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Federal Regs: Respiratory Protection and GHS
Respiratory Protection: Assigned Protection Factors
The safety world was slightly surprised on Aug. 24, 2006, when OSHA released its latest revision to the existing Respiratory Protection Standard, 29 CFR 1910.134. This revision, effective date Nov. 22, 2006, includes definitions and requirements for assigned protection factors (APFs).
On Jan. 8, 1998, OSHA published the final revised Respiratory Protection Standard. At that time, OSHA omitted the section related to APFs, pending further rulemaking. The agency stated that as an alternative to OSHA's APFs, employers must take into account the best available information for respirator selection. To comply with OSHA prior to the APF standard release, most employers referred to the 1987/2004 NIOSH RSL (respirator selection logic) or the ANSI Z88.2 respiratory protection standard, which lists recommended respirator APFs. This scenario resulted in two resources for APFs that assigned different respirator protection factors. Adding to the confusion was that fact that the ANSI Z88.2 standard had not been accredited by ANSI since 2002, as the standard was never reaffirmed.
To view the standard, visit http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12716. Other online references are the OSHA press release on APFs, which can be viewed at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=12373 , and “NIOSH Respirator Selection Logic 2004,” which can be viewed at http://www.cdc.gov/niosh/docs/2005-100/chapter3.html.
Commentary
The release of this new OSHA revision offers the advantage of a single resource for employer compliance with OSHA workplace regulations. The wrinkle in this single resource is that the new OSHA APFs are also somewhat different than both NIOSH and ANSI APFs.
As defined by NIOSH, an assigned protection factor (APF) is the minimum anticipated protection provided by a properly functioning respirator or class of respirators to a given percentage of properly fitted and trained users.
As a reference point, the accompanying chart will help to clarify differences in APFs from three different organizations: NIOSH, ANSI and OSHA. NIOSH APF numbers are taken from its updated RSL, released in October 2004. ANSI APF numbers are taken from their Z88.2 standard released in 1992. OSHA's numbers are the new APFs released in August 2006. Please refer to these publications in their entirety for complete information regarding the APFs listed below.
APF Comparison
Type of Respirator |
NIOSH |
ANSI |
OSHA |
APR (Air-Purifying Respirator) Half-Mask |
10 |
10 |
10 |
APR Full-Facepiece |
50 |
100 |
50 |
PAPR (Powered Air-Purifying Respirator) Half-Mask |
50 |
50 |
50 |
PAPR Full-Facepiece |
50 |
1,000 |
1,000 |
PAPR Helmet/Hood |
25 |
1,000 |
25/1000* |
PAPR Loose-Fitting Respirator |
25 |
25 |
25 |
SAR (Supplied-Air Respirator), Demand, Half-Mask |
10 |
10 |
10 |
SAR, Demand, Full-Facepiece |
50 |
50 |
50 |
SAR, Constant-Flow, Half-Mask |
50 |
50 |
50 |
SAR, Constant-Flow, Full-Facepiece |
50 |
1,000 |
1,000 |
SAR, Constant-Flow, Helmet/Hood |
25 |
1,000 |
25/1,000* |
SAR, Pressure-Demand, Half-Mask |
1,000 |
50 |
50 |
SAR, Pressure-Demand, Full-Face |
2,000 |
1,000 |
1,000 |
SCBA, Demand, Full-Facepiece |
50 |
50 |
50 |
SCBA, Pressure-Demand, Full-Face |
10,000 |
10,000 |
10,000 |
SCBA, Pressure-Demand, Helmet/Hood |
10,000 |
10,000 |
10,000 |
The most significant differences between the NIOSH and OSHA APFs are in the area of powered air-purifying respirators (PAPRs) and supplied-air respirators (SARs). These differences greatly impact respirator manufacturers as well as employers who purchase these devices. In the case of PAPRs and SARS with helmet or hood, manufacturers had a very short time frame in which to complete simulated workplace studies to receive a higher APF of 1,000. Employers, on the other hand, need this information in order to continue using their respirators in hazardous locations and maintain compliance. Some employers were forced to switch to a different respirator, which always presents challenges. The new OSHA assigned protection factor for constant-flow supplied-air respirators with full facepieces also is different than that of NIOSH. OSHA assigned an APF of 1,000 to this respirator configuration, while NIOSH gave it an APF of only 50.
