by Eileen Senn, MS
In their new respirator recommendations discussed in my July 1 post, OSHA and NIOSH allow, but do not recommend, the voluntary use of filtering facepiece respirators (dust masks) for Gulf spill workers “when an individual is bothered by non-hazardous levels of hydrocarbon odor and cannot be relocated to another work area.” Such hydrocarbon odors are most likely offshore near the leaking oil, burning oil, and dispersant and other chemical applications.
BP has had such a policy on the voluntary offshore use of respirators since the oil spill began. The BP policy states: “3M 8577 P-95 masks are available for nuisance odors and can be used up to 100 ppm VOCs (Volatile Organic Compounds) and 0.5 ppm benzene.”
The mask in question, the 3M 8577, P95 particulate respirator with nuisance level organic vapor relief, is NIOSH-approved for protection against oil and non-oil based particles, and is rated 95% efficient against all particulate aerosols. It is not NIOSH-approved for protection against organic vapors. The manufacturer states that
“Nuisance level organic vapor relief refers to concentrations not exceeding OSHA PELs or applicable government occupational exposure limits, whichever is lower.”
This disposable dust mask is lightweight and has an exhalation valve to make breathing out relatively easy. Therefore it creates less physical stress than more substantial respirators. They’re inexpensive: about $5 apiece.
The good news is that NIOSH and OSHA recognize that Gulf cleanup workers who do not qualify for respirators under the new NIOSH/OSHA recommendations may nevertheless want protection from airborne contaminants. The dust mask will protect workers from particulate associated with cleanup, for example, oil mist and some components of diesel exhaust and burning oil. Because it has a small amount of charcoal in the facepiece, it may reduce odors and symptoms like nose and throat irritation. Unfortunately, all the rest is bad news.
First, because it is not approved for organic vapors, this dust mask presumably will remove only small amounts of hydrocarbon vapors, so workers may still be exposed to them.
Second, this dust mask is unlikely to protect against other symptoms being experienced by Gulf spill workers, for example, eye and skin irritation, dizziness, rapid heart rate, headaches, confusion, and nausea.
Third, without excellent training, this dust mask may give workers a false sense of being protected from the volatile hydrocarbon components of crude oil, dispersants, and other chemicals used in the cleanup. With a false sense of security, Gulf spill workers may be less likely to avoid exposure by distancing themselves from exposure sources and using good work practices.
Fourth, this dust mask could increase workers’ exposures by collecting oil mist and holding it over their nose and mouth where vapors may pass through the facepiece, despite the small amount of charcoal impregnated there.
Fifth, voluntary use leaves the decision on the provision of respirators to the discretion of the employer/contractor/subcontractor. Few cleanup workers will dare to voluntarily ask for a respirator. They will justly fear making themselves the target for retaliation.
Finally, OSHA does not require fit-testing when respirators are used voluntarily. (See p.24, Q#3) Therefore, there is no guarantee the dust masks will fit workers. Even well-fitted respirators like these leak up to 10%; ill-fitting respirators are likely to leak even more.
It seems that sensible OSHA respirators rules, especially those requiring fit-testing and medical clearance before wearing one, are considered too much trouble in the Gulf, and so exceptions are being exploited. Filtering facepiece respirators have the most exemptions, including immunity from fit-testing, medical clearance, and written respirator programs. These exemptions appear to by why first BP, and now OSHA and NIOSH have seized on them.
Exceptions to the OSHA respirator standard provide that employers who allow their employees to wear respirators on a voluntary basis, when not required by OSHA or the employer, must implement limited provisions of a respiratory protection program. When a filtering face piece respirator is all that is used, the employee must be provided a copy of Appendix D. For more substantial types of respirators, a written respirator program that covers medical fitness and proper maintenance procedures must be implemented.
BP, OSHA, and NIOSH are shortchanging these workers by allowing them to be provided with a dust mask. There are many models of more protective disposable, limited-use, and reusable respirators that are approved for both organic vapors and particulates. Gulf spill workers who want to voluntarily wear a respirator deserve an appropriate one, such as those approved for both organic vapors and particulates. The 3M 5000 Series⢠Disposable Respirators come in three sizes and cost about $25 each. Using them, however, does require medical clearance. Unfortunately, it looks like they have been rejected for voluntary use because they are too much trouble.
