to the rulemaking process and you already have these requirements out there and approved, as part of standards, you can't ignore them when you build the new standard.
A number of people have been on this same page and said, "Let's step back from this and build a new PAPR standard. And then, within that PAPR standard, add the provisions for emergency responders and high-toxicity environments." Instead of doing that first and then trying to back into something that might be more appropriate for a less-toxic world.
Is that in fact what is happening?
Bobetich: That's one of the proposals, and that's why there has been a delay in being able to work through this standard. . . . NIOSH is working through this and trying to determine if there is a more efficient way of getting a standard for users--responders--while at the same time reviewing the PAPR standard so it really is a new world-class standard for powered air-purifying respirators.
Solving this won't be easy, and it might take some time.
Bobetich: The rulemaking is going to take you two years. In the meantime, the responder community sits without anything. That's not acceptable to the responder community. At the same time, establishing a whole new class of device outside of rulemaking is problematic because it sets precedents for the next 20 years, and it probably makes the PAPR that the average user would use much more of an inappropriate device for their particular application. To have to seal a PAPR to protect against sarin, I've got to approach it differently than I do if I have to keep out silica dust.
That's a very tough nut to crack, but necessary to do. Has the project as a whole proceeded as you expected? Did you anticipate this particular problem would arise?
Bobetich: In the case of PAPR, I think we did, or at least the manufacturers' community was well aware. Because, if you look at what's out in the market, there aren't that many new devices that have been introduced in this category in the last five years. They really are, in essence, changing the whole complexity of the PAPR, or the potential complexity.
Everybody was aware this was being worked on and therefore wanted to wait, to see what NIOSH would come up with?
Bobetich: You have to. . . . Most certification testing is a capacity test. It doesn't in any way represent what a user is going to see. In the case of CBRN, they have ratings of Cap 1, Cap 2, and Cap 3. Capacity 1 is tested at these test representative agents for 15 minutes.
Now, the user might say, 'Gee, you're only testing it for 15 minutes; I need it for hours.' But the concentrations are better than three times the IDLH, which are concentrations that users have no business being able to use it in. So what they're really testing is the capacity of the filter to filter, as opposed to the duration of a device to protect against a given substance.
In some cases, you come up with a theoretical number to do the capacity testing that is an 8-pound filter. There's a 500-gram limit. Guess what? You can't do that.
I'm laughing, but it can't be funny to have to work this way.
Bobetich: The old way of rulemaking had its benefits in that you got a standard; now you knew what to shoot at. And it's probably cheaper that way.
Yes. But you also had input into the standards even in that old way of rulemaking.
Bobetich: You have a comment period.
Exactly. And they want to consult with the manufacturers and the other communities before they put one out. So you'd have opportunities to say this is feasible, this is not, or this is advisable, this is not.
Bobetich: When a concept paper comes out three or four times and you have to retest based on those concepts each time, it ends up being a fairly elaborate process.
What level of investment or commitment does all of this represent for your company and for other manufacturers?
Bobetich: If you're going to be in this, you've gotta be in it. It's not something you do casually. Because it's full-time engineering, the chem labs, material sciences people, manufacturing, operations, industrial engineering. It's what do you need to make, how can you make it, where's it going to be made, can we make it repeatedly, what's our quality test plan? It's a fairly elaborate process.
From when a standard comes into life to when a first product comes out the other end has been as long as two years.
That's an awful lot of development and cost before anything can be sold.
And these standards have been going along simultaneously?
Bobetich: They've been sequential . . . but there has been an overlap.
Does everybody who makes respiratory protection have the capability to be in the game?
Bobetich: There are only six or seven APR devices that have been approved so far. Pretty much all the manufacturers have managed the breathing apparatus. It's a pretty specialized skill.
MSA's benefited. We've been in this for a very long time. We've made military masks since World War I, and so there's a certain expertise you have that translates fairly well to this.
Aren't we creating both a very expensive process for the manufacturers to come up to and a set of standards and test methods to which, in some cases, no products will be certified? What's the true accomplishment of all this?
Bobetich: Back in the early '90s, there was a program called CSEPP, developed by the Department of Defense to work on demilitarization of chemical weapons. And because there weren't any standards available for mustard, or sarin, or the other chemicals, manufacturers ended up going out and getting third-party testing done on their devices. What became very confusing is, MSA might decide to test at a given level and a given duration; somebody else might decide to test at another level and another duration. There was no uniformity at all as to how those tests were done. And there wasn't a NIOSH protocol--other than in the case of gas masks, CS or CN, which police officers, law enforcement, was using.
I think the benefit is, the CBRN standards have at least established the goalposts and the size of the field. Here are the requirements, here are the test protocols, here's the concentrations. If you get an approval, your device has to at least have achieved this level of performance. So I think that's a benefit.
And the benefits to the users?
Bobetich: There's the reassurance that somebody, other than some yet-to-be-named test lab, has done the testing. Third-party testing is meaningful if the third party is neutral.
All of these do incorporate some element of third-party testing?
Bobetich: All of the CBRN standards testing is done at NIOSH. You're using a consistent ruler.
What do responders tell you about these? How interested are they, and how interested are the industrial users?
Bobetich: Responders welcome the fact that there is a protocol against which these are tested. If you look at the early days, there wasn't that consistency, and the user didn't know for sure what a claim meant. . . .
Secondly, it has established a new, higher-level class and performance of device. When you're talking about responding to yet-to-be-determined events, and not really in all cases having the wherewithal to determine what those levels are, it's important to know that a very rigorous test plan has been set out and the devices meet that.
