KTA-TATOR,
INC.
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Pittsburgh, PA 15275
Phone: 412.788.1300
Fax: 412.788.1306
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Proposed by OSHA
By Stan Liang
KTA-Tator, Inc.
In an effort to prevent thousands of injuries and illnesses and hundreds of deaths annually from chronic diseases such as cancer, the Occupational Safety and Health Administration (OSHA) has proposed a new rule to strengthen worker protections from respiratory hazards in the workplace.
Currently seeking comments on the proposed rules, OSHA's amendment to the Respiratory Protection Standard would primarily affect how assigned protection factors (APF) are enforced. New APFs would function as part of a complete respiratory protection program to assist workers and employers in proper respirator selection. APFs indicate the workplace level of respiratory protection that respirators are expected to provide to employees. The new proposal contains an amendment to replace the existing APF requirements in OSHA's substance-specific standards as well as preliminary decisions on an APF Table, and updated definitions for APFs and Maximum Use Concentrations.
OSHA Administrator John Henshaw said, "It's critical that workers and employers select respirators that will protect users against over-exposures and adverse health effects. These proposed additions will assist employers and employees in fit testing respirators and properly selecting respirators based on the conditions in their workplaces."
For more information on the outcome of OSHA's proposal to revise the Respiratory Protection Standards, visit www.osha.gov.
What Do Revised APFs Mean to Industrial Painting Contractors?
The revisions to the Respiratory Protection Standard regulating assigned protection factors (APF) for respiratory protection will clarify OSHA's requirements. Currently, respirator APFs vary significantly depending on what standard is being enforced. For example, the OSHA Lead in Construction Standard and the Cadmium Standard assign an APF of 25 to Type CE abrasive blasting respirators (e.g., loose-fitting helmet/hood). However, when using the same respirator for arsenic exposures, the APF becomes 2,000.
In addition to clarifying respirator APFs, OSHA is also imposing new requirements that affect how the APF of a respirator is determined.
Specific changes in the proposed revision that will have the greatest impact include the following:
- OSHA will replace respirator APF tables now enforced in various standards (e.g., lead, asbestos, cadmium, arsenic, etc.) with a single APF table. For hazards not specifically regulated (e.g., silica), this table would also apply. Currently, OSHA, in its compliance directive for the Respiratory Protection Standard, directs compliance officers to enforce protection factors for hazards such as silica in the NIOSH publication Respirator Decision Logic.
- The APF of the Type CE respirator will become 1,000, regardless whether the dust contains lead, arsenic, or cadmium. However, the protection factor only applies to Type CE respirators that can maintain positive pressure inside the helmet/hood. If it cannot maintain positive pressure, the APF drops to 25.
- The APF of the powered air-purifying respirator increases to 1,000 for tight-fitting, full-face respirators and helmets/hoods. As with the Type CE respirator, helmet/hood respirators must maintain positive pressure or the APF drops to 25.
- The maximum use concentration (MUC) is formally defined "… as the maximum atmospheric concentration of a hazardous substance for which an employee can expect to be protected when wearing a respirator… The MUC usually can be determined by multiplying the assigned protection factor by the permissible exposure limit (PEL), ceiling limit, peak limit or any other exposure limit used for the hazardous substance." Employers must comply with the MUC recommended by the manufacturer, if it is lower than the MUC obtained by multiplying the OSHA APF by the exposure limit (e.g., PEL).
These changes will change how employers use respirators to protect their workers. For example, the increase in the APF for powered air-purifying respirators (for tight-fitting, full-face respirators and hoods/helmets) may permit its use for abrasive blasting of lead-based paints. A single APR Table will govern the selection of respirators, which simplifies compliance with OSHA. However, employers may have to ensure that the manufacturers do not recommend a lower MUC than OSHA before selecting respiratory protection.
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