Asbestos NESHAP Inspection and Safety Procedures Workshop

1. Asbestos NESHAP Inspection and Safety Procedures Workshop Section 11 Respiratory Protection October 2008

2. OSHA’sRespiratory Protection Standard29 CFR 1910.134

3. (a) Permissible practice (b) Definitions (c) Respirator program (d) Selection of respirators (e) Medical evaluation (f) Fit testing (g) Use of respirators (h) Maintenance and care (i) Breathing air quality and use (j) Identification of filters, cartridges, and canisters (k) Training and information (l) Program evaluation (m) Recordkeeping (n) Dates (o) Appendices (mandatory) A: Fit Testing Procedures B-1: User Seal Checks B-2: Cleaning Procedures C: Medical Questionnaire D: Information for Employees Wearing Respirators When Not Required Under the Standard Organization of Standard 29 CFR 1910.134

4. Scope - 29 CFR 1910.134 • General Industry 29 CFR 1910.1001 • Shipyards 29 CFR 1915.1001 • Construction 29 CFR 1926.1101 • The asbestos standards also have sections within them that address respirator use This standard applies to the OSHA asbestos standards:

5. Asbestos Standards • General Industry Standard • Respiratory Protection - Section (g) • Protective Clothing - Section (h) • Appendices: Fit Testing (C), Medical Questionnaire (D), Medical Surveillance (H) • Construction Standard • Respiratory Protection - Section (h) • Protective Clothing - Section (i) • Medical Surveillance - Section (m) • Appendices: Fit Testing (refer to 1910.134), Medical Questionnaire (D)

6. OSHA IssuesConstruction 29 CFR 1926.1101(g) • OSHA Classes of Work • Class I • Removal of surfacing material, TSI or PACM • Class II • Non “high risk” removal (flooring, siding, mastics) • Class III • Asbestos Inspection • Maintenance & Repair • Removal is not the purpose (removal to allow maintenance and repair) • 1 glovebag, mini-enclosures (2 workers max.), 1waste bag (60”x60”) max • Class IV • Maintenance & custodial cleaning activities, incidental contact or incidental to construction

7. Types of Respirators .

8. Tight -Fitting Coverings Half Mask Full Facepiece

9. Loose-Fitting Coverings Loose-Fitting Facepiece Hood Helmet

10. Respirator Selection • Employer must select and provide an appropriate respirator based on the respiratory hazards to which the worker is exposed and workplace and user factors that affect respirator performance and reliability • Selection must take into consideration the nature of the contaminant AND its concentration in the work place

11. Employee Exposure Exposure to a concentration of an airborne contaminant that would occur if the employee were not using respiratory protection. For asbestos, this is measured with personal air monitoring. Samples are analyzed by phase contrast microscopy (PCM) and results are in fibers per cubic centimeter (f/cc or f/cm3)

12. Filtering Facepiece(Dust Mask) A negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium. NOT ALLOWED FOR ASBESTOS PROTECTION

13. Negative Pressure Respirator A respirator in which the air pressure inside the facepiece is lower during inhalation with respect to the ambient air pressure outside the respirator. ☺In other words; you supply the “horsepower”

14. Air-Purifying Respirator (APR) A respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.

15. Half Face (Mask), Negative Pressure, Air Purifying Respirators

16. Full Face (Mask), Negative Pressure, Air Purifying Respirators

17. Positive Pressure Respirator • A respirator that uses a powered source such as a blower unit or compressor that blows filtered air into the face piece • A gap in the face/mask fit will release air and prevent contaminants from entering • This is a tremendous advantage compared to a negative pressure respirator

18. Powered Air-Purifying Respirator (PAPR) For your notes! A PAPR must be provided to workers upon request It is an OSHA requirement that ALL Class I jobs begin in PAPRs Filters for these are rated as “High Efficiency” or “Type H” not P-100

19. Air (Atmosphere) Supplying Respirator • A respirator that supplies the user with breathing air from a source outside of the asbestos work area • Includes supplied-air respirators (SARs) and self-contained breathing apparatus (SCBA) units

20. Supplied Air Respirator (SAR)Referred to as “Type C” An atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user. Also called airline respirator.

