Combining respirator protection factors during lead blasting

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

February 26, 1996

Mr. David S. Abrams
Clayton Environmental Consultants
[Recipient address omitted]
Dear Mr. Abrams:

This is in response to your letter to the Occupational Safety and Health Administration (OSHA) requesting an interpretation on respirator use under the Interim Final Rule for Lead in Construction, 29 CFR 1926.62. Your request for an interpretation pertains to the use of a tight fitting, air purifying, negative pressure half mask respirator, equipped with HEPA filters in conjunction with a Type CE, abrasive blasting hood, and whether the assigned protection factors (APF) for these respirators can be combined for a higher APF. Please accept our apology for the long delay in our response.

The provision at 29 CFR 1926.62(f)(2)(iii) states ..."The employer shall select respirators from among those approved for protection against lead dust, fume, and mist by the Mine Safety and Health Administration and the National Institute for Occupational Safety and Health (NIOSH) under the provisions of 30 CFR part 11." Under the provisions of 30 CFR part 11, Type CE abrasive-blast respirators are the only respirators approved for use in abrasive-blasting operations. The models of Type CE abrasive-blast respirators certified under 30 CFR part 11 are: (1) a continuous-flow respirator containing a loose-fitting hood with a protection factor of 25; (2) a continuous-flow respirator containing a tight-fitting facepiece with a protection factor of 50; (3) a positive pressure, supplied-air respirator containing a half-facepiece with hood with a protection factor of 1000; and (4) a positive pressure, pressure-demand respirator containing a tight-fitting full-facepiece with a protection factor of 2000.

The combination of a tight-fitting, air purifying, negative pressure, half-faepiece respirator with the Type CE, abrasive-blast respirator was never approved by NIOSH under 30 CFR 11. OSHA requires NIOSH certified respirators per 29 CFR 1926.62(f)(2)(iii). Use of non-certified respirators is a violation.

APFs have been determined through rigorous test procedures implemented under 30 CFR 11 by NIOSH. Assignment of protection factors is not an arbitrary procedure, such as multiplying the APF of two respirators used in combination, to achieve a higher APF. If you wish to have the unit of a tight-fitting, air purifying, negative pressure, half-facepiece respirator used in conjunction with a Type CE, loose-fitting, abrasive-blast respirator considered for certification by NIOSH as an abrasive-blast respirator, then you must apply for approval and submit all respirator components as required by NIOSH. NIOSH certifies respirators under 42 CFR 84, now. Please bear in mind that NIOSH issued new respirator certification regulations at 42 CFR 84 in July, 1995.

On August 30, 1995, OSHA implemented an interim enforcement policy change for respiratory protection required for abrasive blasting under 29 CFR 1926.62, the Interim Final Rule for Lead in Construction. This interim enforcement policy change accepts an APF to 1000 for the E.D. Bullard Company's Type CE, abrasive-blast respirators, Models 77 and 88 only when they are used under specific conditions. This change only applies to 29 CFR 1926.62 and it is effective until a final determination by OSHA is made of the proper protection factor to be assigned this class of respirators. A copy of this enforcement policy change is enclosed for your information.

Thank you for seeking clarification on this issue and for your interest in safety and health in the workplace.

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

Enclosure

[Requester letter reproduced on OSHA page; omitted here.]