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.