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EPA Guidance for Determining Organic Vapor Cartridge Service Life for NIOSH-Approved Respirators

EPA Guidance for Determining Organic Vapor Cartridge Service Life for NIOSH-Approved Respirators. Anjali Lamba, MPH, CIH Chemical Engineering Branch Office of Pollution Prevention and Toxics Environmental Protection Agency Gerry O. Wood, PhD Gerry Odell Consulting. Need for Guidance.

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EPA Guidance for Determining Organic Vapor Cartridge Service Life for NIOSH-Approved Respirators

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  1. EPA Guidance for Determining Organic Vapor Cartridge Service Life for NIOSH-Approved Respirators Anjali Lamba, MPH, CIH Chemical Engineering Branch Office of Pollution Prevention and Toxics Environmental Protection Agency Gerry O. Wood, PhD Gerry Odell Consulting

  2. Need for Guidance • Toxic Substances Control Act (TSCA) of 1976 • New Chemicals – Pre-Manufacture Notice • Testing of Cartridges • Use of APRs with Cartridges • Change-Out Schedule Requirement • Specific submitter case - identified need for recommendations update AIHCe 2014

  3. History of Guidance • Minor Revisions by EPA ,1995 and 2002. • Included on OSHA website, 1998. AIHCe 2014

  4. Limitations of Previous Guidance • Only Single Vapor Considered • At Least 36 Tests Specified • Not Included/Considered: • Recent Data and Test Procedures • Recent Understanding of Reactive Vapor Removal Mechanisms • Usefulness of Recent Service Life Estimation Models AIHCe 2014

  5. New Guidance Document AIHCe 2014

  6. Companion Evaluation Document AIHCe 2014

  7. New EPA Guidance DocumentSummary Outline - 1 • Background and Preliminary Considerations • Laboratory Testing for General Qualification • Definition of General Qualification (for no specific application) • Advantages and Disadvantages • Significant Testing Parameters and Suggested Ranges • Recording and Using Breakthrough Data AIHCe 2014

  8. New EPA Guidance DocumentSummary Outline - 2 • Laboratory Testing Reduction • Worst Case Selection • Progressive Testing • Actual Case Testing (Specific Workplace Qualification) • Testing Options • Laboratory Testing (Single or Stacked per Moyer) • Field Testing (e.g., Respirator Cartridge Tubes per Cohen) • Surrogate Vapor Testing (per OSHA) AIHCe 2014

  9. New EPA Guidance DocumentSummary Outline - 3 V. Miscellaneous Requirements, including: • Duration of Tests • Replicates and Reproducibility • Safety Factor Application • Testing with Covapor(s) • Recognition of Products of Reactive Removal VI. Reporting Requirements (lists and tables) • Procedures Used • Conditions Used • Data Obtained • Conclusions Reached (Change-out Schedules, etc.) AIHCe 2014

  10. Decision Logic Flow Chart AIHCe 2014

  11. Lessons Learned • Updated Guidance Developed • Flexibility Allowed for Submitters • Case-by-Case Adaptations • Testing Protocol Design • Consideration of Chemical Properties • EPA Review of Results and Conclusions • Evaluations of Such Guidance with Real Cases – Case Study Developed AIHCe 2014

  12. Contact: Anjali Lamba lamba.anjali@epa.gov Disclaimer: The documents identified in this presentation have not been formally disseminated by the EPA and should not be construed to represent agency policy. AIHCe 2014

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