ML20217D772

Rev 1 to Reg Guide 08.015, Acceptable Programs for Respiratory Protection

ML20217D772
Person / Time
Issue date:	10/31/1999
From:	NRC OFFICE OF NUCLEAR REGULATORY RESEARCH (RES)
To:
References
TASK-*****, TASK-RE REGGD-08.015, NUDOCS 9910180137
Download: ML20217D772 (24)

Text

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l U.S. NUCLEAR REGULATORY COMMISSION n [eagg Revision 1 October 1999 l

I Rg***** j REGULATORY GUIDE OFFICE OF NUCLEAR REGULATORY RESEARCH REGULATORY GUIDE 8.15 (Draft was issued as DG-8022)

ACCEPTABLE PROGRAMS FOR RESPIRATORY PROTECTION A. INTRODUCTION methods of protection against airborne radioactive ma-terial, such as the use of process or other engineering Subpart H," Respiratory Protection and Controls controls, limitation of exposure times, decontamina-To Restrict Internal Exposure," of 10 CFR Part 20, tion and so on, should be considered before the use of

" Standards for Protection Against Radiation," speci- respirators.

fies the conditions under which respiratory protection The information collections contained in this regu-equipment may be used and lists the procedural require-latory guide are covered by the requirements of 10 CFR ments that must be met by a licensee when using respi-Part 20, which were approved by the Office of Manage-rators to limit intakes of radioactive material or to take ment and Budget, Approval No. 3150-0014. The NRC credit for the protection assigned to a respirator in limit-may not conduct or sponsor, and a person is not re-ing and estimating intake of airborne radioactive mate-quired to respor.d to, a collection ofinformation unless rials. If an evaluation shows that further exposure re-t displays a currently valid OMB control number.

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duction is appropriate, and no other practical means are available to reduce exposure to airborne radioactive H. DISCUSSION materials, respiratory protection equipment may be as-signed or its use may be permitted consistent with the Summary of Regulatory Requirements intent of the guidance in this regulatory guide. It is widely recognized among safety professionals This regulatory guide describes a respiratory that the use ci respiratory protection devices in the protection program that is acceptable to the NRC staff. wrkplace can impose physiological and psychological stresses on wrkers, obstruct their vision, hinder their This guide also provides guidance on performing eval-movements, and make effective communications dif h-uations to determine whether the use of respirators opti-cult. These factors increase the risk of physical injury to mizes the sum of internal and external dose and other risks. respirator wearers that, in many cases, far exceeds any potential risk associated with the inhalation of a small Licensees are encouraged to limit the use of respi- quantity of airborne radioactive material. Therefore,in rators to situations in which respirator use has been 10 CFR 20.1703 the NRC requires a minimum respira-shown to keep total effective dose equivalent (TEDE) tor program to control the risks associated with respira-as low as reasonably achievable (ALARA). Other tor use, even if the licensee does not intend to take credit l'$NRC RIGL 1 ATORY Gl'IDIA The guidens are issued m the followng ten broad dmsions Aeguietory Guides are issued to describe and make available to the pubhc such iriforstw ilon as methods acceptable to the NRC staff for implementmo spoofic parth of the Com. t Power Aeactors 6 Products mission s regulahOns leChrliques Whed by th0 staff an evaluating specific problems or pos. 2 Research and Test Reactors 7 Transportation tulated SCOoents and data needed by the NRC staff m its review of apphcations for per- 3 Fuels and Matenals Facihties 8 Occupational Health mets and hcenses Regulatory guides are not substitutes for segulations. and comphance 4 Envircinmental and Sihng 9 Antitrust s ad Ferennet Review Mth them is not required Methods and solutions differerst from those set out in the guides 5 Malenals and Plant Prutection 10 General wil be acceptanie if they provide a basis for the findmgs reqwste to the issuance or con.

fffluence o' a permet of hcense by the Commission S,ngle copies of regulatoq ;)uldes may be obtened free of charge Dy wntmg to the Repro-This gwde was issued after consideration of comments recewed from the pubhc Com. d on a O n n es Se n S u at R g g ot b to D fU ments and suggestions forimprovements e these gasdes are encourageG at all times and Y guidea wh be revised as appropnata,lo accommodate comments and to reflect new in. I

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lasued gwdes may also be purchased from the National Technical Information Service on Written comments may be submitted to the Rules Review and Dimetwes Branch ADM, a standmg order basis Details on this service may be et ta.ned by woting NTIS 520S Port U S Nuclear Regulatory Commission. Washmgton, DC 20555 0001 Royal Road Spnngt eld VA 22161 9910180137 991031 oD PDR REGGD 7 . _?1 (

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for the protection pmvided by the respirators in estima- keeping TEDE ALARA. The extent to evhich a licensee ting intakes. I may use respiratory protection equipment instead of us-Process or engineering controls are required by 10 ing process and engineering controls can also be lim-CFR 20.1701 to be used to the extent practical to con- ited by the NRC pursuant to 10 CFR 20.1704.

trol the concentration of radioactive material in air. The Also,10 CFR 20.1705 specifies that a licensee use of respiratory protection devices should be contem- must obtain authorization from the NRC before using plated only after other measures to limit intake have APFs in excess of those specified in Appendix A to 10 been considered. CFR Part 20. The application for authorization must In addition,10 CFR 20.1702 states that, when pro- describe the need for the higher APF and demonstrate cess or other engineering controls are not practical, the that the proposed equipment provides the higher APF.

licensee must increase monitoring and limit intakes by Applicability of OSIIA's Respiratory Pmtection using access controls, limiting exposure times, using Rules respiratory protection devices, or by employing other The Atomic Energy Act (AEA)gives the NRC the controls to keep TEDE ALARA. Guidance for per-statutory responsibility to protect public health and forming ALARA evaluations (that is, determining whether the use of respirators optimizes the sum ofin- safety, which includes worker health and safety, in the use of source, byproduct, and special nuclear materials.

ternal and external dose and other risks)is provided in this regulatory guide in Regulatory Position 2. The Occupational Safety and lleahh Act provides that this Act is inapplicable for working conditions under If the licensee assigns or permits the use of respira- which another Federal agency exercises statutory au-tory protection equipment to limit the intake of radioac- thority to protect worker health and safety. Therefore, tive material, the requirements stated in 10 CFR in implementing its statutory achority, the NRC pre-20.1703 must be followed. The NRC considers a respi. empts the application of the Occupational Safety and ratory protection device is being used to limit intakes of Health Act forworking conditions that involve radioac-airborne radioactive materials unless the device is tive materials.

cler.rly and exclusively used for protection against non-In 1988, the NRC and the Occupational Safety and radiological hazards. Whether or not credit is taken for llealth Administrition (OSilA) signed a Memorandum use of the device to reduce intake and dose,10 CFR

' of Understanding (MOU) to clarify jurisdictional re-20.1703 applies whenever respiratory protection de- sponsibilities at NRC-licensed facilities. NRC is re- l vices are used.' The minimum respiratory protection sponsible for three areas ofinterest:

program expected of any licensee who assigns or per- .

- Radiation risk produced by radioactive mits respirator use is outlined in 10 CFR 20.1703. This regulatory guide and 10 CFR Part 20 describe an excep-

• "I"'i"I*

tion for voluntary use of one type of filtering facepiece - Chemical risk produced by radioactive respirator when no assigned protection factor (APF) is materials applied.

- Plant conditions that affect the safety of radio-The requirements that must be met before a li- ctive materials and thus present an increased censee may use an APF to take credit for the use of any r diation risk to workers, respiratory protection device to reduce intake and dose The MOU makes it clear that if an NRC licensee is are in 10 CFR 20.1703. using respiratory protection to protect workers against According to 10 CFR 20.1704, the NRC may place nonradiological hazard:,, the OSIIA requirements ap-ply. If the NRC has jurisdiction ard L. .esponsible for i

additional restrictions on licensees, use of respiratory . .

i protection equipment that might further h.mit expo-inspection, the MOU s, ns that NRC will inf.orm sures to airborne radioactive materials, consistent with the abue aml OSilA if the NRC observes an unsafe condition relative to nonradiological hazards. In gen-I '

See NURliGCR-6204. " Questions and Anmers Hased on Resised 10 Ci R Part 20"(UsN RC, May 1994). page 44,Ouestion 91.Copics may be is in compliance with the NRC regulations in Subpart purchased at eurrent raics from the U.s Goven nment Pnntmg offwe.ito.

Box 37082, %ashmgton, DC 20402-9328 (telephone (202) 512-1800). 11, the liceitsee is considered to be in compliance with or from the National TechnicalInformation service by u ntmg NTIS at the corresponding and comparable OSIIA regulations 5285 Port Royal Road, Spnngfscid. VA 22161; phone (703)487-4650

< hup://www.nus gov /ordernow>. Copics are as ailable for mspechon or on TcSpiratorv " protection. Licensees are cautioned, copying for a fee f rom the NRC Public Document Room d 21201. street however, that in situations involving mixed haz.ards, NW.. Washmgton. DC. The PDR's mailmg aJdress is Mail Stop 1 I -6 Washmgton. DC 20555; telephone (202) 634-3273; fu (202) such as airborne radioactive materials and 634-3343. nonradioactive hazardous matena ls, compliance with 8.15-2

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10 CFR Part 20 alone may not provide sufficient that do not qualify as half-facepieces in NRC's view, i protection. the APFs listed in Appendix A to 10 CFR Part 20 now l match the ANSI-recommended APFs.

I O AdditionalInformation s

Licensees are cautioned regarding the use of sup-V When a licensee permits or assigns the use of respi-plied air respirators and self-contained breathing appa-ratory protection devices, such devices should be used ratus (SCBA) that operate in the demand mode. Since in accordance with the manufacturer's instructions. Re-these devices operate in a negative-pressure mode, any spiratory protection devices should also be used consis-face-to-facepiece seal leakage will permit contami-tent with the intent of the guidance in this regulatory nants to enter the respiratory inlet covering where they guide, which describes the elements of a respiratory could be inhaled. Since these devices are air-supplied, protection program that is acceptable to the NRC. More

[ individuals might perceive them to be more protective detailed advice and technical information can be found than they really are and attempt to use them in situa-in NUREG-004)," Manual of Respiratory Protection tions in which a device with a much higher APF is indi-Against Airborne Radioactive Materials."2 cated. This is especially true of two types of SCBA:

C. REGULATORY POSITION demand-only and those that have a so-called " donning switch."

1. ANSI STANDARD Z88.2-1992 AND EXCEPTIONS For the first category, ANSI specifically prohibits the use of demand SCBA in emergency v..uations such The recommendations in the American National as fire fighting. NRC concurs with this prohibition.

