RECORD ID
D01-03-003
STANDARD NUMBER
INFORMATION DATE
03-21-2001
SUBJECT
Respiratory Protection Standard 29cfr 1910.134
QUESTION
Based on the attachment, would a company be non-compliance with 29 CFR
> 1910.134 (i) (8) if their breathing air system was cross-connected to
> various non-breathing air systems?
>OSHA Respiratory Protection Standard Preamble selected paragraph.
>
> Final paragraph (i)(8) requires that air line couplings be
> incompatible with outlets for non-respirable
> worksite air or other gas systems to prevent the
> inadvertent provision of nonrespirable gases to airline
> respirators. Breathing air couplings, therefore, are to
> be made incompatible with outlets from
> nonrespirable plant air and other gas systems. This
> requirement is similar to the provision in paragraph
> (d)(3) of the previous respiratory protection standard
> and proposed paragraph (i)(5) of the NPRM. Martin
> Marietta (Ex. 54-410) stated that there have been
> documented cases in which cross-connections have
> introduced hazardous contaminants into breathing air
> lines. To avoid this problem, Martin Marietta
> recommended that OSHA add a provision to the final
> standard that prohibits connecting breathing air
> lines to any nonrespirable gas source or process.
> Consistent with this recommendation, OSHA has
> added a sentence to paragraph (i)(8) requiring that no
> asphyxiating substance be introduced into
> breathing air lines. This requirement will cover not
> only the contamination of the breathing air system
> from cross-connections, but will also cover other
> potential contaminating conditions, e.g., using nitrogen
> to blow out worksite air lines where the worksite air
> source is also used for breathing air.
>
> Source:
> http://www.osha-slc.gov/SLTC/respiratory_advisor/oshafiles/respiratory7.ht
> ml
>
>
> 29 CFR 1910.134 (i)(8)
>
> The employer shall ensure that breathing air couplings are incompatible
> with outlets for nonrespirable worksite air or other gas systems. No
> asphyxiating substance shall be introduced into breathing air lines.
>
> Source: http://www.osha-slc.gov/OshStd_data/1910_0134.html
>
REGULATORY REVIEW
You are correct. A company would be in non-compliance with 29CFR1910.134 if their breathing air system was cross-connected to "non-respirable worksite air". Of course, no knowledgable DOE contractor would allow such cross-connections to occur even if there were no regulation.