21. Supplied Air Respirator (SAR)Type “C” Pressure Demand With Reserve Air Pressure Demand Continuous Flow Type C Hood Style

22. Self Contained Breathing Apparatus (SCBA) An atmosphere-supplying respirator for which the breathing air source is designed to be carried by the user.

23. Canister or Cartridge A component with a filter, sorbent, or catalyst, or combination of these items which removes specific contaminants from the air passed through the container. Also called air purifying element.

24. Classes of filters for Non-Powered, Air-Purifying, Particulate-Filter Respirators Nine classes: three levels of filter efficiency, each with three categories of resistance to filter efficiency degradation in the presence of oil aerosols • NRP • 100 100 99 99 99 95 95 95 Used for Asbestos Dust Mask N - Not resistant to oil R - Resistant to oil P - Oil Proof

25. Selection and Use • For ASBESTOS the P-100 is used for negative pressure respirators (half/full face). • “High Efficiency” or Type H is used for positive pressure respirators such as a PAPR • Type H and P-100 are functionally the same • Both are color coded MAGENTA (colors vary from reddish to purple)

26. High Efficiency Filters • Filter that is at least 99.97% efficient in removing particles of 0.3 micrometers in diameter. • NIOSH Terminology: N100, R100, and P100 filters. • OSHA Terminology: “HEPA”

27. Identification of Filters,Cartridges, and Canisters • All filters, cartridges and canisters used in the workplace must be labeled and color coded with the NIOSHapproval label • Marked with “NIOSH”, manufacturer’s name and part number, and an abbreviation to indicate cartridge or filter type (e.g., N95, P100, etc.) Organic Vapor, Chlorine, Hydrogen Chloride, Sulfur Dioxide, Hydrogen Fluoride, Chlorine Dioxide Combination P-100&OV Ammonia Organic Vapor

28. End-of-Service-Life Indicator (ESLI) A system that warns the user of the approach of the end of adequate respiratory protection; e.g., the sorbent is approaching saturation or is no longer effective. • P100 respirator cartridges do not have a specific “end of life” as do some chemical cartridges… • If you have even a slightly hard time breathing through them…replace them. • - All respirator cartridges must be kept dry. If they get wet, they’re ruined…replace them!

29. OSHA Class I • In the absence of negative exposure assessment (NEA, air sample data) or work area fiber concentrations ≤1.0 f/cc • MUST wear PAPR (or better) • In work areas >1.0 f/cc • Must wear Type C with SCBA back up or SCBA

30. OSHA Class II & III • Asbestos inspection is OSHA Class III work • Regardless of personal air sample results… • You are REQUIRED to wear a 1/2 face respirator when sampling TSI and surfacing material • Exposure monitoring could require a higher level of protection • For other Class II & III work a NEA or 1/2 face respirator • EPA policy says full-face APR • See Federal Register, Vol. 71. No 64 (8-24-06), p. 50191-2, (h)(iii)

31. Oxygen-Deficient Atmosphere • An atmosphere with an oxygen content below 19.5% by volume • All oxygen-deficient atmospheres are considered immediately dangerous to life and health (IDLH) • Also, if the atmosphere has unknown hazards, it is are considered IDLH

32. Fit Testing Before an employee uses any respirator with a negative or positive pressure tight-fittingfacepiece, the employee must be fit tested with the same make, model, style, and size of respirator that will be used.

33. Fit Testing • Employees using tight-fitting facepiece respirators must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT): • prior to initial use, • whenever a different respirator facepiece (size, style, model or make) is used, and • at least annually thereafter

34. Fit Testing • Additional fit testing shall be conducted whenever change in an employee’s physical condition could affect respirator fit: • facial scarring • dental changes • cosmetic surgery • noticeable change in body weight

35. Respirator Use • Respirators with tight-fitting facepieces must not be worn by employees who have facial hair or any condition that interferes with the face-to-facepiece seal or valve function • Corrective glasses or goggles or other PPE must be worn in a manner that does not interfere with the face-to-facepiece seal • OSHA permits contact lenses to be worn inside of full face respirator masks. • Employees wearing tight-fitting respirators must perform a user seal check each time they put on the respirator

36. User Seal Check“Fit Check” An action conducted by the respirator user to determine if the respirator is properly seated to the face. Positive Pressure Check Negative Pressure Check THIS MUST BE PERFORMED EACH TIME THE RESPIRATOR IS PUT ON!