Staoards Institute standard, ANSI Z88.2-1992, A SCBA with a donning switch operates as a "American National Standard For Respiratory Protec-pressure-demand unit when the switch is in the proper tion,"3 are endorsed by the NRC and may be used by position. The purpose of the donning switch is to permit licensees in establishing a respiratory protection pro-the wearer to switch the mode of regulator operation gram with the following exceptions, from pressure-demand to demand while donning the 1.1 ANSI Z88.2, Paragraph 4.5.1, Program device, or immediately prior to removing the facepiece Administration in a safe area. The donning mode prevents the rapid loss

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Paragraph 4.5.1 of ANSI Z88.2-1992 states "The of air from the SCB A cylinder when the facepiece is not sealed to the wearer's face. There are two potential responsibility and authority for the respiratory protec-problems with this type of device. The wearer will not tion program shall be assigned by the employer to a have the benefit of a highly protective pressure-demand single person."It is acceptable to the NRC staffif the device if(l) the switch is mistakenly left in the donning individual who administers the radiological respiratory program is different from tic person who administers position when the wearer enters a hazardous area or (2) the switch is inadvertently changed to the donning posi-the industrial respiratory protection program, tion while the worker is in a hazardous area. Licensees 1.2 ANSI Z88.2, Table 1-Assigned Prutection who have demand-only SCBAs or SCBAs with don-Factors ning switches, especially those who might need to use in ANSI Z88.2-1992, Table 1," Assigned Protec- them in a fire fighting application, should be aware that t.on Factors,., permits the use of quarter-facepiece res- these devices do not meet the current Natwnal Fire P i di 4 pirators (which seal over the bridge of the nose, around FPA) standards and the de-the cheeks, and between the point of the chm and the vices should either be modified to bring them up to the lower lip). These are not listed in Appendix A to 10 new standard or be replaced.

CFR Part 20 and may not be used in an NRC-regulated 1.3 ANSI Z88.2, Paragraphs 9.3.1 and 9.3.2 respiratory protection program. Paragraphs 9.3.1 and 9.3.2 could be interpreted to ANSI also lists APFs for air-purifying respirators mean that respirators from several manufacturers, or and for atmosphere-supplying respirators. With the mi- several different model respirators from the same nor exception of those filtering facepiece respirators manufactum, are required to be available for use. The NRC staff's position is that one model of respirator 2 copies are available for mspection or cop > mg for a ree from the NRc hm one manufadumis ahuam, m hg a Me o Pubhc Document Room at 2120 L street Nw, Washington, DC. He sizes of facepicCes are available and adequate fit faClors i

s 1 PDR'5 mh"8 8dd'c55 55 M2d S'"P Ll'6, washmgion, oc 20535. icle.

y phone (202) 634-3273; rax (202) 634-3343 are obtained for greater than 99% of test subjects who 3

Copics may be obtamed from the American National standards Institute, 4 National hre Protection Association, *open Circuit self-Contained inc., Sales Department,11 West 42nd street, New York, NY 10036.

lircathing Apparatus for hre hghters," ANsl N PA 1981,1997 edition.

8.15 - 3

are free of facial characteristics that preclude an ade- 2.1 ALARA Evzluitions quate respirator fit. For individuals who achieve a fit factor >500 with a negative-pressure full facepiece but When a specific ALARA evaluation is performed who are unable to achieve a fit factor 10 times the APF, tojustify the use or nonuse of respirators, the evaluation should consider the following:

the NRC suggests consideration be given to assigning a )

positive pressure face-sealing device or to a device for 2.1.1 The use of process and engineering con-which a face seal is not necessary. trols, filtered ventilation systems, and decontamination before the use of respiratory protection devices, 1.4 ANSI Z88.2, Paragraph 10.2, Fnquency of Inspection 2.1.2 Control of access, limitation of exposure time, and the use of other types ofexposure controls be-Paragraph 10.2 recommends that each respirator fore the use of respiratory protection devices, and I stored for emergency use or rescue be inspected at least 2.1.3 The estimated benefit. The evaluation monthly, and that this inspection is to include the proper function of regulators, alarms, and other warn- should show that the TEDE for thejob will be ALARA; mg systems. The NRC suggests, consistent with the that is, the internal dose avoided by using the respira-OSIIA Act, that a monthly visualinspection of SCBAs tory protection equipment is likely to be greater than any additional external dose that may result from the is sufficient, and that an operational test (i.e., pressuriz-ing tiie regulator, testmg the 'ow-pressure alarm) need use of these devices from respirator-induced ineffi-ciency and other factors-only be done quarterly. Other devices stored for emer-gency use should be visually inspected monthly, but In performing an ALAPA evaluation, when decid-only need to be thoroughly examined two or three times ing which respirator is to be considered for assignment per year (see Regulatory Position 4.3 of this Regulatory during a specific task, the licensee should divide the av-Guide 8.15. erage ambient concentratian of radioactive materialin work place air (or the estimated average) by the ap-

2. ALARA REQUIREMENT propriate DAC value for the contaminants present. The As stated in 10 CFR 20.1101(b), licensees must number obtained may be considered initially as an ideal use, to the extent practical, procedures and engineering minimum APF for the selected device. If the ALARA controls based on sound radiation protection principles evaluation determines that use of a respiratory protec-to achieve occupational doses that are ALARA. tion device might be justified, the licensee should con-sider a A vice with this APF or greater. If selection of a According to 10 CFR 20.1702, licensees are to respin or with this APF is inconsistent with ALARA, limit intakes by means of engineering controls or pro- however, the licensee may select a device with a lower cedures, along with the use of respirators, consistent APF. Worker safety factors other than radiological fac-with maintaining the TEDE ALARA. tors, such as heat stress or impaired vision, should be The NRC views the TEDE-ALARA requirement taken into account when performing such an ALARA as a subset of the general ALARA requirement of 10 evaluation. Consideration should also be given to the CFR 20.1101. That is, the focus should be on program- P.ossibility that the planned work will cause resuspen-matic controls. The NRC does not expect or requb e the sion of radioactive matenal, thus increasing the average licensee to use all possible ways and means to reduce mnantration during the task.

the TEDE. Ilowever, each licensee should have an The extent and level of detail addressed in TEDE ALARA program that is integrated into the site radi- ALARA evaluations should be commensurate with the ation protection program. Each licensee is required to potential radiological and physical risks involved in the track doses and to take measures to maintain worker activity. The licensee should consider the following doses ALARA. The NRC recognizes ihat, when evalu- factors in an evaluation of whether respirator use is ations are needed to comply with 10 CFR 20.1702, ALARA.

those evaluations (and the factors needed to make a Environmental conditions, them) are not exact science. Assumptions for workeref-ficiency, stay time hours, estimated intakes, etc., are by -

Protective equipment and clothing, including the their very nature not precisely known. Therefore, when respirator, that would be required for the activity the evaluation results do not show a clear. obvious indi- being evaluated and their effects on worker effi-cation (to use or not use respirators), the NRC expects 'IC"CY' the licensee to use professionaljudgment as to whether

• Comfort level of the workers regarding the use of or not to assign respirators. respirators, 8.15 - 4

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• Experience and skilllevel of the individual with re- equivalent (DDE) from a task orjob below which a re-spect to the task, cord of an ALARA evaluation is not needed. When the Process and engineering controls to be used, licensee plans to use respiratory protection equipment, f]

• the licensee does not need to record ALARA evalua-(j

• Specific details of the task to be performed (e.g., tions for situations in which the projected external DDE dose rates, estimated average airborne concentra- to any individual is below the threshold.

tions),

The licensee does not need to record ALARA eval-Potential post-activity negative impacts (e.g., per- uations when the prospective radioactive material in-sonnel decontamination and skin dose assess- take is below an established threshold, assuming no ments, portal monitor alarms). respiratory protection is provided, k Such evaluations should be documented in accor- Regardless of the magnitude of the projected exter-dance with implementing procedures, but they may ei- nal and internal dose, the licensee does not need to per-ther be job-specific or be performed for general job form or record ALARA evaluations before requiring types. ALARA evaluations performed for generaljob the use of respiratory protection equipment as a precau-types should be reviewed periodically to ensure that tionary measure when there is a large uncertainty about none of the assumptions or parameters upon which the the magnitude of the projected concentrations of air-evaluation is based have changed. The hcensee, how-borne radioactive material to which the workers will be ever, should be able to support the decision to use or not exposed (e.g., a new job with significant airborne con-to use respirators in each circumstance. Supporting in- tamination poten..al, but with no history of previous formation could include the results of surveys, meas- similar jobs). (See NUREG/CR-6204,1 Question 60.)

urements and calculctions, previous history with this or similar jobs, or other pertinent data. The judgment of 2.4 Exceptions to ALARA Requirement for Respirators individuals with extensive knowledge and experience in the field may also be sufficient in circumstances that The ALARA principle must be applied in a reason-are not amenable to quantitative analysis. able fashion when making decisions on respirator use.

For ALARA evaluations, a respirator-induced The NRC staff recognizes that there may be situations (Q") worker inefficiency factor of up to 15% may be used when the dose evaluation clearly indicates that respira-without further justification. Larger worker ineffi- tors need not be used, but the licensee makes a profes-ciency factors may be used, but the licensee should sional decision to use respirators in spite of the evalua-have test data to support them. tion for reasons that are valid but may not be quantifiable.

2.2 Estimated ALARA Benefit When the use or nonuse of respirators has no clear The evaluation should demonstrate whether or not impact on TEDE, the licensee should opt to not use the TEDE for the job will be ALARA; that is, whether respirators in most circumstances. There could be some the internal dose avoided by using the respiratory reasonable exceptions to this, however. For example, protection equipment is likely to be greater than or less respirator use could be considered if a nonradioactive than any additional external dose that may result from nuisance dust exists in the work area. In these cases, the use of these devices from respirator-induced ineffi. the respirators should be selected to have the least pos-ciency and other factors. Nonradiological factors sible impact on worker stress, vision, and ability to should be included. Examples are the benefit of an air. communicate.

supplied suit that provides cooling or the loss of effi- Other valid exceptions would be certain respira-ciency because of impaired vision. tory protection devices used to reduce heat stress on 2.3 ALARA Evaluation-Records workers or used as contamination-control devices in high contamination but relatively low airborne radioac-Licensees who perform analyses to determine tivity areas (e.g., the use of airline-supplied hoods for whether or not the use of respirators will optimize the steam generator entries).

sum ofinternal and external dose and who record these ALARA evaluations in accordance with the following A reduction in TEDE for a worker would not be g

guidance wdl be considered to be in compliance with trasonable if an attendant increase in the worker's in-NRC staff recommendations. dustrial health and safety risk (e.g., from a vision limi-tation or other respirator-related problem) would ex-The licensee should establish a reasonable thresh- ceed the benefit to be obtained by reducing the risk old value (in rem) for prospective external deep dose associated with the reduction in the TEDE. (See 8.15 - 5

NUREG/CR-6204,1 Question 387.) This determina- tional check (non-face-sealing devices) on a respi- ,

tion is likely to be based on judgment rather than any rator each time it is donned, quantitative comparison.

• Fit-testing, The NRC is aware of existing State OSIIA regula- . Selecting respirators, l tions that require an employer to provide a worker with Maintaimng breathm.g air quality,

,I a respirator upon request (i.e., voluntary respirator use).

Compliance with such State regulations is acceptable

• Inventory and control of respiratory protection I

to the NRC. (See NUREG/CR-6204,1 Question 386, equipment, and Regulatory Position 4.7 of this guide.) Also, the .

