OSHA has extended to Nov. 1 the deadline to comment on 20 of the 25 proposed rules the agency published on July 1, many of which give end users more choices for respiratory protection as long as assigned protection factors are not reduced.

OSHA is extending the period for submitting comments by 60 days to allow stakeholders to review the notices of proposed rulemaking (NPRM) and collect information and data necessary for comment. Many of the proposals would make changes “designed to provide employers with greater flexibility in selecting appropriate respirators while maintaining equivalent levels of worker protection," explained OSHA in announcing the revised requirements. Exposures to 1,3-butadiene, acrylonitrile, benzene, cadmium, coke oven emissions, cotton dust, ethylene oxide, formaldehyde and lead are among the standards where employers would have greater discretion as to what respirators are used.

For example, the NPRM for revising the asbestos standard proposes to strike the requirement to use a tight-fitting powered air purifying respirator, or supplied air respirator, or a self-contained breathing apparatus, and in its place require only that employers provide employees with a respirator that offers an APF of 50. Right now, the OSHA regulations deem that PAPRs have an APF or 50.

The promise of new technology

In many of the respirator-related proposed rules, OSHA suggests respirator technology is constantly evolving.  In fact, in the asbestos proposed rule, OSHA says it “…believes that this proposed rule appropriately incorporates advances in technology, which have made some provisions of the asbestos standards outdated, and would allow employers to take advantage of future technological advances. This proposed standard is intended to account for modern knowledge and technology and to streamline the selection of respirators.”

Dan Glucksman, the International Safety Equipment Association’s (ISEA) senior director for policy, says “more and more we are seeing high tech entering the PPE space. We see it in head protection and cooling PPE. ISEA members are constantly researching and innovating in the respiratory protection area – which is also why we need NIOSH’s Respirator Approval Program to be appropriately funded.”    

These proposals are not prescriptive, says Glucksman. “They let science and research make advancements.”

OSHA will allow for more respirators to be chosen and used as long as they meet the designated assigned protection factors (APFs indicate the minimum level of wearer protection) for a number of toxic exposures, says Glucksman. “Manufacturers will develop new filter technology that provides protection at the APF level. These proposals could lead to new designs and thinking about respirators. This is part regulatory relief and part the science of OSHA saying let’s expand what we allow as long as the APFs are met. Doing job hazard analyses will be important with allowing a broader selection of respirators,” he says.