Respiratory Protection: APF Proposal Divides Industry, Labor

Dec. 5, 2003
One piece of OSHA rulemaking casting a big shadow this year, given the agency's modest regulatory agenda, is OSHA's proposal to amend the respiratory protection standard to include new assigned protection factors (APF).

NIOSH and industry stakeholders support the proposal, and in written comments submitted to OSHA, have praised the agency for doing its homework. But the AFL-CIO opposes OSHA's decision to grant an APF of 10 to all half-mask air purifying respirators.

"We believe the record supports a final rule that includes an APF of 10 for elastomeric half-masks and an APF of five for filtering facepieces and quarter-masks," wrote the AFL-CIO in its comments.

The controversy over the APF for filtering facepieces also appears to have stymied the effort to update ANSI's "Practices for Respiratory Protection" (Z88.2) standard. The committee has voted to approve a standard that gives a more protective APF of five to filtering facepieces, but the move has provoked a reaction among respirator manufacturers and the International Safety Equipment Association (ISEA).

"The standard will become finalized, but we already know that ISEA is going to challenge our standard because of the APFs for filtering facepieces," said Howard Cohen, chair of the Z88.2 committee. The standard cannot be issued while an appeal is ongoing.

The failure of ANSI to issue its standard has leant more urgency to OSHA's effort to address APFs.

At the root of the dispute, according to Cohen, is the lack of reliable data about how filtering facepieces perform in the workplace. Currently, these respirators have an APF of 10. Whereas manufacturers contend that given the lack of data, the APF should not be changed, labor and a majority of other stakeholders on the ANSI committee decided that the lack of data justified moving to a more protective APF.

This argument will likely be played out at OSHA's informal public hearing on the APF proposal, scheduled to begin Jan. 28 in Washington, DC. Another area of contention concerns how OSHA addresses maximum use concentrations, used when workers are exposed to airborne contaminants where the agency does not have a permissible exposure limit.

While the dispute over APFs for filtering facepieces may be serious, stakeholders appear to agree on most of the other technical matters addressed in OSHA's proposal.

Cohen said that in virtually all the other categories of respirators there are few differences between the ANSI committee's standard and the OSHA proposal.

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