Storage and issuance of respiratory protection i voluntary use of disposable filtering facepieces (dust equipment, masks)is permitted in Appendix A to Part 20 without {

l fit-testing or medical screening.

Maintenance, repair, testing, and quality assurance of respiratory protection equipment,

3. PROCEL)URES AND PROGRAMS

• Recordkeeping, 3.1 Applicability .

Limitations on periods of respirator use and relief Pursuant to Subpart H of 10 CFR Part 20, a licensee from respirator use.

may assign and take credit for the use of respiratory pro- Written procedures should also be in place for:

tective equipment to limit intakes of airborne radioac-

• Performing and documenting the required medical tive material. Unless the licensee can clearly show evaluation, otherwise, any use of respirators under Subpart 11 is considered to be for the purpose oflimiting the intake of Maintaining TEDE ALARA and performing radioactive material. Therefore, if respirators are as- ALARA evaluations with regard to respiratory signed routinely or periodically, the licensee's respira- protection.

tory protection program must include, as a minimum, Written procedures should also include a descrip-all the requirements contained in 10 CFR 20.1703. tion of the following applications of respirators:

If a licensee does not use respirators routinely or

• Routine respirator use periodically, but has determined that there is sufficient

• Nontoutine respirator use (e.g., in unassessed areas likelihood of an emergency situation to justify the or for nonrecurring tasks for which engineering maintenance of emergency-use self-contained breath- controls are not in place or practical); and ing apparatus (SCBA) or other types of respirators for an emergency, a program is necessary to ensure the safe Emergency respirator use (e.g., recovery of an ,n- i use of that equipment should it be needed. jured person from an area where air concentrations of radioactive material may be high, the breathing Footnote d of Appendix A to 10 CFR Part 20 and quality of the ambient air has not been assessed, or Regulatory Position 4.8 of this regulatory guide de- the area may become immuiately dangerous to life scribe an exception for voluntary use of certain types of or health (IDLH) because of the presence of nonra-filtering facepiece respirators when no APF is applied. diological hazards).

3.2 Written Procedurrs 3.3 Application of Assigned Protection Factors According to 10 CFR 20.1701 'vritten procedures 3.3.1 The APFs listed in Appendix A to 10 CFR must be in place. These procedures should address and 20 are an indication of the predicted level of protection implement the following respiratory protection pro. that a respirator user can expect to get from a given type gram e:ements: of respirator. Use of the APF presumes that:

Monitoring, including air sampling and bioassays, The respirator user has been trained to properly don the device; Supervision of the program, including program au-dits' The user has been satisfactorily fit-tested (face-sealing devices only);

• Training and minimum qualifications of respirator

• The user properly performs either a user seal check program supervisors and implementing personnel

• on face-scaling devices to ensure that there is no e Training of respirator users, ir.cludirg the require- gross seal leakage, or an operational check on non-ment for each user to inspect an6 perform a user face-sealing devices to ensure that the equipment is seal check (for face-sealing devices) or an opera- operating properly; and 8.15 - 6

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• The respirator performs properly. 3.3.5 The following is an example of the use of 3.3.2 APFs are intended to be used as follows: the APF to estimate intake and then dose.

n d[Vl

• For selecting a type or types of respirators to be pur.

chased by a licensee to address the expected range of potential airborne contamination levels at the fa-Two fully qualified respirator users wearing half-facepiece negative-pressure respirators (APF

= 10) perform work for 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> in an airborne con-cility and credible emergency situations; tamination area. Four 1-hour air samples taken dur-ing the course of a task indicate that actual airborne For selecting a specific type of respirator from among thos available at the facility, to be used in contamination concentrations were 11.2, 15.4, the performance of a specific task, to keep the 24.8, and 12.6 times the DAC respectively. Taking TEDE of exposed workers ALARA; and credit for the APF=10, actual worker exposure can be assumed to be 1.1 DAC-hr + 1.5 DAC-hr + 2.5 For estimating intake when bioassay and other DAC-hr + 1.3 DAC-hr = 6.4 DAC-hr. Since 1 evaluation methods are either not available or are DAC-hr = 2.5 mrem, the worker doses may be re-not the method of choice. corded as j 3.3.3 For personnel for whom an internal dose-6.4 DAC - hr x mrem monitoring program is required pursuant to 10 CFR = 16 mrem 20.1502 (e.g., an adult radiation worker likely to re-ceive 10% of an ALIin a year), any intake must be re. If the licensee desires, bioassay measurement may corded as specified in 10 CFR 20.1204. Using APFs to be performed, and the recorded dose may be adjusted in estimate intake and thus dose of record from internal accordance with 10 CFR 1703(i).

sources is permitted.

3.4 Surveys 3.3.4 If respirator wearers are not required to be monitored for intake of radioactive material, no record A survey pmgram that is adequate to identify po-of internal exposure (DAC hours) or internal dose tei.tial respiratory hazards, to perm t selection of the pmper respiratory protection method (not necessarily n) *(mrem)

The APF ofneed beis calculated ten times greater thanor retained if:

the assignment of respirators), and to evaluate actual or (O the respirator the multiple by which average ambient concentra-suspected intakes is required'by 10 CFR 20.1703(c)(1) and (c)(2). Survey programs include (but are not neces-tion of airborne radioactive materialin the work- sarily limited to) surveys for radiation, contamination, place exceeds the applicable DAC value and airborne radioactive materials, and bioassay measure-The licensee's respiratory protection program ments. Other regulatory guides, some of which are meets all the requirements of Subpart H of 10 CFR listed below, describe methods and programs that are Part 20. accepta' ole to the NRC.

Number Tith Date 8.9, Rev.1 Acceptable Concepts, Models, Equations, and Assumptions for a Bioassay Program 7/93 8.11 Applications of Bioassay for Uranium 6/74 8.20, Rev.1 Applications for Bioassay for 1-125 and I-131 9/79 8.21, Rev.1 Health Physics Surveys for Byproduct Material at NRC-Licensed Processing and Manufacturing Plants 10/79 8.22. Rev.1 Bioassay at Uranium Mills 8/88 8.23, Rev.1 Radiation Safety Surveys at MedicalInstitutions 01/81 8.24, Rev.1 Ilealth Physics Surveys During Enriched Uranium-235 Processing and Fuel Fabrication 10/79 8.25, Rev.1 Air Sampling in the Workplace 6/92 8.26 Applications of Bioassay for Fission and Activation Products 9/80 8.30 llealth Physics Surveys in Uranium Mills 6/83 8.32 Criteria for Establishing a Tritium Bioassay Program 7/88

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8.34 Monitoring Criteria and Methods To Calculate Occupational Radiation Doses 7/92

V 8.36 Radiation Dose to the Embryo / Fetus 7/92 8.15 - 7

3.5 Supervisory Positions and Responsibilities the respirator may be used in accordance with the A program should be established that: manufacturer's instructions. Equipment or devices supplied by a company other than the respirator Identifies the individuals who have supervisory manufacturer may be used as long as they do not alter and technical responsibilities in the respiratory the form, fit, or function of the respirator. Any such de-

)

l protection program (including the respirator pro- vice that attaches to or requires penetration of the respi- 2 gram admmistrator),

ratory inlet covering is likely to void the NIOSil ap-States the responsibilities of each position, proval for the device and should not be used.

l

• Specifies minimum training and retraining require- 4.2 Non-NIOSII-Certified Equipment ments for each position, and If a licensee identifies a need for a respiratory f Identifies the minimum qualifications for appoint- protection device that would adequately provide the ment or assignment to these positions, needed protection but the device is not NIOSH-The radiological and nonradiological respiratory certified,is not listed in Appendix A to 10 CFR Part 20, protection programs may have different administrators nd no comparable NIOSil-certified device exists, the as long as adequate communication and coordination licensee may apply to the NRC to use the noncertified exist between the programs. device (see 10 CFR 20.1703(b)). NRC approval is re-quired whether or not APF credit will be used, except

4. EQUIPMENT that supplied-air suits may be used without such ap-4.1 NIOSII-Certified Equipment proval as long as no APF is used (see Regulatory Posi-tion 4.10.1). The application to use a noncertified de-The National Institute for Occupational Safety and vice should:

Health (NIOSII) issues approvals for respiratory a

protection devices. A list of the manufacturers and Explain why no existing NIOSif-certified device model numbers of approved devices is available from meets the licensee's need, NIOSil.5The NRC requires that only NIOSH-certified

• Present evidence that the material quality and per-equipment be used in a radiological respiratory protec- formance characteristics of the proposed device are tion program unless a variance has been granted as de- capable of providing adequate respiratory protec-scribed in 10 CFR 20.1703(b). In addition, these de- tion to the wearer under the proposed conditions of vices must be used, maintained, and stored in such a use,and manner that they are not modified and are in like-new .

Show that using the device as proposed will not condition at the time ofissue.6A reasonable amount of subject the wearer to undue physical or psychologi-wear that does not affect performance is acceptable. cal stress or nndue hazard.

According to 10 CFR 20.1703(e), the licensee is to Such test information may be provided by the li-provide adequate equipment or material, as necessary cc.nsee, the equipment manufacturer, or by a reliable to supplement resp!ratory protective equipment, to re- third party. The manufacturer of such a device shculd duce the likelihood that respirator use might contribute have previous experience with the design and manufac-to workplace accidents or injury. Examples of such ture of respiratory protection equipment. The licensee equipment would be spectacle adapters, voice amplifi- may use such devices under controlled test conditions cation equipment, material or equipment to prevent or to develop information for the authorization applica-reduce fogging of respirator lenses, and body-cooling tion. When the NRC has granted authorization to use equipment ir. environments with high temperature or such a device to one licensee, subsequent applications high humidity. by additional licensees may make use of test informa-Safety or protective equipment used in conjunction tion in that original submittal. As a minimum for de-with respirators should not interfere with the proper fit vices that have not yet been authoiized for use by NRC, or operation of the rc .pirator. Manufacturer-supplied the licensee should be involved in at least one opera-equipment (e.g., welde '1 shields, communications de- tmnal test of the device.

vices) specified on the approved subassemblies list for 4.3 Inventory, Inspection, and Storage 5

This list is available from Pubhcahans Disseminanon. DSsT, National Respirator facepieces that are routinely available Insutute for occupanonal safety and ilcalth, U.S Department ofilealth for issue should be visually m.spected at least every and iluman Sernces,46 )6 Columbia Parkw ay. Cincinnati, Ohio 45226.

month or in accordance with manufacturer's instruc-6see "NtoSil Approval Requirements for Respiratory Proicction Equip-men Radianon troiecton Management,voi 14, september' October (jons. If such devices are stored in clear plastic bags, they should be handled and examined, but need not be 8.15 - 8

removed from the bags for this inspection as long as the only by persons specifically trained to perform this licensee can determine that the device is ready for issue. work. Such repairs and maintenance should be per-Respirator facepieces (face-sealing types) must be formed in accordance with the manufacturer's instruc-

/3 checked for leakage (user seal check) prior to each use tions, but in general, training by the device manufac-see 10 CFR 20.1703(c)(3)). A user seal check per- turer is not required.

