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Respirator Education

Breathing Air Quality


The breathing air quality requirement for atmospheresupplying respirators is often one of the least understood elements of a respiratory protection program. Supplied air respirators (SAR) and self contained breathing apparatus (SCBA) are subject to very similar, but not identical, air quality requirements. While the need to provide clean air to the respirator user is obvious for health and safety reasons, excessive contamination can also have adverse effects on respirator performance. These effects may include regulator or valve malfunction and rusting of storage cylinders. This article will discuss the legal requirements for breathing air quality, the types of systems used to deliver good quality air and quality monitoring procedures.
Air Quality Specifications

respirator use regulation 29 CFR 1910.134. 2 OSHA also requires Grade D air, but cites a later edition of Commodity Specification for Air (G-7.1-1989). OSHA has also modified some of the specific language from G-7.11989. 3 It should be noted there is now a 1997 edition of Commodity Specification for Air.4 Its Grade D air description is very similar to OSHAs specification. Table 1 compares the Grade D air requirements of OSHAs regulation 1910.134 and the 1966 and 1997 editions of the Compressed Gas Association publication G-7.1. It is evident from Table 1 that 1910.134 has more specific requirements for Grade D air than either edition of G-7.1. In addition, compliance with OSHAs
Table 1

specification also satisfies NIOSHs requirement. Therefore, the remainder of this discussion will focus on Grade D air as described in 1910.134.Some of the limits identified in the OSHA regulation warrant comment. OSHAs dew point specifications came from G7.1-1989, where they were applicable only to SCBA used in extreme cold (similar to Note 2 in Table 1). They now apply to any use of any atmosphere-supplying respirator. The intent of this requirement is sound, i.e., prevention of water condensation and potential freezing in cold environments. However, applying these specifications to all use conditions can sometimes create problems. For example, if users purchase breathing air in cylinders for use with SAR, the air must comply with the -50F

Respirator Education

Grade D air (quality verification level)


G-7.1-1966 OSHA 1910.134 G-7.1-1997

Limiting Characteristics

There are two breathing air quality regulations that affect most users of SAR and SCBA: 1. The respirator approval regulation 42 CFR Part 84. 1This regulation specifies a minimum air quality required to receive and maintain approval by the National Institute for Occupational Safety and Health (NIOSH). The air quality specified is Grade D or better, as described in Compressed Gas Association Commodity Specification for Air (CGA G-7.11966). If SAR and SCBA are supplied with air that does not meet this specification, the NIOSH approval is void. 2. The Occupational Safety and Health Administration (OSHA)
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Percent Oxygen atm/19.0-23.0 19.5-23.5 atm/19.5-23.5 (Balance predominantly nitrogen) (Note 1) (Note 1) Water, ppm (v/v) (Note 2) (Note 2) Dew Point, F (Note 2) Air in cylinders: -50F (Note 2) Compressor air: >10F below ambient Oil (condensed) 5 5 5 (mg/m 3 at NTP) Carbon Monoxide (ppm) 20 10 10 Odor (Note 3) No noticable odor (Note 3) Carbon Dioxide (ppm) 1000 1000 1000 Note 1: atm = oxygen content normally present in atmospheric air (applies to compressors). The numerical values denote the acceptable oxygen limits for synthesized air. Note 2: Varies from saturated to very dry, depending upon intended use. If a specific water limit is required, it should be specified in ppm (v/v) or dew point. Dew point is expressed in F at one atmosphhere pressure absolute (760 mm Hg). G-7.11997 specified a dew point not to exceed -65F (24 ppm v/v) or 10 degrees lower than the coldest temperature expected in the area for self-contained breathing apparatus used in extreme cold. The intent of this requirement is to prevent water condensation and freezing, which could cause the breahting apparatus to malfunction. This requirement also differentiates Grade L from Grade D air in the 1997 specification. Note 3: Subjective limit, determined by sniffing. Air may have a slight odor. The presence of a pronounced odor renders the air unsatisfactory. (continued on next page)

