In the last several weeks I have been writing about respirators and how they should be managed when NOT in use. In this article, I will be discussing respirators when we use them in emergency conditions or potentially emergency conditions. In my world of process safety management, I see a lot of misguided logic in respirator decisions that I hope to clear up with this brief article. But there is NOTHING I can say here that any reader should not CONSULT with their respirator program administrator before acting upon it.
Let’s first examine the logic that many organizations subscribe to… “respirator must be on your person” while conducting highly hazardous activities. Line break or process opening tasks seem to be the most abused use of this ill-fated logic (my personal opinion). It is my opinion that any “non-routine opening” of a process that contains a Highly Hazardous Chemical (HHC) or Extremely Hazardous Substance (EHS) requires the use of a Supplied Air Respirator (SAR). More on why I recommend a SAR over an Air Purifying Respirator (APR) later on. Is there anyone reading this that really believes when !@#$ hits the fan and there is a significant release the workers in the middle of it all will stop and don a respirator before they attempt to exit the area? Anyone who has witnessed a line break/process opening gone bad will attest that it does NOT work that way. SAFTENG members need only to watch the HF Release video I posted in 2012 to observe how fast things go wrong and the extremes of how we define “bad”! In that video, had the two workers been provided a SAR (and proper fall protection), they may still be alive today; without either protection, we tragically witnessed workers losing their lives and families losing their loved ones!
The idea that merely having a respirator at the worksite and not donned on the workers is ILL-FATED LOGIC and actually fits no risk profile I have ever seen or read about. I compare it to as if I am carrying my brake pads inside my car with me while driving!!! This approach just does not work! How difficult is it to require the workers performing the hazardous task(s), and those who need to be in the immediate area, to wear the PROPER respiratory protection while they are actually at risk? My practice/policy has always been they wear all the required PPE until the break/opening has been completed without incident AND the isolation methods were either blind/blank, Double Block and bleed, or Disconnect & misalignment. If all of this is in place and working as designed I would then allow the workers to lower their PPE one level (e.g., Level A to B, Level B to C, Level C to D). Notice that in some tasks workers will be in respiratory protection the entire time (i.e. A to B and B to C). Although, based on each situation, workers could request a variance to the policy if the situation warranted, the administrative controls in my variance procedures are so burdensome (purposely so) that there needs to be a large advantage with very little risk before even inquiring about getting one!
Full Face Air-Purifying Respirators as Emergency Escape Respirators
Using an Air Purifying Respirator (APR) as an “escape only respirator” is NOT a good practice and should be AVOIDED when working with those HHC/EHSs that have low IDLH levels. I will let each reader define “low IDLH,” but I use 300 ppm and lower. There are some safety personnel that will make the argument that “an APR is better than nothing” and this is a concern of mine. APRs have a significant number of limitations, and one of the top limitations is that are NOT approved for use in an IDLH atmosphere; and for GOOD REASON! Working on a 1″ line or larger containing an HHC/EHS in liquid form can create an IDLH atmosphere very quickly, which can overcome the Assigned Protection Factor (APF) of the APR and place the workers in grave danger! We too often think that workers will be able to stand up and walk calmly away from the release point, forgetting that some of these HHC/EHSs have significantly higher vapor pressures coupled with highly high expansion ratios, which translates into a vapor cloud that obscures the vision of the workers trying to escape. Throw in a blocked exit or two and a hose lying across the floor or trench grating removed, and we NOW HAVE THE SITUATION of a downed worker in an IDLH atmosphere with only an APR to protect them. Take this same situation put the workers in an SCBA and look at how the outcome could change. Sure, they may become downed or trapped, but they will be provided the HIGHEST LEVEL of respiratory protection afforded and at least have a fighting chance while they await rescue.
Emergency Escape Respirators (Escape Apparatus and mouthpiece)
The last type of respirator that I want to mention is the “emergency escape respirator.” There are two types that tend to dominate the high-risk industries: Emergency Escape Breathing Apparatus (EEBA – Constant Flow Respirators) and mouthpiece/Nose Clip style. The Constant Flow Respirators are the type that uses a clear plastic-type bag that the user places over their head, and the respirator provides a constant flow of breathing air to the bag. The Mouth Bit/Nose Clip style is just a mouthpiece that the user places between their teeth bites down, and places a “swimmer type” nose clip over their nose. BOTH of these types of respirators have inherent flaws in their applied uses, and I would like to mention them briefly.
Personally, I have never been a huge fan of either type of emergency escape respirator, but in many situations in those high-risk industries, they are a MUST-HAVE. The EEBA Constant Flow Respirators are the ONLY type of escape respirators that should be stored in high-risk locations, such as multi-level chemical processing areas. By the rule of thumb, I believe that under NO CIRCUMSTANCES should any APR be placed in emergency respirator boxes. APRs were NEVER designed or intended to be used for emergency escape, and I say this knowing that there are APR cartridges approved for “emergency escape”. Keep in mind that I can also buy EXIT signs with 3″ lettering even though all the fire codes and OSHA regulations require 6″ lettering; so, just because I can buy it does not make it correct/safe by default.