(~) (formed by the person being issued the respirator, either Maintenance and repair of sora components of at the point ofissue or immediately prior to entenng an certain devices require manufacturer-certified training anborne contamination area, fulfills this requirement.

(e.g.,SCBA regulator,SCBAlow pressure alarm).The Equipment used in conjunction with facepiece res- device manafacturer identifies the components that re-pirators (e.g., belt- or facepiece-mounted air regulators, quire mam.facturer-certified training.

air supply hoses, portable distribution manifolds) 4.5 Control and Issuance should be inventoried and functionally tested periodi-

. cally or prior to use. Licensees should maintain positive control ever

. . . the issuance of respiratory protection devices. Suffi-When it is provided as emergency respiratory cient control should be established and maintained so protection equipment, SCBA should be visually in-that persons not authorized to wear such devices are ef-l spected monthly and operationally tested at least quar-fectively prevented from obtaining them.

terly. Escape-only devices should be visually inspected monthly. Personnel who issue respirators must ensure that

, each person issued a respirator has been medically Some other respiratory protection devices, such as screened, trained, and (for face-sealing devices) fit-air-purifying respirators specifically designated for tested within the period prescribed. Persons may only emergency use, should be visually inspected monthly be issued face-sealing respirators for which Miey have and should be removed from any protective container been fit-tested (i.e., same make, model, style, and size).

and thomughly examined periodically (e.g., 2 to 3 times per year). Such devices might be stored at the 4.6 Recordkeeping Emergency Operations Facility at a commercial power Records of all the required activities in a respirator program should be kept in a manner that shows com-p) reactor or at comparable locations at a materials licens-ee's facility.

pliance with the requirements of the applicable regula-Repair and replacement parts for respiratory tions.

protection devices should be inventoried and inspected 4.7 Half-Facepiece Respirators (APF = 10) periodically. The goal is to ensure that there are suffi-cient functional parts available to support the respira. Half-facepiece respirateis seal over the bridge of tory protection program when it is operating at full ca. the nose, around the cheeks, and unh the chin. Tradi-I pacity. tionally, half-facepiece respirators are made of rubber or an clastomeric material (e.g., silicone rubber), have When in storage and not available for use, respira-

~

at least two adjustable elastic head straps (4-point sus-tors and component parts of respiratory protection de-pension), and use replaceable filter cartridges.

vices should be stored in such a way as to prevent dam-age to such components and devices. Devices in storage Two relatively new variations on the half-facepiece should be inspected before they are made available for resphator are now available. They are sometimes re-issue. Equipment stored for periods of a year or more ferred to as " reusable," " reusable-disposable," or should be inspected annually to ensure that they are in " maintenance-free" devices, and they are designed to I good condition in case they are needed unexpectedly. be worn several times or for some perbd of time by the user. These devices are not intended for only a single Breathing air cylinders, including SCBA cylin- use, and they can be divided into two general catego-ders, must be tested as prescribed in the Shipping Con- ries:

tainer Specification Regulations of the Department of Transportation (49 CFR 173 and 178). Each breathing

• Respirators that have a standard rubber or clasto-air cylinder should be permanently ard legibly marked meric facepiece with lilters attached, but the filters

" Breathing Air"or" Compressed Breathing Air." re n t replaceable. These devices are considered to be half-facepiece respirators.

('_) 4.4 Maintenance and Repal . .

d *

" Filtering facepiece" respirators in which the filter Respirators and compcnent parts of respiratory medium is an integral part of the facepiece structure protection devices should be maintained and repaired and is no: replaceable.

t 8.15 - 9

In order for a device in the second category to be they create very little solid radioactive waste. These de-considered a half-facepiece respirator in an NRC pro- vices are permitted for use in a radiological respiratory '

gram,it must have both of two design characteristics: protecticn program, but no credit may be taken for their

= . use except as described below. Licensees are relieved of Seal-enhancing rubber or elastomeric material ap-plied to the entire face-to-facepiece seal area, and the requirement to medically screen and fit-test the l

. I wearers of such devices as long as no APF,is used. A

+

An adjustable four-point (minimum) suspension user seal check should be performed upon donning, if strap system. possible, in accordance with the manufacturer's in-Most of the devices that qualify as half-facepiece structions, and all other applicable program require-respirators also have exhalation valves, but an exhala- ments listed in 10 CFR 20.1703 apply. Devices must be tion valve, while desirable, is not an essential design NIOSii-certified, and wearers must be trained in the

{

component. Devices that meet these criteria are consid- pr per use and limitations of the deviu s. The informa-ered half-facepiece respirators and have an APF = 10. tion contained in OSHA's Appendix D to 29 CFR They are acceptable for use in an NRC-regulated pro- 1910.134 constitutes acceptable training for users of gram as long as the user can properly perform a seal these devices. The availability of the devices should be check upon donning, and all other program require- c ntrolled so that untrained individuals cannot oloa in ments (e.g., medical screening, fit-testing, training) are them, and so that these devices are not mistakenly sub-fulfilled. It is important to follow the manufacturer's stituted for a more protective device in the Held, recommendations and in-house contamination control Single-use respirators might be appropriate in situ-procedures to establish the length of time such face- ations when a respirator is not necessary but is re-pieces may be used before being discarded. quested by a worker (i.e., voluntary respirator use).

T$e use of quarter-facepiece respirators (which This type of respiratcr can limit intakes of nuisance seal over the bridge of the nose, around the cheeks, and f"* * * . n us o a m re pm ec m evice c nn t be

. . . justiRed in an ALARA analysis. These devices should between the point of the chin and the lower lip)is not

, be discarded after each use, and a new device should be acceptable in an NRC-regulated program because it has used for subsequent work.

been observed that the fit becomes unstable when the wearer moves around in the work place, especially If a licensee wants to use an APF for these devices, when the wearer talks. These devices have never been the rule (at footnote d to Appendix A to 10 CFR Part 20) permitted in an NRC-regulated respirator program, and Permits the use of an APF of 10 if the licensee can dem-good alternatives such as half-facepiece respirators are onstrate a St factor of at least 100 by using a validated or readily available. evaluated, qualitative or quantitative, fit-test. If an APF is used for these devices, the requirement for medically 4.8 Other Filtering Facepieces or Dust Masks (No screening the user is reinstated. Acceptable protocols APF) for qualitative fit-testing can be found in Sections B1 Other NIOSH-certified filtering facepiece respira. through B5 of Appendix A to OSIIA's 29 CFR tors are available that do not fit NRC's description of a 1910.134, " Respiratory Protection."

half-facepiece respirator in Regulatory Position 4.7. 4.9 Respirator Filters These are generally considered to be single-use dispos- .

able respirators and are referred to in this regulatory H has changed the way nonpowered air-guide as dust masks. An experienced respirator pro. Purifyin8 respirator filters are certified and designated.

gram administrator should be able to distinguish be-Under NIOSil's old rule (30 CFR Part 11), respirator tween these single-use, filtering facepiece dust masks hen f r pmtedmn agam.st abrne ragonuMes l and those that qualify as half-facepiece respirators in an were requ e to be at kast 99.97% efficient for the NRC-regulated program. Table 1 of ANSI Z88.2-1992 e llecti n f 0.3 m mass median aerodynamic diame-does not divide facepiece respirators into two groups. ter @@) particles, the particles being produced by The standard does not differentiate between single-use the vaporization and condensation of dioctyl phthalate en t meet hs entesn argommonh re-disposable filtering facepieces and half-facepieces, but allows an APF = 10 to all disposables and quarter- and ferred to as high-efficiency particulate air (llEPA) fil-half facepieces. ters. Under NIO5H's new rule (42 CFR Part 84), filters are divided into three categories based on their perfor-l Dust masks are relatively inexpensive; have little mance characteristics when used against oil-containing i or no impact on worker vision, cardiopulmonary stress, and non-oil-containing airborne hazards. The catego-heat stress, and ability to communicate verbally; and ries are N (non-oil-resistant), R (oil-resistant), and P 8.15 - 10

(oil-proof). Within each category there are three levels ues to operate properly and that the "like-new condi-of efficiency: 95 (95% minimum efficiency),99 (99% tion" criterion is maintained as described in Regulatory minimum efficiency), and 100 (99;97% minimum effi- Position 4.1 of this guide.

[] ciency). Some examples of filter designations would be For example, some chin-style gas mask canisters

/ N-99, P-95, R-100. The decision as to whether N ,

for organic vapors are stamped with a "Use Before" R , or P-type filters should be used is left to the li-date, which is 5 years from the date of manufacture.

censee.

Such canisters should not be used after that date has Footnote b to Appendix A to 10 CFR Part 20 re- passed. Also, the date that these canisters are first un-quires that, for air-purifying respirators operating in the sealed should be written on the canister label, and the negative-pressure mode that have an APF <100 (i.e., canisters should be discarded one year from the unseal-half-facepiece respirators), filters of at least 95% effi- ing date, ciency be used (e.g., N-95). For air-purifying respira- 4.11 Supplied Air Hoods fors operating in the negative-pressure mode that have .

an APF = 100 (i.e., full-facepiece respirators), filters of In 1996, NIOSIl issued a notice to respirator users at least 99% efficiency must be used. For air-purifying to alert users to updated information relative to the per-respirators operating in the positive-pressure mode that f rmance fcertaintypesofsupplied-airrespiratorsap-have an APF >100 (i.e., full-facepiece powered air-pu- proved and used during abrasive-blast (sandblasting) rifying respirators), filters of at least 99.97% efficiency paa ons. NIOSil assigned relatively low APFs for are to be used. these respirators with certain types of respirator inlet coverings (e.g., the APF for a loose-fitting hood is 25).

NIOSli has determined that, effective July 10, The NRC staff recently became aware of an 1998, particulate filters and respirators certified under industry-sponsored testing initiative focused on hood 30 CFR Part 11 can no longer be manufactured and slupped as NIOSii-certified items. NIOSH has als performance. While the results have not been pub-lished, initial indication is that, while most mc els taken the position that (1) distributors who purchased demonstrated APFs greater than 1000, some designs 30 "FR Part 11 particulate filters and respirators prior did not provide test subjects with APFs that exceeded to by 20,1998, will be able to sell them as " certified" 1000'

[_N until inventories of these products are depleted, and (2)

( ) end users who purchase said particulate filters and res. Until the study is completed and the results are pirators from these distributors will be able to use them made available, licensees should use hoods with anti-until their inventories are depleted or until the end of the aspiration devices and use supplied air flow rates at the shelf life or service life for these products, maximum allowed by NIOSli certification, consistent Filters for powered air-purifying respirators will with wearer comfort (noise limitations). Anti-aspiration devices minimize penetration of the hood by continue to require that dust-fume-mist ilEPA filters be contaminants. These devices include neck dams or used until NIOS11 amends its regulations.

other neck-sealing features that fit snugly around the Respirator filters can be re-used by the same person user's neck. These devices limit the " bellows effect," as on the same day without being re-tested, as long as con- do bibs or hood shrouds that may be tucked inside a tamination control is adequate and the filters do not ap- worker's protective clothing. These bibs help form a pear to be damaged. If the licensee's procedures allow lower barrier to minimize the backflow of for filter re-use beyond one day by the same person, or contaminants.

by other persons, such filters should be re-tested before 4.12 Supplied Air Suits re-use occurs. Such re testing should include a penetra-4.12.1 Supplied Air Suits Used With No APF tion test using any appropriate aerosol and a pressure-drop test. Filters to be reused should not have any ap- One-piece and two-piece supplied-air suits are per-parent damage and should meet the licensee's criteria mitted for use in nuclear industry respiratory protection for iesidual contamination. programs, but no APF is assigned and no protection credit may be taken except as discussed in Regulatory 4.10 Service Life Limitations Posilmn 4.12.2 of this guide. NIOSli certification pro-If the respirator equipment manufacturer specifies cedures do not currently include a method for testing and certifying these suits. NRC believes, however, that (q a jshelf nents of life or service a respiratory life limit protection on the system, onelicensee or moreincompo- certain nuclear industry applications (e.g., control-l V should comply with the recommendations of the rod drive removal at boiling water reactors) they might manufacturer. This will ensule that the device contin- be the best overall choice, taking into account 8.15 - 11

respiratory protection, contamination omtrol consider- connects the device to a supply of breathing air, the ations, heat stress, and ALARA. APF increases to 1000.