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Respirator Education

Breathing Air Quality


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Frequency of Air Quality Testing

requirement. If the ambient temperatures are reasonable, air of this dryness is not needed to prevent condensation. Prolonged use of extremely dry air can cause drying of the nose and throat and, occasionally, nosebleeds in certain individuals. It is also conceivable that the dew point specification for air compressors may require some users to purchase an air drier where one was not needed before. OSHA adopted the 10 ppm carbon monoxide limit from the 1989 edition of G-7.1. Well designed and maintained breathing air systems should have essentially no carbon monoxide in the air. It is significant to mention that most carbon monoxide is drawn into air compressors rather than being generated by the air compressor (due to overheating and decomposition of oil).5 This will be discussed further in this article in the section entitled Compressor requirements. The OSHA odor specification differs from G-7.1: no noticeable odor rather than no pronounced odor. G-7.1 acknowledges that it is common for air to have a slight, not unpleasant odor (Note 3 in Table 1). If the OSHA requirement is interpreted literally, there is potential for air that otherwise meets the Grade D specification to be rejected (and possibly cited by OSHA). It is worth pointing out that the Grade D air specification has always had a carbon dioxide limit of 1,000 ppm. End users are generally less aware of this limit than some other limits. If indoor air is used as the source for the compressor, the carbon dioxide limit sometimes can be exceeded unless the purification system is capable of removing it.

OSHA requires that users obtain a certificate of air analysis documenting Grade D quality for cylinders of purchased breathing air. There is no specific requirement to verify the quality of the air produced by in-house compressors. Logically, the only way to know whether the levels of Grade D contaminants are acceptable is to test the air with some frequency. There are two recommendations for frequency of air quality testing that users may consider: 1. National Fire Protection Association (NFPA) 1404-1996 recommends quarterly testing for fire departments who produce their own breathing air;6 2. American National Standards Institute (ANSI) Z88.2-1992 recommends acceptance (initial) and periodic testing for breathing air systems.7 ANSI allows the frequency of testing to be adjusted to the performance characteristics and history of each system. For example, if quarterly testing of a well maintained system reveals no significant contamination over the course of a year, sampling might be reduced to semi-annual or annual frequency. OSHA does not specifically require keeping records of air quality testing. However, users are well advised to have these records available to verify that breathing air of acceptable quality has been provided at all times. Users might also consider treating these results as environmental exposure records, which are covered by the access and retention requirements of OSHA regulation 29 CFR 1910.1020. 8
Methods of Air Quality Testing

assure Grade D quality, choosing techniques is left to users discretion. A third party laboratory that will provide sample collection devices and perform the analyses may be employed. For users who prefer to perform their own analyses, Commodity Specification for Air lists sampling methods that may be used to test for each of the regulated contaminants.4 The methods listed range from sophisticated techniques such as gas chromatography, to very simple procedures such as colorimetric detector tubes. The choice of methods for sampling and analysis should be based upon the users familiarity with sampling instruments, comfort with in-house versus third party analysis and cost. An almost unlimited number of methods can provide acceptable results if properly used.
Compressor Requirements

Since OSHA does not specify sampling methods for testing air to

The OSHA regulation lists specific considerations for the set-up and operation of compressors used to supply breathing air. No specific type of compressor is required. Both oil-free and oil-lubricated compressors can be used. In many cases, plant air compressors may be safely used for breathing air. Regardless of the type of compressor, the air inlet must be located to minimize the entry of contaminants. It is generally easier to meet this requirement if the inlet is located outdoors, away from areas where combustion engine exhaust, ventilation discharge stacks or other sources of contamination are present. OSHAs regulation also requires compressed air systems to have suitable in-line air purifying sorbent beds and filters to ensure breathing air quality. In this context, in-line means situated after the compressor and before the point of connection to the approved respirator supply hose. Currently, no approved respirator has

