by Todd Nighswonger
A terrorist has attacked your plant, causing an explosion that releases chemicals into the air inside and around the facility. Do you have respirators on hand to protect emergency responders and the rest of the work force trying to escape?
The answer to that question depends on whom you ask and, to a certain degree, on the type of facility and where it is located. Terrorists are likely to strike near large population centers, but they also may target a remote chemical facility, for instance, because of the availability of toxic industrial materials or chemicals that could be used in the attack.
"No place is immune - small-town USA or a large metropolis," says Michael J. Fagel, Ph.D., CHCM, corporate safety director for Aurora Packing in North Aurora, Ill., and an expert in emergency planning for disasters. "No place has any level of protection or shield and can say, 'It won't happen here.' It certainly may happen there."
Terrorists potentially have a myriad of chemical, biological, radiological and nuclear (CBRN) agents at their disposal, says Les Boord, program manager, Standards Development Section, for the National Institute for Occupational Safety and Health (NIOSH). "The only limitation is the creativity of the terrorists who design the attack. As we know from experience, they are pretty creative."
There is no universal type of respirator that is effective against all CBRN threats, according to respirator manufacturers and the U.S. government, but development of such products is under way by respirator manufacturers.
The military for years has worked at providing soldiers with respiratory protection in the event of a terrorist attack. The technology is available for industrial use, but NIOSH is only beginning to develop criteria to certify respirator products that will protect against CBRN agents. Until then, users must rely on hazard assessments and consultation with product manufacturers.
A debate exists as to whether the right kind of respirators for CBRN agents already are available, notes Bob Weber, CIH, international technical service and regulatory affairs manager for 3M's Occupational Health & Environmental Safety Division. "Is there anything as universal as what NIOSH is looking for? The answer is no. The certification that NIOSH is developing will not be a magic bullet. There won't be one respirator that will do everything."
At least not yet. NIOSH in May certified the first self-contained breathing apparatus (SCBA) for use against CBRN agents. In June, stakeholders met in Pittsburgh to begin establishing certification criteria for full-face, air-purifying respirators. The agency also plans to offer certification for escape respirator hoods and powered air-purifying respirators over the next year or two. The goal is to certify as many products as possible against virtually all CBRN hazards.
"With a terrorist event, you don't know what you're going to encounter," NIOSH's Boord says. "You could encounter any of the toxic industrial materials, as well as chemical warfare agents. The respiratory protection you're offering needs to have some assurance it is capable of meeting this wide spectrum of hazards. That's why we need to define new [certification] requirements."
The process, however, won't go fast enough for those awaiting NIOSH-approved products. Testing, which costs $35,000 per attempt, only is performed at one location, the U.S. Army Soldier and Biological Chemical Command (SBCCOM) center at Edgewood, Md. Because live agents are used in the testing, the product is destroyed, leaving manufacturers with no explanation why a product failed.
Any SCBA that NIOSH approves for CBRN protection, Boord says, also must comply with NIOSH respirator certification requirements (42 CFR 84) and NFPA 1981 ("Standard on Open-Circuit Self-Contained Breathing Apparatus for the Fire Service").
In the meantime, just how protected will workers be if a terrorist strikes their plant?
On-site Chemical or Warfare Agent?
Facilities complying with 29 CFR 1910.134, OSHA's respiratory protection standard for general industry, may be more prepared than they think should a terrorist use large quantities of existing chemicals to fuel an attack.
"If you're talking about a chemical plant, most likely the terrorist will use the chemicals that are there by trying to create a leak, an explosion or something along those lines," says Bill Newcomb, director of regulatory affairs for North Safety Products.
Plants with compliant respiratory protection programs likely are prepared for the release of existing chemicals, whether by accident or by terrorist, Boord says. "When you look at it from an industrial-use perspective, you would be using respirators in environments that basically are controlled. You know what the hazards are and have administrative procedures in place."