Users of supplied-air suits must be medically ap- Another type of combination device of interest to proved and trained, and the air supplied to the suit must nuclear reactor licensees is the combination particulate /

meet the minimum quality requirements specified in organic vapor respirator canister, commonly referred to CGA 7.1-1997," Commodity Specification for Air,"7 as a "radiciodine canister." When used in conjunction for other (NTOSil-certified) supplied-air devices. The with the appropriate facepiece, this canister is not spe-equipment must be stored, maintained, and tested (as cifically certified for protection against airborne radio-applicable)in accordance with the manufacturer's rec- iodine because iodine does not have good user-warning ommendations and the licensee's respirator mainte- properties and the canister is not equipped with an end-nance and quality assurance program, of-seivice-life indicator (ESLI). It is certified, how-  !

ever, f r pr tection against airborne particulates When selecting such devices for use in a respira-(P-100) and for orgam,e vapors. Therefore, an APF of tory protection program, the licensee should determine M n y be used for airborne particulates. Licensees that the material quality and performance characteris-who wish to use an APF for radioiodme for this device tics of the proposed device are capable of providing ad-nmst apph to NRC for authonzation. Alternatively, equate respiratory protection to the wearer under the they may use representative air sample data to estimate proposed conditions of use, while not subjecting the and control worker doses, then perform post-exposure wearer to undue physical or psychologicM stre. or un-bioassay to confirm or correct the estimated doses to due hazard. Such material and performance informa-tion may be provided by the licensee, the equipment ". rkers. Otherwise, licensees must use representative ir s mple data from the workplace to assign doses to manufacturer, or by a reliable third party. The manufac-exp sed workers. Requirements for determming inter-turer of such a device should have previous experience n I doses are contamed in 10 CFR 20.1204.

with the design and manufacture of respiratory protec-tion equipment. 4.14 Eme gency and Escape Equipment 4.12.2 Supplied Air Suits Used With an APF 4.14.1 Equipment for Emergency Entry If a licensee needs to apply an APF to a supplied-air The equipment preferred for emergency entry iato j suit, a written application may be made to the NRC in an unassessed envircnment, or into an area with high accordance with the requirements of 10 CFR 20.1705. c ncentrations of a chemical hazard,is the open-circuit f Conditions of use to be described in the application self-ccmtained breathing apparatus (SCBA) operated in I would include the anticipated length of air supply hose the pressure-demand mode, with a minimum rated ser-(minimum and maximum) and breathing air supply vice life of 30 minutes. Also acceptable are a combina-pressure (minimum and maximum). The NIOSil ap- tion full-facepiece pressure demand supplied air respi-proval criteria for supplied-air hoods (42 CFR Part 84) r tor with an auxiliary self-contained air supply of at may be useful to licensees who anticipate applying for le st 5 minutes duration and a positive-pressure, use of an APF for supplied-air suits. cl sed-circuit (recirculating) SCBA with a minimum rated service :ife of 30 minutes.

4.13 Combination Devices 4.14.2 Other Emergency E,qu.ipment Some devices are available that combine two respi-Other equipment may be designated for emergency rator types in one unit (e.g., a combmatron of negative-use against airborne radioactive material. An example

pressure air-purifying and contmucus-fkv airline res-would be air-purifying respirators stored at the Emer-pirator). When taking credit for use ef such a

, gency Operations Center at a commercial power reactor combmatm, n device, the licensee must ensure that the facility. At nuclear power plants, where emergency re-proper APF is applied to the exposure time and aliborne soonders might receive a radiation dose from airborne concentration that exists while the respirator is fun' r$dioiodine in a credible accident scenario, organic-tionmg m each mode of operation. For example, when vapor cartridges or canisters may be used for whatever using the combmation device described above, an APF protection they provide and radioiodine doses should of 100 apphes during the time the wearer is m the air-be controlled and accounted for as stated in 10 CFR Part borne contammation area and not connected to an air 3

~0' supply hose. Once the worker reaches the work site and 4.14.3 Escape Equipment

~

7 Availabie from the Compressed Gas Association,Inc.,1235 Jefferson Davis lhghu ay, Ariington, VA 22202. cape only. Other escape-only devices are available that 8.15 - 12 L___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __________ _________________________________a

are hazard-specific (e.g., mouthpiece and bit respiraturs The medical evaluation program should be carried for escape from chlorine environments). These devices out by the physician, or by a certified, medically trained must be NIOSil-certified for escar.; from the atmos- individual such as a registered nurse (RN), licensed

('N practical nurse (LPN), emergency medical technician

('^') phereescapein which from, but neverthey will for entry into,be used.

hazardous They may be used for areas. (EMT), or someone who, in the judgment of the licens-ee's physician, has adequate experience, education, 4.15 Decontamination and Disinfection of training, and judgment to administer the screening Facepieces; Contamination Control program.

Licensees should decontaminate and disinfect res. Medical evaluations performed by a physician pirators and associated equipment in accoidance with other than the licensee's physician may be acceptable as the manufacturer's instructions, paying particular long as comparable screening tests and acceptance cri-attention to the cleaning or sanitizing agents used and to teria are used for screening individuals, the maximum temperature of the water used for clean-5.1.3 Timing of Medical Evaluations ing, to avoid degradation of the respirator. Chemical residues should not be hazardous or irritating to the According to 10 CFR 20.1703(c)(5), the initial user. Radiological limits for reuse of respirators after medical evaluation to determine a worker's fitness to they have been cleaned and sanitized onould be estab. use respirators must be accomplished prior to respirator lished by the licensee. fit-testing for tight-fitting facepieces and prior to the first field use for loose-fitting devices, ince no fit-test

5. RESPIRATOR USERS is required for these types.

5.1 Medical Evaluation The worker must be re-evaluated medically every 12 months thereafter or at some other frequency estab-5.1.1 The Licensee's Physician lished by the licensee's physicia .. ANSI Z88.6-1984 suggests a range for reevaluation from every 5 years for A physician selected by the licensee should deter-workers below age 35, to annually for workers over mine which screening methods and tests are appropri- age 45.

(n) ate,and should set should tests, and the acceptance criteria periodically review the for those methods imple- If necessary, a re-evaluation " grace period" of up

\d mentation of the program. This screening process to 90 days is considered to be reasonable.8 In unusual should be sufficient (in the opinion of the licensee's circumstances, ary otherwise fully qualified respirator physician) to identify any persons who should not use user whose medical screening has expired within the respiratory devices for medical reasons, or who should p st 90 days may be issued a respirator with the concur-be limited to the use of specific types of devices. The rence of the Respirator Program Administrator. Licen-NRC regulations do not require a " hands-on" physical sees should not interpret this grace period to mean that examination by a physician. re-screening can be accomplished every 15 months. For example, the Health Physics Position referred to above The licensee should choose a physician with an ap- specifies that, if annual rescreening is indicated, three propriate specialty (e.g., internal medicine, industrial consecutive examinations should not exceed 39 medicine, family practice), and the licensee's physician months.

should be licensed to practice medicine in the United 5.1.4 Failure To Meet the Acceptance Criteria States.

I Individuals whose screening results fall outside the 5.1.2 Establishing and Performing the range of the criteria established by the licensee's physi-l Evaluation cian may have their cases evaluated by the licensee's physician. This evaluation might consist only of a re-ANSI Z88.6-1984, " Respirator Use-Physical view of the written record, or it might involve a Qualifications for Personnel,"3 provides guidance that hands-on examination. In these situations the licensee's is acceptable to the NRC staff for the physician to use in physicisa might permit the individual to use one or determining medical fitness. The screening method more types of respirators judged to impose less stress, may include a medical history questionnaire (the and prohibit the use of other more stressful devices.The gy OSIIA Respirator Medical Evaluation Questionnaire licensee's physician may confirm the outcome of the

( ) in Appendix C to 29 CFR 1910.134 is acceptable) and

'd spirometry testing. The licensee's physician, however, 8 G.D. Kerr et al.,* Health Ph)sicis Positions Data Base," Health Physics establishes the precise screening method. Po5 ion 219, NUREG'CR-5569, Revision 1, Page 120, february 1994.

8.15 - 13

screening by prohibiting the individual from using any 5.3 Fit-Testing l respirator.

A fit-testing program is to be implemented for all f 5.1.5 Privacy of Medical Records f ce-sealing respirators (see 10 CFR 20.1703(c)(6)),

even if they wri he rsed in a positive pressure mode in Medical records and the results of medical screen- the field. The employee should be fit-tested with the ing tests should be kept private. The only information same make, model, style, and size of respirator that will that should be transmitted from the medical department be used in the field.

to the respirator department is whether or not an indi-Each person being fitnested should already have vidual may use respirators, or which devices may be been trained in how to properly don, and perform a user used and which may not be. A simple medical-approval seal check on, a face-scaling respirator. Therefore, dur-form is adequate.

ing the test, no person (including the person administer-S.2 Training ing the fit-test) should assist or coach fit-test subjects who are not obtaining a satisfactory facepiece seal.

A training program, including hands-on training, Qualitative fit-testing (OLFT) and quantitative fit-must be established and implemented for respirator us- testing (ONFT) must be accomplished with the face-ers (see 10 CFR 20.1703(c)(4)). When face-sealing res-piece operating in the negative pressure mode, regard-pirators will be used, this training should take place less of the mode of operation in which it will be used in prior to fit-testing. As a minimum, each trainee should:

the field. QLIT can usually be accomplished with un-

+ Be informed of the hazard to which the respirator m dified respirators. For QNFT, some respirator wearer may be exposed, the effects of contaminants manuf cturers provide a fit-test adapter to accomplish on the wearer if the respirator is not worn properly, this. Otherwise, respirators used for fit-testmg will and the capabilities and limitations of each device need to be modified. While this modification voids the that may be used. NIOSli certification for the test device, certification is not required since occupational exposures are not in-Be shown how spectacle adapters, communica- volved during fit-testing.

tions equipment, and other equipment that will be Filters used during fit-testing should be at least used directly in conjunction with the respirator are 99.97% efficient, even if less efficient filters wi:1 be to be attached and operated properly.

used in the work place. The fit-test is intended to mea-Be able to demonstrate competency in donning, us. sure only face-to-facepiece leakage, so filter efficiency ing, and removing each type of respiratory protec. on the test respirator should be as high as possible.

tive device that may be used.

