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.
*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).