Eileen Senn is an industrial hygienist who has performed occupational health work for government and unions for 40 years. She was an OSHA industrial hygiene inspector in Philadelphia for eight years in the 70s and 80s. She directed an OSHA New Directions training grant from 1979 to 1981. She worked in occupational health surveillance for the state of New Jersey from 1986 to 2002. She has been an Independent consultant for the past eight years. She is perhaps best known for her seminal article, Playing Industrial Hygiene to Win.
Notes:
*See: Q&A on the OSHA Respirator Standard p. 24, question #3)
See here for a full text of the voluntary use exemptions in OSHA’s respiratory protection standard, starting with 1910.134(c)(2).
Is there any information that shows the need for an elastomeric facemask for these workers? If so, who is going to make sure they are medically fit to wear them? If they are not, they could be at significant risk of heart disorders, e.g. if they are smokers or have other lung disoreders. Who is going to make sure they fit properly and workers know how to use them? Who is going to make sure they are properly trained? Who is going to make sure they are wearing them properly and consistantly (even 10 minutes of non-use per hour eliminates any effectiveness)? How will use be compromised by the need to constantly hydrate or the need to communicate? Unless there is real evidence that they are necessary, I am not convinced they would help protect workers in the Gulf.
If these respirators are being used, NIOSH must test them to describe their characteristics. It’s likely that elimination of odors by the respirator is equivalent to capture of organic vapor. Some quick work in the laboratory would change the “may’s” to will or will not.
NIOSH and OSHA have addressed these important questions in a number of documents, Scott, which can be accessed at http://www.cdc.gov/niosh/topics/oilspillresponse/. They do recommend elastomeric respirators for the offshore Gulf cleanup workers closest to the crude oil, including those drilling relief wells, applying dispersant, and providing support and supplies. While elastomeric respirators are not generally recommended for onshore and nearshore workers, there are exceptions for workers if they are near to or downwind of burning oil, far from shore, performing high pressure washing, cleaning fresh crude oil from wildlife, or experiencing symptoms or health problems.
Please answer the question: who is going to assure effective use if workers voluntarily use elastomerics?
The OSHA Respirator Standard requires employers to do that, Scott, even when respirators are used voluntarily. 1910.134(c)(2)(ii) states: âIn addition, the employer must establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.â
That still doesn’t deal with the very real problem of workers removing their respirators to talk, hydrate or because of discomfort.
There’s no doubt that hazard situations that require workers to wear respirators to protect their health creates challenges both for the workers and employers. That’s nothing new for all kinds of workplaces. The challenges with the clean-up in the Gulf are not insurmountable—-remember BP has vast resources and we have agencies who say they are on their toes to make sure that BP does what is needed. The President says BP will pay the bill—there’s no reason that bill should have some serious money for worker H&S for the clean-up crews.
I agree with Eileen, the OSHA regs are clear–it’s the employers responsibility to have an effective respiratory protection program. If that means that BP has to hire more H&S professionals to ensure respirators are fitted and worn properly–so be it. If that means they need 1, 5, 10 H&S people at every staging site–so be it. If OSHA finds that they have not implemented an effective respiratory protection program—they should be cited. If BP or their contractors need more personnel to make sure their H&S procedures are being followed, they should hire them.
If the respirators have to be removed by workers every 30 minutes for rest breaks—and the H&S personnel have to make sure the devices are clean and put on properly again—so be it. If that’s what needs to be done, that’s what needs to be done. Our government said that BP is paying the bill for the clean-up. We should demand and keep pressing that the workers involved in the clean-up get top-notch protection, not some scaled back version because this situation is unique. Because it’s unique—and BP is paying the bill—we should demand nothing less than top notch protections. If there are workers who are not medically able to wear respiratory protection, then they should not be assigned to do work that may require respiratory protection. If that means they can’t do the clean-up work, so be it. If these are fisherman or other workers who have lost their primary source of income because of the spill, and they can’t do the clean-up work, they should demand just compensation from BP for their losses—-not be forced (or encouraged) to put their health at risk by doing a job they are not fit to do, or doing a job where the regular health and safety regs are not being followed because it’s just too complicated.
I agree there are many problems associated with respirator use. Iâd rather see exposures controlled through engineering and administrative controls and there should be more of that happening in the Gulf. But fortunately or unfortunately, appropriate respirators are still necessary at this time, despite their many shortcomings.
That is the key question: Are they necessary and for whom?
It is interesting to note that in the UK these devices are only advised for a maximum of two hours use as the protection factor data was produced from short-term studies. In addition, they would not be considered for use against some of the components of crude oil that may have irreversible effects.