The size of the particles that make.up the challenge Be instructed in how to inspect each type of respira- ems 1 during fit-testing is unimportant. The follow-tory protective device that may be used and be ing challenge crosols have been used successfully.

instructed to perform such an inspection before Corn oil (QNFT) donning any device.

Sodium chloride (QNIT)

Be instructed in how to perform a user seal check Ambient dust particles (ONIT) on face-sealing devices and be instructed to per-Sodium saccharine (QLFT) form this user seal check each time this type of de-vice is donned. Bitrex (denatonium benzoate)(QLFT)

Amyl acetate (or isoamyl acetate or isopentyl ace-Be informed that any respirator user may leave the tate),9 commonly called " banana oil"(OLIT) work area at any time for relief from respirator use .

in the es ent of equipment malfunction, physical or Stanmc chloride (irritant smoke) (OLFT) psychological distress, procedural or communica. All these are acceptable challenge agents as long as tions failure, significant deterioration of operating the sensitivity of the detection system (QNFT) or the conditions, or any other condition that might ne. ability of the test subject to sense the challenge agent cessitate such relief. (OLIT) meets the test protocol requirements.

Be advised that in case of respirator malfunction or During training or operation, perceptible outward wearer distress, the respirator may be removed as leakage of breathing gas from the face-to-facepiece seal the respirator user exits the airbome contamination M ht-test USing amyl or isoamyl o, isopentyi acetate requires that an or-area. ganic vapor respirator cartr.dge be used in the test respirators.

8.15 - 14

area of any SCBA is unacceptable, and the wearer OLFT is acceptable if the method used is capable should not be permitted to continue to use the device. of: l Such leakage will quickly deplete the available breath-Verifying a fit factor 10 times the APF for face-ing gas and if used in an emergency could easily place pieces that in the field will operate in the negative the wearer in jeopardy.

pressure mode, or 5.3.1 Quantitative Fit-Testing (QNIT)

~

Verifying a fit factor of 500 (not 500 times the ONFT is acceptable for testing all face-sealing de- APF) for facepieces that in the field will operate in vices. If QNITis used to test facepieces that will be op- a p sitive-pressure mode. Devices that operate in a erated in the negative Eressure mode in the field, an p sitive-pressure mode are listed in Regulatory 1 overall fit factor of at least 10 times the APF (given in Position 5.3.1' t

Appendix A to 10 CFR Part 20) should be demon- Currently available OLFT methods are only capa-strated. Requiring that the overall fit factor meet the ac- ble of verifying a fit factor of 100. Therefore present ceptance criterion means that the fit factor for one or OLFT methods are only appropriate for devices with an more of the individual test exercises might be less than APF of 10 or less, unless and until new QLFT methods the acceptance criterion, but a satisfactory overall fit- that can confirm higher fit factors are developed and test can still be achieved. validated. Licensees may use OLFT to test respirators with APF greater than 10, but may only take credit for If QNFT is used to test facepieces that in the field an APF of 10 even though the listed APF is higher for will be operated only in a positive pressure mode, an the device in Appendix A to 10 CFR Part 20.

overall fit factor of at least 500 (not 500 times the APF) should be demonstrated with the facepiece operating in 5.3.3 Irritant Smoke the negative pressure mode. Face-sealing devices that operate in a positive pressure mode are powered air- The currently used irritant smoke OLFT protocol h has never been validated. Ilowever, it will evoke an ia-purifying respirators (PAPR), continuous flow sup-plied-air respirators, pressure-demand supplied air res-voluntary response in virtually anyone who smells it, and it is therefore less subjective than the other OLFT pirators and SCBA, and positive-pressure recirculating SCBA' Erotocols. NRC considers that this Erotocol has been sufficiently evaluated to permit its use in nuclear indus-For combination devices (e.g., a combination of try respirator programs for half-facepiece respirators negative-pressure air purifying and continuous-flow that will be used in the negative pressure mode of airline device), the minimum acceptable fit factor is 10 operation.

times the APF for the negative pressure mode of opera-When stannic chloride hydrolyzes with moisture in tion, or 500, whichever is greater.

the air it forms hydrochloric acid (IICl) and stannic ox-During all quantitative fit-tests, the sample point ychloride. Licensees should ensure that only stannic inside the facepiece should be midway between the chloride smoke tubes are used. Similar tubes that gener-mouth and the nose of the test subject. ate smoke of a different chemical composition may not be sufficiently irritating to the test subject to be sensed 5.3.2 Qualitative Fit-Testing (QLFT) at low concentrations. Smoke tubes that use chemicals other than stannic chloride are not acceptable.

While no numerical measure of facep.iece leakage is directly obtained from QLFT protocols, they are de- If irritant smoke is used as the challenge aerosol signed and validated quantitatively. Each validated during QLFT, the licensee should take steps to protect protocol first tests the subject's ability to detect (i.e., the person administering the test frorr. repeated expo-smell or taste) a small concentration of the challenge sures to the irritant smoke. These steps could include 3 aerosol (C2). After donning the device to be tested, the using a contaSment chamberaround the head and torso seal area is then exposed to a higher concentration of the of the fit-test subject to contain the smoke, providing challenge aerosol (Ci ) and the subject performs a se- the test area with a ventilation or air filtration system, quence of head, neck, and body movements while the assigning a respiratory protection device to the person concentration of challenge aerosol is maintained. If the performing the fit-testing, or other measures. The fit-challenge concentration is 100 trmes the wearer's test protocol should also be designed to limit the test r

detection threshold, and the wearer isn't ab:e to detect subject's exposure, especially when performing the the challenge aerosol, the test hasin essence measured a sensitivity screening checks that deteunine whether the fit factor of at least 100 (i.e., Ci /C 2 2100). test subject can detect the irritant smoke.

l 8.15 - 15 l _ . - - -

Because of exposure to both the fit test subject and on a medical screening questionnaire (if used) might be the fit test administrator to the chemical irritant, considered.

NIOSII does not recommend the use of irritant smoke Licensees are cautioned that Federal regulations for respirator fit-testing.

that apply to some nonradiological hazards (e.g.,29 5.3.4 Fit-Test Protocols and Pr6cedures CFR 1910.1001 on asbestos) may require ietesting at  ;

Fit-testing should be performed in accordance with m re fr quent intervals, and they may require more

. . than one satisfactory fit-test.

an established protocol.10 Each time fit-testing is re-quired, only a single satisfactory fit-test need be 5.4 User Seal Checks performed. Each respirator wearer must perform at least one Protocols that can be used for developing OLFT type of user seal check each time a face-scaling respira- )

and ONFT procedures may be found in Sections B1 tor is used. A user seal check is performed immediately through B5 and in Sections C1 through C3 0f Appendix prior to exposure to ensure that the respirator is prop-A to OSIIA's 29 CFR 1910.134, " Respiratory Protec. erly seated on the face. Some licensees may require the tion." Fit-testing performed in accordance with these respiratar user to also perform such a user seal check at protocols will comply with NRC's requirements. the point of respirator issue to ensure that the respirator is in good working order before the worker proceeds to 5.3.5 Retesting the job site. In this case, the respirator user must per-Retesting must be done annually. If necessary, a re- form another user seal check after donning the face-test " grace period" of up to 90 days is considered to be piece at the work site, reasonable.8 In unusual circumstances, an otherwise A user seal check is not a substitute for a fit test.

fully qualified respirator user whose fit-test has expired Acceptable user seal checks are described below.

within the past 90 days may be issued a respirator with .

the concur. .nce of the Respirator Program Administra- Silive-Pressure check. Close off the exhalation va e and exhale gently into the facepiece. The face fit tor. Licensees should not interpret this grace period to mean that fit-testing can be accomplished every 15 is c nsidered satisfactory if a slight positive pressure months. Three consecutive fit-test periods should not c n be built up inside the facepiece without any evi-exceed 39 months. dence of outward leakage of air at the seal. For most res-pirators this method ofleak testing requires the wearer Retesting should be performed before the next res- to first remove the exhalation valve cover before clos-pirator use when a potential respirator wearer, since the ing off the exhalation valve and then carefully replacing last fit-test, has had it after the test.

• A weight change of 10% or more, Negative-pressure check. Close off the inlet open-

• Significant facial injury or scarring in the area of ing f the canister or cartridge (s) by covering with the the facepiece seal, palm of the hand (s) or by replacing the filter seal (s),in-

. . hale gently so that the facepiece collapses slightly, and Sigmficant dental changes (e.g., multiple extrac-hold the breath for ten seconds. The design of the inlet tions without prosthesis or acquisition of new den-tures), opening of some cartridges cannot be effectively cov-ered with the palm of the hand. The test can be per-Reconstructive or cosmetic surgery in the area of formed by covering the inlet opening of the cartridge the facepiece seal, with a thin latex or nitrile glove. If the facepiece re-Any other condition that might change the fit of a mains in its slightly collapsed condition and no inward face-sealing respirator, leakage of air is detected, the tightness of the respirator f is considered satisfactory.

Licensees should take steps to make these retest criteria known to respirator users (e.g., during training Manufacturer s recommendedscalcheck. The res-and retraining) and should work with site medical or pirator manufacturer's recommended procedures for health personnel to identify persons who meet any of performing a user seal check may be used instead of the the retest criteria. Adding or revising some questions positive and negative pressure check procedures pro-vided that the employer demonstrates that the manufac-turer's procedures are effective. f Also acceptable as a seal check is the use of an irri-1"see Respirator Fil Testing and the Exercise Protocol," Radiation tant or odorous test agent, such as stannic chloride (irri-Protection Management. Volume 6. september / october 1989.

tant smoke) or amyl acetate (or isoamyl or isopentyl 8.15 - 16

acetate).9 While seal checks that use these agents are seal area of full-facepiece respirators and are therefore I more involved than other methods, require a test sub- not allowed. If alf-facepiece respirators seal around the es stance, and might require the assistance of others to bridge of the nose and prevent standard spectacles from

( properly administer, they are still permitted to be used being worn as designed. NRC requires that respirator U) by licensees. users be able to see well enough to be able to work 5.5 Operational Checks safely and to keep radiation doses ALARA. Ilow these goals can best be met isleft to thej.udgment of the respi-Non. face-sealing respirators (e.g., airline-supplied rator program administrator.

hoods) should be operationally checked to ensure pror operation a short time before the wearer enters Most n'anufacturers of full-facepiece respirators the radiological environment for which the device is t offer a spectacle adapter kit. Non-manufacturer-supplied adapters may be acceptable if they do not in-be used for piotection. For example, once an individual has donned a supplied-air hood, the air should be al- terfere with the facepiece seal and if they ('o not cause any distortion of vision, damage the lens of the face-lowed to flow for a period of time (e.g., one minute) be-piece, or cause any harm to the wearer during use. It is fore the wearer enters the contaminated area. During not advisable to use home-made adapters, or to simply this time support personnel should verify that the air pressure at the distribution manifold is within the tape the spectacles inside the facepiece.

proper range specified by the manufacturer and that the Contact lenses are permitted for use with respira-wearer feels that the airflow is adequate. tors provided the wearer has demonstrated successful experience in wearing such lenses. Contact lens wear-5.6 Communications ers should be required to practice wearing the respirator i

Respiratory protection devices limit the wearer's while wearing the contact lenses, for example, during ability to communicate. NRC regulations require that tr mng r fit-testing.

respirator users be able to communicate well enough to Another option is to select a respirator that does not be able to work safely and to keep radiation doses interfere with the use of standard cpectacles, such as a ALARA. Ilow these goals can best be met is left to the

' hood or helmet.