This new OSHA standard on APFs supersedes most of the APFs that have been noted in substance-specific standards previously released by OSHA, making it much easier for employers and employees to follow safe workplace respiratory practices.
CM
Hazard Communication Standard: Globally Harmonized System (GHS)
OSHA's Globally Harmonized System (GHS) is designed to eliminate the inconsistencies posed by regulations in various countries for the classification and labeling of hazardous chemicals, as well as safety data sheet information.
The GHS advance notice of proposed rulemaking (ANPRM) was published in the Federal Register on Sept. 12, 2006. Go to http://www.gpoaccess.gov/fr/index.html to view the ANPRM. The OSHA Web site also provides a GHS summary at http://www.osha.gov/dsg/hazcom/ghs.html.
Commentary
If all goes according to OSHA's plan, one in three Americans will be affected by the most significant change to the Hazard Communication Standard (HCS) since it was first promulgated in 1983. According to OSHA's revised estimates, the current HCS affects more than 100 million Americans, employed at more than 7 million working places and working with nearly a million hazardous products.
So why change, and why change now? To understand this, one has to travel back to 1992, when the United Nations Conference on Environment and Development (UNCED) adopted a mandate for the development of a Globally Harmonized System of Classification and Labeling for Chemicals (GHS). Many observe that our government moves at a glacial pace, but imagine shepherding through a significant global change. This explains why it has taken more than 15 years for this change to finally have the potential to impact U.S. workplaces in 2008.
The intent is for GHS to remove or significantly minimize the inconsistencies presented by the varying rules countries have for labeling hazardous chemicals and promote enhanced worker protection and facilitate more efficient trade in this global economy.
OSHA states:
… the United States (U.S.) is both a major importer and exporter of chemicals, the manner in which the U.S. and other countries choose to regulate information dissemination on hazardous chemicals not only has an impact on the protection of employees in the U.S. but also may pose potential barriers to international trade in chemicals. To protect employees and members of the public who are potentially exposed to chemicals during their production, transportation, use, and disposal, a number of countries have developed laws that require information about those chemicals to be prepared and transmitted to affected parties. These laws vary with regard to the scope of chemicals covered, definitions of hazards, the specificity of requirements (e.g., specification of a format for safety data sheets), and the use of symbols and pictograms. The inconsistencies between the various laws are substantial enough that different labels and safety data sheets must often be developed for the same product when it is marketed in different nations.
The Bottom Line
As much as GHS is meant to drive global harmonization in classification, safety data sheets and labeling, the GHS requirements typically are adopted by each country or region and may be modified by individual governmental bodies to meet specific in-country or regional compliance requirements and objectives. For all practical purposes, safety managers can anticipate more harmonization, but there will be national differences. How should safety departments prepare for what is coming?
GHS Classification and Regulatory Data
GHS requirements, regulatory data and substance classification data should be maintained in a database, by region, tracking how each country or region adopts the requirements. Online, Web-accessed reference data and integrated corporate enterprise data should include the following:
- Online regulatory data access with an easy-to-use interface and robust search, query, reporting and analysis.
- A system and process for regulatory updates in which relevant employees receive alerts on changing regulations.
- The integration of chemical regulatory data into diverse, custom, open corporate environmental, health and safety systems, including efficient change management and regular updates as regulations change and new ones are released.
SDS Authoring and Distribution
GHS classification data is necessary for substances and mixtures as part of safety data sheets (SDSs) and label authoring. SDSs and labels should be re-authored in compliance with GHS requirements for the country or region that has adopted GHS or is anticipated to adopt GHS. Authoring should support seamless, large-scale updates to SDSs and labels, thus providing a single source for GHS-driven SDS and labeling changes.
SDS Management
Chemical users should be able to search, print, view and e-mail SDSs in a company-specific database via a Web browser interface. GHS requirements are likely to drive significant revisions to SDSs and thereby increase the burden of vendor MSDS management.
Other Regulatory Impact
In addition to OSHA's HCS, GHS classification is also anticipated to affect current Toxic Substances Control Act ( TSCA) and Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) filings and inventories. Companies with chemicals that are subject to TSCA and FIFRA regulations should also review the impact of the GHS regulations on those chemicals.
CM
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