37. Fit Testing • The fit test must be administered using an OSHA-accepted QLFT or QNFT protocol contained in Appendix A of 1910.134 • Before respirator use and annually thereafter

38. Qualitative Fit Test (QLFT) A pass/fail fit test to assess the adequacy of respirator fit that relies on the individual’s response to the test agent. • QLFT Protocols: • Irritant smoke (cough) • Bitrex (taste) • Isoamyl acetate (taste) • Banana oil (taste) • -Saccharin (taste)

39. Qualitative Fit Test (QLFT) Bitrex Banana Oil Ampules Irritant Smoke Bitrex Test Kit Irritant Smoke Kits – Powered & Manual

40. Quantitative Fit Test (QNFT) An assessment of the adequacy of respirator fit by numerically measuring the amount of leakage into the respirator.

41. Quantitative Fit Test (QNFT) Probed respirators & probe kits TSI PortacountTM OHD FitTester 3000TM

42. QNFT Fit Factor A numerical estimate of the fit of a particular respirator on a specific individual; typically estimates the ratio: Concentration of a substance in ambient air Concentration inside the respirator when worn If the fit factor is determined to be equal to or greater than 100 for tight-fitting half facepieces or equal to or greater than 500 for tight-fitting full facepieces, the quantitative fit test has been passed with that respirator

43. How much asbestos inside the mask? • OSHA allows up to the PEL inside the mask • OSHA asbestos PEL 0.1 f/cc (8 hr TWA) • The EPA’s policy is a lower number • 0.01 f/cc, EPA PCM Final Clearance Value • This is a generally accepted industry practice • Has been in EPA asbestos model course materials for many years

44. PROTECTION FACTORS (PF) CO = Concentration Outside Mask (f/cc) CI = Concentration Inside Mask (f/cc) For determining concentration inside the facepiece Conc.outside PFConc. Inside “MUC” = PF x Concentration Inside (Maximum Use Concentration) Concentration = f/cc This number comes from personal air sample data! ÷ ÷ X

45. Protection Factors (PF)29 CFR 1910.134 Respirator TypePFMUL2 Half face APR10 0.1 f/cc Full face APR50 0.5 f/cc PAPR1 (tight fitting and hood) 1000 10.0 f/cc Supplied Air (Type C, PD) 1000 10.0 f/cc 1 Hoods can only claim 1000 if supported by manufacturer’s data. 2 Using recommendation of 0.01 f/cc inside mask: MUL = (0.01 f/cc)(PF)

46. Respirator Program • Must develop a written program with worksite-specific procedures when respirators are necessary or required by the employer • Must update program as necessary to reflect changes in workplace conditions that affect respirator use • Must designate a program administrator who is qualified by appropriate training or experience to administer or oversee the program and conduct the required program evaluations • Must provide respirators, training, and medical evaluations at no cost to the employee

47. Respirator Program Elements 1. Selection 2. Medical evaluation 3. Fit testing 4. Use 5. Maintenance and care 6. Breathing air quality and use 7. Training 8. Program evaluation

48. Medical EvaluationProcedures • Must provide a medical evaluation to determine employee’s ability to use a respirator, before fit testing and use • Medical evaluation procedures for all OSHA regulated asbestos activities will follow the procedures outlined in 29 CFR 1926.1101 (m) “Medical Surveillance”…at least • Medical questionnaire(29 CFR 1926.1101, Appendix D) • Pulmonary function test • Physical Exam • May also perform X-ray or other procedures • All records from medical evaluation are kept employment plus 30 years

49. Respirator Careand Storage • Provide each user with a respirator that isclean, sanitary and in good working order • Use procedures in Appendix B-2 orequivalent manufacturer’s recommendations • Store in a sealed bag to ensure cleanliness • Store in a manner to ensure the integrity of the facepiece. (no heavy objects on top, don’t leave in a hot car)

50. SUMMARY • Anticipate Hazards • Determine Appropriate Protection • Use the right respirator with the right cartridge • Maintain the respirator • Have a written respiratory protection program • Sample smart – use good techniques