/ judgment of the respirator program administrator. In many situations, adequate communication can be 5.8 Use of Respirators in Low Temperatures maintained by training the respirator wearers to speak 5.8.1 Lens Fogging slowly and' distinctly. In other situations, especially where ambient noise levels are high or where respirator Fogging of the inside of the respirator lens is com-wearers must communicate across long distances, monly experienced in full facepiece respirators operat-voice amplification devices or other types of systems ing in the negative-pressure (including demar d) mode might have to be employed, or the pressure-demand mode. The fogging is caused by the condensation of the moisture in exhaled breath that Licensees are reminded that if these deviws are at-comes in direct contact with the inside of the lens. Most tached to the respirator or require a modification of the full facepiece respirators have air inlet ducts positioned respirator, they must be listed on the manufacturer's i to direct the inhaled air across the inside of the lens as it schedule of approved subassemblies. This ensures that enters the facepiece. This :lears off the accumulated the NIOSH approval for tire device remains in force condensation, but the lens fogs again during exhala-with the addition of the communications equipment, tion. The cooler the ambient air temperature, the less ef-After-market communications de' ces supplied by fcctive the lens clearing provided during inhalation. At a company other than the respirator manufacturer may temperatures below freezing, lens frosting can occur be used as long as they do not alter the form, fit, or func- that will not be removed during inhalation and may tion of the respirator. Any such after-market device that eventually seriously obscure the wearer's vision. Lens attaches to or requires penetration of the respiratory ia- f gging ar:d frosting, therefore, can present a signifi-let covering is likely to void the NIOSH approval for cant safety hazard by restricting the wearer's ability to the device. see clearly in the work place. Some possible solutions l

to the fogging and frosting problems are:

-m 5.7 Vision

/ \

( ,) Some types of respirators prevent the wearer from Nose cup. Most full-facepiece manufacturers pro-vide an optional component called a nose cup. It is at-using standard spectacles or from using them properly. tached to the inside of the facepiece in such a way that it The ear pieces of standard spectacles pass through the directs the stream of exhaled air directly into the ex-8.15 - 17

halation valve, minimizing the amount of moist air con- If the device in use is operated in the negative-tacting the interior of the lens. pressure mode, it is unlikely that the respirator wearer would be aware of the malfunction. The air breathed by Anti-fog applications. Most full-facepiece the wearer would, at least in part, be unfiltered ambient manufacturers provide an anti-fog material that limits air entering the respiratory inlet covering through the fogging when applied to the interior of the respirator open exhalation valve during the negative-pressure (in-lens.

halation) portion of the breathing cycle.

j Plastic. inserts. Thin plastic inserts that are applied 5.8.3 Conclusion to the inside of the facepiece lens to form a double-pane .

insulating barrier may effectively reduce fogging. Licensees should recognize the potential problems 1 associated with respirator use in subfreezing environ-Before using commercial anti-fogging products ments and take special care when face-sealing respira-(that are not supplied by the respirator manufacturer), tors are used in subfreezing temperatures. When pos-check with the respirator manufacturer regarding the sible, respirators assigned under these circumstances compatibility of these products with their facepieces, should be non-face-sealing types (that have no exhala-tion valve) or should be a type that continues to provide

, Licensees should be aware that NIOSII requires protection to the wearer even if the exhalation valve l that facepieces used with SCBA be designed to prevent freezes in the open or partially open position.

lens fogging. This means that,in order to maintain the NIOSil certification of the device, a nose cup or some 6. SAFETY other method must be used when fogging might be a 6.1 Standby Rescue Persons l

problem.

According to 10 CFR 20.1703(f), standby rescue 5.8.2 Exhalation Valve Freezing persons must be provided when workers wear supplied air hoods or suits, possibly in conjunction with other Another potential problem when using ag 6.: of protective equipment, that are difficult to remove with-face-scaling respirator in subfreezing temperatures is out assistance. Such standby rescue persons must be the possibility that the exhalation valve could freeze. If equipped with respiratory protection devices that are the valve freezes shut, exhaled air will be exhausted appropriate for the potential hazards, must observe or through the face-to-facepiece seal area and the - piia-otherwise be in direct communication with such work-tor wearer will be aware of the malfunction. In this cese, ers, and must be immediately available to assist them in the respirator will probably provide adequate protec-case of a failure of the air supply or any other reason that tion as the wearer exits the work area.

ner. aitates relief from distress. A sufficient number of If the valve freezes in the open position, or if ice standby rescue persons (not necessarily one-for-one) forms on a portion of the exhalation valve seat, a path is raust be available to effectively assist all users of this created for contaminated ambient air to enter the respi- type of equipment. Standby rescue persons must be suf-ratory inlet covering. If the device in use were a pow- ficiently trained or experienced to render effective as-ered air-purifying respirator or a conti e us-flow sup- sistance if needed.

plied-air respirator, it is likely that the respirator wearer 6.2 Face-to-Facepiece SealIntegrity i would not be aware of the malfunction, although the in-l ternal dose consequences of this type of failure would Anything in the face-to-facepiece seal area of a probably be limited. tight-fitting respirator that is under the control of the respirator user is prohibited by 10 CFR 20.1703(h).

If the device in use were a pressure-demand Materials in this area might ir.terfere with the seal of the supplied-air device (e.g., air line-supplied or SCBA), it respirator, might prevent proper exhalation valve func-is likely that the respirator weerer would recognize that tion, or might impair the operation of a facepiece-a malfunction had occurred since air would leak out of mounted air regulator. The list of prohibited materials the facepiece through the exhalation valve. Even includes (but is not necessarily limited to) facial hair of ,

though the wearer would ecmtinue to be adequately pro- any kind in the seal area (the worker must be clean- I tected, he or she should exit the work area immediately shaven), hair from the head intruding into the seal area, since a respirator malfunction has occurred. If the de- cosmetics, spectacle temple bars, protective clothing, vice in use is a SCB A, the duration of the air supply will and equipment. A respirator wearer should not be re-be reduced because of the loss of breathing gas from the quired to shave more than once during each 12-hour supply cylinder. pe 6 d.

8.15 - 18

6.3 Un ssessed Environments The quality of the air delivered to all atmosphere-(3 For entry into areas where the level of hazard has supplying respirators must meet the requirements of Grade D air for breathing air systems as defined in CGA

(") notconditions, been assessed because of the existence or in response to unanticipated releases of of unusual G-7.1-1997," Commodity Specification for Air"H (10 radioactive material, the licensee must use only SCBA CFR 20.1703(g)).

operated in the pressure-demand mode. The use

• Intake points for breathing air compressors should SCBA to circumvent the pre-exposure sampling be located and protected in such a way as to prevent air-requirement (10 CFR 20.1703(c)(1))is not permitted borne contaminants from being drawn in.

for nonemergency activities.

6.5.3 Moisture Content in Breathing Air Cylinders 6.4 Ernergency Escape OSilA requires (29 CFR 1910.134(i)(4)(iii)) that For emergency escape from normally safe environ- the moisture content in breathing air cylinders, in addi.

ments, where a respiratory hazard might develop sud- tion to the Grade D requirement, does not exceed a dew denly, any type of device authorized for use in Appen- point of-50 *F(-45.6 *C) at one atmosphere pressure.

dix A may be used as long as it provides adequate CGA G-7.1-1997 states that air in SCBA cylinders short-term protection against the type of hazard that should not exceed a dew point of-65 *F(24 ppm v/v),

might be encountered. or 10 *F lower than the coldest temperature expected in the area where the SCBA will be used. NRC requires 6.5 Barathing Air Quality compliance with the OSilA requirement (29 CFR 1910.134(i)(4)(i)) for all cylinders and suggests meet-6.5.1 Breathing Air Systems ing the CGA G-7.1-1997 Grace L requirement for moisture content, if practical.

The breathing air supply system used by licensees may be either a dedicated system or a multi-purpose air 6.5.4 Testing Frequency

[] system. While a dedicated breathing air systera with The air from compressors that furnish breathing air

!Q non-cil-lubricated compressors has its advantages, the to an in-plant header used as a breathing air supply only requirement (10 CFR 20.1703(g))is that air of the should be tested periodically. The time interval be-minimum quality specified below be delivered to each tween tests should be reasonable under the circum-supplied-air respirator. Licensees are cautioned, how- stances and conditions of use. For example, combina-ever, to avoid ccmtaminating the internals of the system tion breathing air / service air systems that are in used for breathing air. This includes both radiological continuous or daily use should be tested at least and non-radiological contaminants. There are two pri- monthly; whereas a dedicated breathing air system with mary ways in which air systems become contaminated: a non-oil-lubricated compressor need only be tested allowing contaminants to be drawn into the compr:ssor quarterly. Breathing air systems that are only used peri-intakes and ccmnecting the air system to a contaminated odically should be tested immediately prior to use, then system which then reaches a higher pressure than the air periodically during use.

system and causes contaminated fluid to flow into the I air system. The air from compressors used to supply breathing air to cylinders should be tested periodically. This ap-l Air pressure or flow gauges used to show com. plies to cylinders filled by the licensee and to those f pliance with NIOSil certification requirements should filled by a vendor. If the airis tested and shown to meet i be calibrated at regular intervals consistent with the cal. the quality criteria at the beginning of the filling pro-

! ibration frequency of other similar gauges at the facil. cess,it is reasonable to assume that cylinders may be ity. Calibration annually and after gauge repair is rea. filled for the following 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> without retest. Other sonable. reasonable retest periods may be acceptable.

. . 6.5.5 Test Methods Quick disconnects and other breathing air cou.

plings should be incompatible with outlets for non- The test methods described in CGA 7.1-1997 are

,[3 respirable air or other gas or fluid systems. Breathing acceptable to the NRC staff. Licensees who perform

() air hoses may not be used for any other purpose. No as- weekly or more frequent air quality tests should use de-phyxiating substance may be introduced into any lines H Available from the Compressed Gas Association. Inc.,1235 Jefferson used for breathing air. Daus th 8hway, Arbngton VA 22202.