Have we ever wondered what happens when the worker on the top level of the process has to work his/her way down the stairs after the release, and the only emergency respirator available is a full-face APR? What if it is me? I wear glasses and need them for safe egress, especially in poorly lit areas. What am I and other corrective lens wear to do? We can not don the APR with our glasses on, and if we remove our glasses to don the APR, we may not be able to see to exit the area safely. I have yet to see any employer require adequate vision as a safety feature for their workers, but I have seen hundreds using APRs as their emergency escape respirators. NOTE: Some BADLY outdated codes may still require an APR to be provided for “emergencies,” and employers should seriously question a code that was written 15-20 years ago and give serious consideration to UPGRADING the available respirators to exceed these codes! The next question we should be asking about our EEBA is, “How much breathing air do I need to safely remove myself from the hazardous atmosphere”? One industry that we do a lot of work in has some rather large storage tanks, and this industry has a good practice of requiring an EEBA on your person if you have to get on one of these large tanks. The one flaw that we always come across is there is no rationale for how much air this emergency escape respirator must have, and the facility has an assortment of both 5 and 10-minute packs. We (the SAFTENG team) make our point by demanding that we get the 10-minute bottles; the site personnel see our demands and begin to ask why we care so much if we get the 5-minute or 10-minute. When we explain to them that we want all the air we can get, they begin to see that a 5-minute bottle most likely will leave one a bit short in air supply! There is a HUGE difference between a 5-minute bottle and a 10-minute bottle, and for anyone having to travel, let’s say, four levels or more (e.g. 40′ or more vertically) I have always required the 10-minute bottle to be in these areas; regardless if the travel is by well lit and designed stairs or fixed ladders. But let’s discuss the concept of storing these emergency respirators in “strategic locations”.
Another flaw we see in using these EEBAs is that facilities try their best to strategically store them in the field rather than require EACH WORKER entering these high-risk areas to carry their own. We do a lot of shutdown/turnaround work and have seen hundreds of workers doing HIGH-RISK work in HIGH-RISK areas, and the safe work permit states “emergency respirators provided.” Turns out the permit writer counted the two (2) escape respirators in a cabinet as “emergency respirators provided” for the 100+ workers. What do we think would have if there had been a release of the HHC/EHS and only two escape respirators are provided? This is providing a serious false sense of safety, and safety professionals need to CHALLENGE these types of practices/assumptions. Suppose we have situations where workers need to have access to these types of emergency respirators. In that case, we need to provide them to EACH WORKER or ensure that the storage area is adequately stocked and FULLY accessible by all workers. I can NOT STRESS ENOUGH that these types of respirators should be on each person if possible. Yes, they can get in the way of the workers doing their work. Yes, we have gone years without ever having actually used one, so yes, our risks may be low, but we also know that it takes only one or two workers taking shortcuts to undermine our layers of protection. When this happens, and we have workers 40′ or higher in the area with LIMITED MEANS of egress, these emergency escape respirators may make the difference between life and death.
How many of you have ever pulled out a Mouth Bit/Nose Clip style escape respirator and placed it in your mouth and the nose clip over your nose? If you have never done it, I encourage you to do it in a low concentration of a chemical like ammonia so that you can PERSONALLY KNOW their limitations. I am sorry, but having worked in paper mills and chemical plants, I sort of grew up in the safety profession with these types of escape respirators as a daily way of life. That was until I actually needed one once and found out that although it works, albeit not too well, in a Chlorine atmosphere, they do NOTHING for your eyes!! I want to encourage everyone to examine the use of these devices closely and to ask tough questions about their usage. Are they appropriate for the chemicals at the facility? Remember, these devices are rated on RESPIRATORY PROTECTION ONLY and not for eye protection, so even though they may allow one to escape from breathing the vapors/gas, they may not actually allow full escape due to the damage done to the eyes. I also believe that when we take a safety committee and place them in these respirators and pour some household ammonia into a cookie sheet tray, there will be questions asked that will lead to devising other emergency escape protocols. Trust me or do the exercise yourself to come to the same conclusion!
Regardless of the type of escape respirator we wish to issue, we (the issuer) are still EXPECTED to provide training on the Use, Limitations, and Care of these respirators. Handing them out like candy is NOT doing anyone any favors!!! Never should we assume that they are so simple that when the release occurs, everyone will be able to don the respirator in a timely manner. Very few businesses actually provide hands-on training to the workers/visitors who are issued these respirators. Some show a video that actually trains the user, but VERY FEW businesses actually have the user don the respirator, WHICH IS REQUIRED by OSHA (1910.134(k)(1)(iv). I assume this is done with the mouth-bit type so that the respirators can be used over and over again by different users, as these are one-time use respirators so if each visitor were to don the respirator during orientation/training, the respirator would have to be discarded at the end of that user’s use. Check your manufacturer’s training requirements – you may be shocked at what they “recommend” as the minimum level of training.
I go back to the rule of thumb so many try to make… “it is better than nothing”. Is providing inadequate respiratory protection for emergency conditions really better than nothing? Is this how we set our safety expectations for our workers on site? It is my opinion that we are setting ourselves up for a HUGE DISAPPOINTMENT and a backlash as many have never experienced after we gas some workers who were either using the wrong respirator, did not have an escape respirator available, or were never adequately trained on the respirator provided. You can bet one of these workers will dial 1-800-321-OSHA at the end of the day, and our day will go from bad to worse! Stop “hoping” that all will turn out OK and take action to ensure all will be OK. Constantly analyze our layers of protection: Prevent, Protect, and Mitigate in relation to workers in those high-risk areas. If there is high-risk RISK WORK taking place, then we should require a level of respirator protection suited for that worst-case scenario; if there is no high-risk work actually taking place, but the area has limited access and is remote by nature, then what is our method of “protecting” these workers from the HHC/EHS when our Prevention Safeguards have failed us. Yes, it may be once in a blue moon that we will ever actually need to use one of these respirators in emergency escape conditions, but trust me when I tell you that you will be the HAPPIEST safety professional/emergency responder when that day comes, and everyone makes it out alive!