MEMORANDUM

TO:	Barbara Hargis
FROM:	Susan Martin
RE:	OSHA Comments on New Respiratory Standard Impacts on LANL Program

John Steelnack, Project Director for the new OSHA Respiratory Protection standard said in a telephone call today that he anticipated the impacts of the standard on LANL to be minimal, since he characterized LANL’s and LLNL’s programs to be "state of the art." LLNL’s James Johnson testified for the record as OSHA’s expert witness and was quoted for the argument that respiratory protection programs must be written because of their complexity.

The language of the new standard fills 30 pages of the Federal Register; the existing standard took up 5 pages in the Code of Federal Regulations. With the revision, all provisions addressing respiratory use, selection and fit testing are deleted from OSHA’s substance-specific standards. Mr. Steelnack said the major changes in the standard provided clarification, definition or specificity to existing requirements, with respect to fit testing, medical evaluation and respirator selection processes, and the most important new requirement was that an employer must designate a respiratory program administrator. He said that, previously, the responsibility for the program was often so diffuse that there was no one person or point of contact available to coordinate the program.

Attached is a document prepared by the OSHA Office of Training and Education this month entitled, "Major Provisions of OSHA’s Respiratory Protection Standard 29CFR1910.134." Standard requirements outlined in this document have been reviewed by Don Trujillo of the respiratory protection section to verify that LANL is in compliance with the revised requirements. The revised standard requires employers to make a determination that respirator use is required by September 8, 1998. Compliance with all other standard provisions is required by October 8, 1998.

Mr. Steelnack pointed to the following as major changes/additions to the standard (revisions are in italics):

• MEDICAL EVALUATION Old- 1910.134(b)(10) states that respirator wearers must be determined to be "physically able to perform the work and use the equipment", with determination by "the local physician." Revision 1910.134 (e) outlines extensive procedures for medical evaluation by a physician or licensed health care professional. Evaluator may use either a medical questionnaire or a physical examination. The information required is contained in mandatory Appendix C.

• FIT TESTING Old- 1910.134(e)(5) required that the user have an opportunity to wear the respirator "in a test atmosphere." Revision 1910.134 (f) requires a qualitative fit test (QLFT) or quantitative fit test (QNFT) for all employees using a negative or positive pressure tight-fitting facepiece respirator. Appendix A of the revised standard contains Fit Testing Procedures. Appendix B contains mandatory User Seal Check Procedure and Respirator Cleaning Procedures.

• SELECTION OF RESPIRATORS Old- 1910.13(c) referenced only ANSI Z88.2-1969 Respiratory Protection Practices. Revision 1910.134 (d) Selection of Respirators contains extensive respirator selection criteria and requirements. It sets forth general rules for selecting respirators for routine operations, prescribes specific kinds of respirators for identified highly hazardous atmospheres and emergency situations, and specifies when air-purifying respirators can reliably be used. When exposure cannot be identified or reasonably estimated, the atmosphere shall be considered immediately dangerous to life or health (IDLH). The revision contains specific requirements for respirators for IDLH and non-IDLH atmospheres.

• TRAINING Old- 1910.134(b)(3) required that the user must be instructed and trained in the proper use of respirators and their limitations. Revision 1910.134 (k) delineates the requirements for effective comprehensive training which must be provided at least annually.

Other major revisions not mentioned by Mr. Steelnack were reviewed by Don Trujillo for confirmation of program compliance here at LANL. Mr Trujillo noted that the LANL program in some cases exceeded the requirements of the new standard, e.g., the revision allows acceptable training provided by another employer prior to initial respirator use for compliance with initial training requirements; LANL does not allow training by another employer to be considered as sufficient for initial respirator use training.

Attachment

xc:	Helena Whyte Don Trujillo Mike Pannell