Isn't it true SCBAs are what the responder community wants to use, and therefore having such a wide selection of certified ones is very good for them?
How about for the industrial side?
Bobetich: Industrially, I don't think people have really considered it to any great extent. You have certain categories--nuclear and utilities have looked at what an event might be, how it might affect them, or how they might need to respond. And maybe have their security people set up with these kinds of devices. But it really hasn't affected the industrial user, per se.
They're waiting, if they even know about this, to see what comes out at the end. To know what they either have available or can afford. So how do CBRN-certified respirators differ from regular respirators in terms of cost?
Bobetich: You're typically not able to use thermoplastic that you might use in other facepieces. You're typically using a butyl, or a neoprene, or a higher class of elastomer. From that standpoint, it's a bit more costly a facepiece than an industrial facepiece. And I guess rightfully so: It's supposed to do more than an industrial facepiece can do. . . .
I expected they'd be significantly more expensive simply because there's a lot of development cost that has to be recovered somewhere.
Bobetich: There is a lot of development cost, but the market doesn't necessarily allow you to recover it very fast.
Well, all of the other players are in the same boat.
Bobetich: It's what we do. It's what the safety industry has done.
Does the responder community have the funding to buy these more capable units? Are they keenly interested in doing so?
Bobetich: Over the last couple of years, the dollars have been flowing fairly strong to the responder community through FIRE Act and also Homeland Security funding. FIRE Act funding has been cut back the last couple of years. Homeland Security funding--it seems since [Secretary Michael] Chertoff came in, they've been a little tighter with the dollars. And it's probably like that in any administration change, where they just want to see where it's going.
He made it plain when he came in that funding would be much more risk-based than blanketed all over, which might be helpful if you're a manufacturer trying to sell to a community. It did surprise me that so few APRs have been certified to date.
Bobetich: It's not an easy standard.
Exactly right. And few escape respirators so far?
Bobetich: There has been one manufacturer, at least, that has passed all the NIOSH testing requirements for the escape, and they're waiting for their approval letter.
It's not an easy standard. And also the problem you face is, NPPTL was getting up and running. They moved up from Morgantown into Pittsburgh. There was a little lag time there; they had some new people. The agent testing is done at RDECOM. Being a government facility and having other government priorities, you stand in a queue there.
Something as simple as getting fit testing done: The fit test panel is fairly elaborate for all of these. Just finding the right size people and enough of them to do the testing: All of those things.
I started to say we're fortunate we haven't had a lot of incidents where we needed these devices. But you've already explained they will be useful for very toxic environments, as well.
Bobetich: Yes. The thing I think that's important is, there really is not a clear understanding in the community--whether government, or manufacturer, or union--of what a CBRN device is approved for. If you had an old, chin-style gas mask, it would be approved against half-percent organic vapors, and you might go down the list: ammonia, chlorine, and so forth.
These devices have been tested against very high levels, in most cases three times the IDLH. And yet, they don't carry a specific approval other than CBRN.
So there's a debate: Wow, these should be kept on the shelf, waiting for that event to happen. And the other side is saying, Wait a minute, a tractor-trailer that overturns on the highway is a chemical event. Right now, New Orleans is a biological, chemical event.
It doesn't take a terrorist to generate these things. There are events that happen all the time to responders that would require them to use these devices.
Again, what is the next step beyond PAPR?
Bobetich: Those would be the combination devices. Actually, there is a self-contained, closed-circuit device approval that's kind of working its way through the system. That would be devices designed for extended rescue, tunnel sorts of situations, where you might have to be in the device for three or four hours.
Please explain the combination devices.
Bobetich: The concept is, you're a firefighter. You have to go through a toxic environment that is mildly toxic, by degree, to get to the true nature of the hazard. So the ability to use a powered device to purify the air in that environment, and then switch over to a positive-pressure SCBA, would allow you to work in that environment for a longer time off of the cylinder and then leave that environment, possibly, under the PAPR and go through decon on the PAPR. You'd have a longer timeframe.
That's an interesting concept. Would the user manually make the switch and have to determine what the atmosphere was?
Bobetich: That's to be determined.
Would such devices also be considered by industrial users? They always want, I think, the most capable device they can afford and need for a given situation.
Bobetich: I think that's still to be determined.
Did responders ask for it?
Bobetich: I think the RAND report said there are periods of time when a responder would need respiratory protection but wouldn't need the highest class, and current devices don't provide that.
As far as you can tell, MSA and other manufacturers are interested in creating such devices?
Bobetich: If the market's interested in 'em. . . . It's investment--time and money. All of this has gotta be framed in the business world: If you build it, will indeed they come?
To sum up, ultimately this has been a worthwhile, fairly expensive, and intensive process that's going to be in the end very valuable to responders and probably very valuable to industrial users. Is that right?
Bobetich: I think so. I think it stretches technology. And any time that happens, the higher-class device gets better and the lower-class device gets better. There are things that all of us can take from these developments that we can apply to the product line and make improvements, with benefits across the range.
The thing that really is important for the industrial user is, they are the potential bomb. You're sitting there with tank cars on the side rail beside your plant, or you have a giant tank farm with chemicals on your facility. Those are fairly tempting targets. Probably easy to get to.
Is there a point soon when we'll know which way the PAPR standard will go?
Bobetich: Yes. There's supposedly a public meeting that will be announced in the November-December timeframe, where NIOSH will announce the next concept for PAPR.
This article appeared in the November 2005 issue of Occupational Health & Safety.
This article originally appeared in the November 2005 issue of Occupational Health & Safety.