In a simpler time, buying respiratory protection for your department meant finding the best price for SCBA units that would provide breathable air for firefighters when exposed to the smoke and fire gases of ordinary (Class A) combustibles.
Today, fire chiefs and their staffs have to look at providing respiratory protection for a far greater number of hazards. Those hazards can range from burning plastics and other carbon-based synthetic materials to the chemical, biological, radiological and nuclear threats from terrorists.
There are a host of respiratory products on the market today — SCBA, Air Purifying Respirators (APR) and Powered Air Purifying Respirators (PAPR) — that meet or exceed the equally large host of applicable rules, regulations, standards and guidelines that manufacturers have to comply with.
But how familiar are you and your staff with those requirements that can have an effect on your purchasing decisions? If your answer is “not very,” you’re not alone. So here’s a look at how to make sense of the rules of the road for respiratory protection.
HAZWOPER
The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), Title 29, Code of Federal Regulations, Part 1910.120 was the first global document that outlined proper emergency response to hazardous material release incidents.
Personal protective equipment guidelines, including those for respiratory protection, were first defined in Appendix B of the HAZWOPER standard as OSHA/EPA Protection Levels A, B and C.
- Level A: Use where the hazards are unknown or unquantifiable or when the greatest level of skin, respiratory and eye protection is required.
- Level B: Use where the highest level of respiratory protection is necessary, but a lesser level of skin protection is needed.
- Level C: Use where the concentrations and types of airborne substances are known and the criteria for using APR/PAPR are met.
Using these general levels of protection does not ensure that the wearer is adequately protected from CBRN-specific hazards. The HAZWOPER standard itself states that the generic descriptions of the equipment do not fully address the performance of PPE in relationship to specific needs.
Relying solely on PPE being marketed on the basis of OSHA/EPA PPE levels could result in exposure levels above acceptable limits, or an unnecessary reduction in operational effectiveness through lack of mobility, decreased dexterity or reduced work duration.
Currently, no single ensemble can protect the wearer from exposure to all hazards. It is important that the appropriate combination of respirator, protective ensemble and other equipment be selected based on a conclusive hazard assessment at the scene.
The National Institute for Occupational Safety and Health developed seven performance-appropriate standards and test procedures for all classes of respirators that will provide respiratory protection from CBRN agents.
The following also provides comparison information to assist in transitioning from OSHA/EPA Levels A, B, and C to standards-based terminology. Because the OSHA/EPA levels are expressed in general terms, it is not possible to map the levels to specific standards. However, it is possible to look at specific standards-based ensembles and establish their level based on the standards defined below.
1. NIOSH Statement of Standard for CBRN Open-Circuit SCBA
The purpose of this standard is to specify minimum requirements to determine the effectiveness of open-circuit, positive-pressure SCBA used during entry into a CBRN atmospheres at or above immediately dangerous to life or health, or entry into unknown atmospheres.
- Approval under NIOSH 42 CFR Part 84, Respiratory Protective Devices, Subpart H.
- Compliance with NFPA 1981 Standard on Open-Circuit Self-Contained Breathing Apparatus for Emergency Services Special Tests under NIOSH 42 CFR 84.63(c).
- Chemical Agent Permeation and Penetration Resistance Against Distilled 1. Sulfur Mustard (HD) and Sarin (GB) Laboratory Respirator Protection Level 2.
2. NIOSH Statement of Standard for CBRN Full Facepiece Air-Purifying Respirator
The purpose of this standard is to specify minimum requirements to determine the effectiveness of full facepiece APR and PAPR used during entry into non-IDLH CBRN atmospheres.
3. NIOSH Statement of Standard for CBRN Power Air-Purifying Respirators
The purpose of this standard is to specify minimum requirements to determine the effectiveness of tight-fitting and loose-fitting PAPR used during entry into a non-IDLH CBRN atmosphere. NIOSH, under the authorization of the Occupational Safety and Health Act of 1970, provides a testing approval and certification program assuring commercial availability of safe respiratory protective devices.
4. NFPA 1991 Standard on Vapor-Protective Ensembles for Hazardous Materials Emergencies, 2016 Edition
The purpose of this standard is to establish a minimum level of protection for emergency responders against adverse vapor, liquid-splash and particulate environments during hazardous materials incidents and from specific chemical and biological terrorism agents in vapor, liquid-splash and particulate environments during CBRN terrorism incidents.
This standard matches OSHA/EPA Level A.
5. NFPA 1994 Standard on Protective Ensembles for First Responders to CBRN Terrorism Incidents, 2012 Edition
NFPA 1994 sets performance requirements for protective full-body ensembles used in response to CBRN terrorism incidents.
The standard defines three classes of ensembles — Class 2, 3 and 4 — based on the protection required for different hazard types (vapors, liquids and particulates) and airborne contaminant levels.
- A Class 2 CBRN ensemble protects responders from a vapor or liquid hazard where the concentrations are at or above the IDLH level and require the use of SCBA. This standard matches OSHA/EPA Level B.
- A Class 3 CBRN ensemble protects responders from low levels of vapor or liquid hazard where the concentrations are below the IDLH, permitting the use of CBRN-rated APR or PAPR. This standard matches OSHA/EPA Level C.
- A Class 4 ensemble protects responders from biological hazards or radiological particulate concentrations are below the IDLH permitting the use of CBRN-rated APR or PAPR. The CBRN requirements do not include chemical hazards, but only applies to biological agents and radiological particulates. This standard matches OSHA/EPA Level C.
6. NFPA 1951 Standard on Protective Ensembles for Technical Rescue Operations, 2013 Edition
The NFPA 1951, 2007 Edition contains performance requirements for a CBRN technical rescue protective ensemble for use during entry into non-IDLH CBRN atmospheres. This standard matches OSHA/EPA Level C.
This ensemble category defines limited protection requirements where exposure to physical, thermal, liquid and body fluid-borne pathogen hazards and CBRN agents in vapor, liquid-splash and particulate forms could be encountered.
7. NFPA 1971 Standard on Protective Ensembles for Structural Fire Fighting and Proximity Fire Fighting, 2013 Edition
NFPA 1971 includes optional protection from CBRN hazards. Only complete ensembles certified as compliant with these additional optional requirements provide this specified level of CBRN protection.
The protection levels set in the NFPA 1971 CBRN option are based on the Class 2 requirements contained in NFPA 1994. This standard matches OSHA/EPA Level B.