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filtration elements that are located in-line between the air source (i.e., point of attachment of the approved assembly) and the users breathing zone. OSHAs requirement for in-line sorbents and filters is performance oriented; suitable means whatever is necessary to achieve Grade D or better air quality. The specific sorbents and filters necessary to meet this requirement are largely a function of the quality of air produced by, or drawn into, a particular compressor. Essentially, systems available for improving breathing air quality fall into two categories: 1. Filtration systems. This type of system removes aerosol contaminants (mostly water and oil mists). These systems generally consist of one or more filter elements. It is common to treat one of the filters with activated charcoal to remove trace organic vapors that might cause odors. Filtration systems do not remove carbon monoxide or other gaseous contaminants and do not reduce dew point. The 3M W-2806 Air Filter and Regulator Panel is an example of this type of system. 2. Purification systems. These systems remove aerosol contaminants and specific gaseous contaminants, including carbon monoxide. They may or may not incorporate an air drier to reduce dew point. The 3M Portable Air Purification System is an example of a purifier that does not dry the air. All purification systems have limitations regarding the specific contaminants and the concentrations of these contaminants that can be removed! No system can always assure Grade D or better air quality!

The OSHA regulation requires that the sorbents or filters present be maintained in accordance with their manufacturers instructions. Furthermore, a tag documenting the most recent maintenance of these elements must be maintained at the compressor.
Monitor and Alarm Requirements

requirements are performanceoriented. Employers must use their judgement to determine the best practices to assure and document acceptable air quality. A sound breathing air quality program may exceed the specific requirements of the regulation. This is particularly true when testing the air to assure Grade D quality and keeping records of the results.
References
1. Approval of Respiratory Protective Devices, Code of Federal Regulations Title 42, Part 84, 1996, pp. 528-593. 2. Respiratory Protection, Code of Federal Regulations Title 29 (5), Part 1910.134, 1998, pp. 412-437. 3. Compressed Gas Association: Commodity Specification for Air (CGA G7.1), Arlington, VA: Compressed Gas Association, 1989. 4. Compressed Gas Association: Commodity Specification for Air (CGA G7.1), Arlington, VA: Compressed Gas Association, 1997. 5. Distler, T.M.: Formation of Carbon Monoxide in Air Compressors, Am. Ind. Hyg. Assoc. J. 40: 548-551 (1979). 6. National Fire Protection Association: Standard for a Fire Department SelfContained Breathing Apparatus Program (NFPA 1404), Quincy, MA: National Fire Protection Association, 1996. 7. American National Standards Institute: American National Standard for Respiratory Protection (ANSI Z88.2), New York: American National Standards Institute, 1992. 8. Access to Employee Exposure and Medical Records, Code of Federal Regulations Title 29 (6), Part 1910.1020, 1997, pp. 105-114.

Respirator Education

OSHA identifies different monitoring requirements for oil-free and oil-lubricated compressor systems. If the compressor is oilfree, users are required to ensure that carbon monoxide levels do not exceed 10 ppm. The regulation does not explain how this should be done. Oil-lubricated systems must have a high temperature alarm or a carbon monoxide alarm or both. If only a high temperature alarm is used, carbon monoxide must be monitored at sufficient intervals to assure the 10 ppm limit is not exceeded. The regulation does not define sufficient intervals. Therefore, testing for carbon monoxide at some interval is implied for oil-free systems and specified for oil-lubricated systems. It is conceivable that testing for carbon monoxide could be done daily or weekly to satisfy the legal requirement. However, a continuous carbon monoxide monitor may be the simplest way to comply with the regulation. It also assures that if a carbon monoxide event occurs, (for example, a combustion engine inadvertently left operating near the compressor inlet), it would not happen between scheduled periodic samplings.
Summary

Users of SAR and SCBA are most directly affected by the breathing air specification of the revised OSHA respiratory protection regulation. For the most part, the OSHA

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