8.15 - 19

tector tubes filled with colorgeactive chemicals sensi- will meet the basic program requirements for an tive to the various possible contaminants. The breath- OSilA-regulated respiratory protection program de-ing air should be tested two to four times per year using scribed in 29 CFR 1910.134. This is intended to relieve more rigorous analytical methods (e.g., gas chromatog- licensees of the burden of developing and maintaining raphy). two parallel respiratory protection programs to comply 6.5.6 Sampling Breathing Air for with OSIIA and NRC requirements. Radiological con- j Radiological Contamination siderations rue incorporated into the NRC-regulated i program to achieve full compliance.

When breathing air supply manifolds are perma-Minor differences between NRC and OSIIA respi-nently or temporarily located inside contaminated or ratory protection requirements are described below airborne radioactivity areas, covers or caps should be along with the resolution of orjustification for the dif-used to protect them from contamination. Wipe sam-ference. The NRC requirements that are not in full pies should be taken at the air connection points prior to agreement with OSIIA rules are not likely to place any attaching a respirator supply hose. The breathing air significant burden on licensees.

should be sampled periodically far radiological con-taminants.

OSIIA's 29 CFR 1910.134(c)(2) permits individu-

! als to provide their own respirators for voluntary 6.5.7 Oxygen Purity Requimments use. While this is not specifically prohibited in an When any respiratory protection device uses an ox- NRC program, contamination control issues would ygen supply rather than an air supply (e.g., closed- rec mmend against this option.

circuit SCBA), that oxygen must meet the United

• OSIIA exempts voluntary wearers of filtering face-States Pharmacopoeia requirements for medical or pieces (dust masks) from all program require-breathing oxygen. ments, but such volunteers must be provided with the information cor.tained in Appendix D to 29 6.6 Use of liigher or Lower APFs CFR 1910.134. NRC differentiates between dis-According to 10 CFR 20.1705, licensees may ap- p sable filtering facepieces (no APF) and half-ply to the NRC for permission to use higher APFs than f cepiece respirators (APF = 10), which include those specified in Appendix A to 10 CFR Part 20. Such certain filtering facepieces. This distinction is de-applications should describe the situation for which the scribed in Regulatory Position 4.7 and 4.8 of this higher APFs are needed and should demonstrate that guide. NRC only peimits voluntary use of smgle-the respiratory protection equipment proposed pro- use disposable filtering facepieces and exempts vides these higher protection factors under the intended sud voluntary wearers fmm me repements for medical screening and fit-testing, but still requires conditions of use. This demonstration should be based on either licensee testing or reliable test informatmn. that minimal training be provided, including how to don and use the facepiece effectively. This train-Licensees may use APFs lower than the ones listed ing requirement is compatible with OSIIA's 29 in Appendix A to 10 CFR Part 20 without notifying or CFR 1910.134 Appendix D.

obtaining approval from NRC.

• OSIIA's 29 CFR 1910.134(d)(1)(i) requires that,if 6.7 Limiting Duration of Respirator Use the employer cannot identify or reasonably esti-mate the employee exposure, the employer must Licensees should establish reasonable limits on the consider the atmosphere to be IDLil (immediately length of time that individuals are required to work dangerous to life or health). This leads to very spe-while using respirators (10 CFR 20.1703(c)(4)(ix)). cific requirements in 29 CFR 1910.134(d)(2) for The NRC recognizes that such limits will vary consid- the assignment of respirators. The term IDLII does etably and will depend on a variety of factors such as not realistically apply to airborne radioactivity but tempetarire and humidity in the work area and the type could apply to certain nonradiological hazards at an of respiratar being used. Limits may be based on input NRC-licensed facility, in which case OSIIA rules from medical personnel and from experienced respira. apply. Such nonradiological hazards include tor users. Additional guidance for limiting duration of oxygen-deficient environments (e.g., inerted struc-respirator use is provided in NUREG-0041. tures and vessels), chemical hazards (e.g., chlorine, hydrazine), and fire fighting.

6.8 OSIIA Requirements OSilAt 29 CFR 1910.134(d)(1)(iv) requires the Licensees whose respiratory protection programs employer to select respirators from a sufficient fulfill the requirements of Subpart fl of 10 CFR Part 20 number of respirator models and sizes so that the 8.15 - 20 l

respirator is acceptable to, and correctly fits, the by the ticensee's physician before being designated i user. While NRC requires that respirator wearers as medically qualified to use respirators. Precisely

, demonstrate an adequate respirator fit, no specific how this additional evaluation is accomplished is a i

(' ) requirements are placed on licensees regarding the medical decision to be made by the licensee's phy-(j provision of respirators in various sizes and from sician and does not necessarily have to include per-several different manufacturers. The NRC ap- sonal contact with the person being screened.

proach permits exercise of the licensee'sjudgment with respect to how many different devices and OSIIA's 29 CFR 1910.134(e)(2)(i) requires that sizes to provide. Additionalinformation about this medical evaluations obtain all the information re-requirement, which is repeated in ANSI quested in Sections 1 and 2 of Part A of OSilA's Z88.2-1992,is in Regulatory Position 7.3 of this medical questionnaire, which is Appendix C of the guide. OSIIA rule. NRC permits, but does not require, the Appendix C questionnaire to be used in medical OSIIA does not currently promulgate APFs for res- screening programs.

pirators but reserves the ability to do so (29 CFR

• OSIIA's 29 CFR 1910.134(e)(6)(ii) requires that a 1910.134(d)(3)(i)(A) and Table I). The maximum .

APFs that may be used in an NRC-regulated pro- p wered air-purifym.g respirator (PAPR) be pro-gram are listed in Appendix A to 10 CFR Part 20, vided to a worker whose physical condition does and these are consistent with the APFs listed in not allow the use of a negative-pressure device.

ANSI Z88.2-1992. NRC places no such requirement on licensees, but the OSilA approach is an acceptable option under OSIIA's 29 CFR 1910.134(d)(3)(iii) requires the the NRC rules.

employer to provide specific types of respirators

• for protection agamst gases and vapors. In an NRC,- OS11A's 29 CFR 1910.134(f)(7) requires a fit fac-regulated program, exposure to radioactive nobl tor of at least 100 for tight-fitting half facepieces gases is not considered a sigmficant respiratory and at least 500 for tight-fitting full-facepiece res-hazard, and protective actions for these contami- pirators. NRC requires 10 times the APF for negative-pressure devices (i.e.,100 for half face-nants should be based on external (submersion) pieces,1000 for full facepieces), and 500 for tight-dose considerations. Respirators do not necessarily V) have to be assigned for protection agamst airborne radioiodine vapors since personnel dose can be fitting respirators that will operate in a positive pressure mode in the field.

controlled by limiting stay times or by other meth-

• OSIIA's 29 CFR 1910.134(h)(3) requires that all ods. Airborne tritium gas and tritiated water vapor respirators maintained for use in emergency situa-are not effectively removed by air-purifying respi- tions be inspected at least monthly and in accor-rators, so APFs do not apply for these devices for dance with the manufacturer's recommendations, protection against tritium. The APF of atmosphere- and be checked for proper function before and after supplying respirators is reduced to 3 for protecLc.; each use. It also contains other specific require-against airborne tritium since approximately one- ments. NRC suggests a monthly visualinspection third of the intake occurs by absorption through the of SCBAs and a quarterly operational test (i.e.,

skin.

pressurizing the regulator, testing the low-pressure

• alarm). Other devices stored for emergency use l OSilA's 29 CFR 1910.134(e)(2)(i) permits a "phy-should be visually inspected monthly, but unc'er sician or other licensed health care professional (PLIICP)" to set up, administer, and make medical NRC guidance only need to be thoroughly ex-l 1 amined 2 or 3 times per year. It is suggested that li-decisions about the medical status of potential res-censees also consider manufacturers' recommen-pirator users, and it ccmtains a number of prescrip-dations in establishing their inspection schedule.

tive requirements. In an NRC program, a physician (the licensee's physician) must set up or approve

• OSIIA's 29 CFR 1910.134(i)(5)(iii) requires that the tredical screening program for respirator wear- suitable in-line air-purifying sorbent beds and fil-I ers and set the medical acceptance criteria. A li- ters be used on the intakes ofbreathing air compres-censed health care professional may carry out the sors, and that they be maintained and replaced or a

screening process and medically approve as respi- refurbished periodically following the manufactur-rator users those who fall within the acceptance cri- er's instructions. NRC requires only that air of (O) teria established by the licensee's physician. Ilow-ever, the individuals who fall outside the Grade D quality, described in CGA G7.1, be deliv-ered to each supplied-air respirator.110w that is ac-established acceptance criteria must be evaluated complished is left to the licensee.

8.15 - 21

l OSilA's 29 CFR 1910.134(i)(7) requires the pres- D. IMPLEMENTATION {

ence of a high-temperature alarm or a carbon mon-oxide alarm on the discharge of oil lubricated breathing-air compressors. As stated above, NRC The purpose of this section is to provide informa-requires only that breathing air of Grade D quality tion to applicants regarding the NRC staff's plans for be provided, using this regulatory guide.

Licensees are reminded that OSHA hazard-specific regulations, many of which are listed in Ap- Except in those cases in which an applicant pro-pendix A to this guide, may contain requirements for poses an acceptable alternative method for complying using respiratory protection equipment and for moni- with specified portions of the NRC's regulations, the f toring or controlling workplace hazards that might methods described in this guide will be used in the eval-occur separate from or concurrr itly with airborne ra- uation of respiratory protection programs described in a diological hazards. Some of these hazards to be consid- licensee's operating procedures, applications for new ered are heat stress, oxygen deficiency, chemical toxic- licenses, or license amendments and for evaluating ity and confined spaces. compliance with Subpart 11 of 10 CFR Part 20.

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8.15 - 22 1 ,____-__A

APPENDIX A OSIIA Regulations e The sections of the OSIIA regulations listed below, among others, may

(' ccmtain requirements that are in addition to those required by the NRC.

They may also contain requirements for limiting or controlling hazards that are not under thejurisdiction of NRC.

29 CFR 1910.120 Hazardous Waste Operations 29 CFR 1910.134 Respirato.y Protection-General Industry 29 CFR 1910.146 Permit Entry Confined Spaces 29 CFR 1910.155 Fire Protection 29 CFR 1910.401 Commercial Diving Operations 29 CFR 1910.10(K) Air Contaminants (PELs) 29 CFR 1910.1001 Asbestos 29 CFR 1910.1025 Lead 29 CFR 1910.1028 Benzene 29 CFR 1910.1048 Formaldehyde 29 CFR 1926.103 Respiratory Protection-Construction Industry

, REGULATORY ANALYSIS A separate regulatory analysis was not prepared for this regulatory guide.

The regulatory analysis," Regulatory Analysis of Proposed Revisions to 10 CFR Part 20, Subpart 11, Respiratory Protection and Controls To Re-strict Internal Exposure," was prepared for the amendments, and it pro-vides the regulatory basis for this guide and examines the costs and bene-fits of the rule as implemented by the guide. A copy of the regulatory analysis is available for inspection and copying for a fee at the NRC Public Document Room,2120 L Street NW. (Lower Level), Washington, DC, as Enclosure 2 to SECY-99-207.

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