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Changes in Respirator Testing Requires Changes by Pesticide Applicators

 

Changes in Respirator Testing

Requires

Changes by Pesticide Applicators.

 

 

By Ronald D. Gardner

Pesticide Management Education Program

Cornell University

 

Not too long ago the Worker Protection Standard was enacted and it required significant changes in pesticide labels. One of those changes that clearly helped applicators, was that more specific respirator requirements were added. These requirements clearly listed, by designation, the respiratory protection device required for protection of the pesticide applicator. We all know the adage the "label is the law" meaning that if the label says to wear a TC-21C respirator while mixing and handling a pesticide that that is the only legal respirator to use. But, what if there are no TC-21C respirators to be found? Then what? It seems that changes made by the federal agencies charged with protecting our health will make the situation described above not a fantasy but a reality. But please, don’t panic or start writing your Congressman, just read on and find out how this transition from old to new will be made.


What Changes Were Made and Who is Responsible

The National Institute of Occupational Safety and Health or NIOSH is the government group that tests safety devices such as respirators. In July 1995, NIOSH upgraded the tests used to certify non-powered particulate respirators. This upgrade replaces the old standards established under 30 CFR Part 11, with new standards found in 42 CFR Part 84. So Part 11 respirators were certified under "old" standards, and Part 84 respirators were certified under the new standards. The major differences are in the resistance of the respirator to oil and better removal of small particles. Part 84 respirators will be designated as "N" (no oil), "R" (oil-resistant for 8 hours) or "P" (oil-proof may last longer than 8 hours). This means that "R" and "P" Part 84 respirators assure that oils will not degrade filter efficiency. Part 84 respirators will also have a better particle collection efficiency, down to the 0.3 micron range. They will do a better job than Part 11 respirators in filtering out smaller particulants such as mold spores or silica. Part 84 respirators will have an efficiency designation of 95, 99 or 100. A type 95 is 95% efficient while a type 99 is 99% efficient and the type 100 is the most efficient and equivalent to the old HEPA filter. The type 100 respirators will be designated "HE" (high efficiency) and will be used with powered air-purifying respirators.

There are also changes in terms and product names that will become familiar to us over time. The old term "dust/mist" respirator will now be replaced with "filtering facepiece" respirator. They may also go by the designation TC-84A. Organic vapor (OV) removing cartridge respirators once designated TC-23C will still have the same name, but they will list which filters or prefilters can be used, such as N, R or P. The color coding of organic vapor cartridges will not change. They will still have white letters on a black background.


Who is Affected and What Impacts Will These Changes Make?

You are! Particularly if you currently use a NIOSH-approved non-powered air-purifying respirator specified on a pesticide label. This includes dust/mist masks and organic vapor-removing cartridge respirators with a pre-filter approved for pesticides. During the last year, respirator manufacturers have been making the new Part 84 respirators. As of July 10, 1998, the manufacture of the older Part 11 respirators has stopped. Don’t throw out the old respirators though, because EPA will still allow you to use them. Also, it is okay to buy a new Part 84 respirator!

EPA issued a policy statement May 7, 1998 in the Federal Register (Vol. 63, No. 88) and stated that all of the new respirators (Part 84) meet or exceed all of the standards for the old ones (Part 11). Therefore, EPA will not initiate enforcement actions against applicators who merely substitute the new respirator for an old one, even if the label specifies the old respirator. Although pesticide labels have not yet changed to reflect the new NIOSH designations, they will in the near future. The new labels will have both the old Part 11 and the new Part 84 designations. Later, when supplies of old respirators is gone, EPA will have labels changed again to list only the Part 84 designations. So, you can continue to use your old particulate respirators, filters and pre-filters until you are ready to purchase new ones. Respirator manufacturers estimate they may have three years of inventory in the channels of trade. So, sales and use of older respirators will not be impacted, until the supply is gone. For powered air-purifying respirators, HEPA filters will remain available. The appropriate designation under the new Part 84 rules would be a type 100.


Will There be Changes in Selecting a New Respirator?

Yes. There are three new questions that must be answered when selecting a Part 84 respirator. They have to do with selecting the type of filter and the efficiency of that filter. Here is a table that sketches out the basics.

 

Question

 

Yes

 

No

Does the chemical, formulation or tank mix contain oil?

Choose "R" or "P" filter or pre-filter.

Choose either an "N", "R" or "P" filter or pre-filter.

Will the respirator be used more than 8 hours with an oil-containing chemical?

Choose a "P" filter or pre-filter.

Choose an "R" or a "P" filter or pre-filter.

The third question "Which filter efficiency do I choose?," requires a little discussion. For all practical purposes, there are two choices the type 95 and the type 100, because most manufacturers probably will not make both the type 99 and 100, but only the 100 or HE filter or pre-filter. As a general, rule types 95 and 100 are both good for most pesticide uses so they are both good choices. When the job requires a HEPA or type 100 respirator the selection should then be the "HE" or type 100.

The following tables summarise the changes gone over here and perhaps will help to understand the new designations. These changes are for the better. Better particle removal, better oil resistance and better protection for you the respirator user.


Nine choices based on filter class and efficiency.

 

Filter Class\Efficiencies

 

95%

 

99%

 

99.97% (100%)

 

N-series (not resistant to oils)

 

N95

 

N99

 

N100

 

R-series (resistant to oils for up to 8 hours)

 

R95

 

R99

 

R100

 

P-series (oil proof)

 

P95

 

P99

 

P100

 


Example uses of new respirator designations

 

Pesticide & paint pre-filters

 

R95

 

Dust/mist disposable masks

 

N95 & R95

 

HEPA Filters

 

P100

 

Oil Dust Masks (with time limit)

 

R95

 

Oil containing pesticides or paints (no time limit with organic vapor cartridge)

 

OV/P100

References:

Jeffery C. Camplin. "Understanding OSHA’S New Respiratory Standard," Compliance Magazine, May, 1998, pp. 34-35.

Cummings, Mary-Lynn. Associate Director for Research, Office of Research, Cornell University. Personal Communication. July, 1998.

US EPA. "Labeling Requirements for Pesticides; Respirator Compliance Policy Statement." Federal Register, Vol. 63, No. 88, May 7, 1998, pp. 25168-25169.

"EPA Update/Respirators," Gempler’s Alert Newsletter, Vol. 5, No. 6, June 1998, pp. 3 and 5.

Grieger, Jim. Office of Environmental Health and Safety, Cornell University. Personal Communication. July, 1998.

Jones, Judy. Past Associate Director for Research, Office of Research, Cornell University. Personal Communication. July, 1998.

Miles, John B. Jr., Director of Compliance Programs, "OSHA Memorandum — Particulate Respirators Certified 1996 under 42 CRF Part 84."

Smith, Judy. New NIOSH Certification of Respirators. Personal Communication via the Worker Protection Standard Forum (wps-forum@are.berkely.edu). 1998.

Shelly, Thomas. Office of Environmental Health and Safety, Cornell University. Personal Communication. July, 1998.

Verine, Jennifer L. Office of Environmental Health and Safety, Cornell University. Personal Communication. July, 1998.