How should OH prepare for new respirator standard?
Question: I understand that the new standard for respirators will go into effect soon and requires a lot of changes in occupational health programs. How do we prepare for it?
Answer: The new standard for nonpowered, air-purifying respirator performance goes into effect July 10, 1998. After that date, employers may purchase only respirators that meet the new specifications. In the meantime, OH providers may need to revise existing protocol for testing respirators, training employees, and making purchasing decisions.
Occupational Health Management consulted with the federal Occupational Safety and Health Administration (OSHA) in Washington, DC; the National Institute on Occupational Safety and Health (NIOSH) in Cincinnati; and two manufacturers of respirators. They offer the following advice on how to prepare for complying with NIOSH 42 CFR Part 84.
The old standard applying to respirators was 30 CFR Part 11. The new NIOSH 42 CFR Part 84 went into effect on July 10, 1995, but it included a three-year grandfathering clause to allow employers and occupational health providers to comply. Respirators meeting the old standard still can be purchased and delivered through July 10, 1998. Most manufacturers also have started selling respirators compliant with the new standard.
Standard does not require new purchase
It is not necessary to purchase new respirators meeting the new NIOSH 42 CFR Part 84 standard until July 10, 1998, but manufacturers will urge you to go ahead and purchase the newer respirators. Some may not have remaining stock of older types of respirators available as the compliance date approaches. After July 10, 1998, manufacturers will not be allowed to sell respirators that only meet the old standard.
Respirators meeting the old standard may be used after July 10, 1998, and the employer will be in compliance. There is currently no cutoff date for using respirators approved under the old standard, but OSHA may declare them noncompliant at some point in the future.
Employers may have to change the type of respirators in use. This change can take place at any time, and it can be phased in over a length of time. Many of the currently used dust/mist/fume filters will not meet the new respirator standard. But even when complying with the new standard, employers may not have to change the entire respirator mask currently in use. Instead, the manufacturer will simply provide a different type of drop-in filter cartridge that complies with the new standard. However, you should expect an increase in the price.
Also, you should expect manufacturers to be busy filling orders as the July 98, deadline approaches. Customers may want to buy the old-style respirators at the last minute to delay changing the respirators they use, and others may want to buy the new respirators under the mistaken impression that they are the only type that will be compliant after that date. Either way, manufacturers may be swamped with orders.
New fit testing may be required if the change in respirators or filter cartridges has any effect on the face seal something to consider when selecting a product to comply with the new standard. If your supplier can provide new filter cartridges that fit the same face seals in use before, there is no need for fit testing beyond your routine testing.
The new standard creates three new series of particulate filters, designated as N, R, and P:
• N is designed for "no oil" use, so it may not be used in an atmosphere with oil particles, such as when oil is aerosolized during the lubrication of metal cutting equipment.
• R is "oil resistant," so it can be used with or without oil particles in the air. But when used in oil-containing atmospheres, an R filter may be used for only eight hours unless certain types of testing are used to show extended use is safe.
• The P filter is "oil proof." It can be used without restrictions, other than those normally associated with particulate filters.
Each of those filter types also has three levels of filter efficiency. That makes a total of nine filter designations from which to choose.
Respirators that comply with the new standard will carry the designation "84A" in the NIOSH approval number.
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