Accidental releases of chemicals, however, may be at lower concentrations than releases caused by a terrorist. "Today media contained in canisters exists that will filter out many toxic industrial materials, but not at the potential concentrations that NIOSH believes might happen," Weber points out. NIOSH is working with SBCCOM on hazard mapping to determine potential concentrations if particular chemicals are released by terrorists.
"If you don't know the concentration, you're pretty hard-pressed to say a particular [respirator filter] canister will provide protection," says Ken Bobetich, product group manager for air-purifying respirators at MSA.
NIOSH plans to begin certifying full-face respirators that protect users from high concentrations of chemicals and a variety of CBRN hazards, including weapons of mass destruction (WMD) that industry has not worried about in the past. Releasing a warfare agent, 3M's Weber says, would be more disturbing on the psyche of Americans than blowing up a chlorine tank, so a company can't rule out the possibility that a terrorist might use sarin or mustard gas, for example.
While the use of WMD agents such as sarin or mustard gas is less likely, respiratory protection for these hazards is harder to prepare for because of not knowing which agent(s) a terrorist will use. NIOSH lists 40 WMD-type hazards, including several biological, chemical, nerve and choking agents.
"Importing a [warfare] chemical to a chemical plant would be like bringing a sandwich to a banquet," says Aurora Packing's Fagel, who assisted at the World Trade Center last fall and continues to train New York City firefighters on emergency response to terrorism.
One issue that NIOSH will tackle on certification is that some CBRN hazards can permeate a respirator's material. Permeation is the main issue with certification for SCBAs, which have no filter issues because the air is supplied.
Respirators typically are stored and distributed as needed. Respirators for terrorist response, however, need to be readily available. "They get exposed to different extremes of environmental conditions: heat, cold, humidity, shock and vibration, Boord says. That is an aspect that will be addressed in certifying respirators for [CBRN] protection."
What if the threat of a terrorist attack is thought to be extremely low at a facility that has had no need for respiratory protection in the past? The company needs to assess whether a threat exists and determine if respiratory protection is feasible and practical.
"Unless there's a credible threat, you can't have respiratory protection available for everybody at a low-risk plant," maintains Capt. Henry Delgado, MS, CIH, with the Office of Emergency Preparedness in Dallas. Delgado has expertise on determining personal protective equipment (PPE) for emergency medical services and PPE limitations in a chemical or biological attack.
"You need to look at the level of risk and the potential," Weber agrees. "If the potential is extremely low, you may not need to do anything."
If the risk is high enough, however, there are steps to take to protect workers.
Responding or Escaping?
The type of respirator protection needed in the event of a terrorist attack depends on the type of hazard present and whether workers are emergency responders or are part of the work force trying to escape. Each scenario calls for a specific type of protection.
Responding. For workers who are first responders, compared to those who might respond at a later time to assist or clean up, wearing an SCBA with an encapsulated suit is a must, mainly because there may be a question as to what CBRN agent was used in the attack. Finding out later that a respirator was inadequate could prove fatal.
The job of first responders entering an unknown environment is to assess the hazards and determine whether subsequent responders will need the same full-body protection or whether less physically demanding equipment can be used, according to James S. Johnson, Ph.D., MSH, CIH, QEP, leader of the Chemical and Biological Safety Section for the Lawrence Livermore National Laboratory in Livermore, Calif. Johnson has done extensive research on the type of respiratory protection needed for chemical and biological agents and has developed guidelines to determine the type of respiratory protection suitable for responders (see "Selection of Air-Supplying Respirators for Chem-Bioterrorism Response").
Keep in mind, North's Newcomb says, that respiratory hazards are not the only concern for responders to a CBRN scenario. "The self-contained breathing apparatus is sufficient for virtually anything respiratory. Dermal exposure or physical exposure will be the limiting factors."
As the responder's level of exposure decreases, certain types of air-purifying respirators may be adequate (see "Selection of Air-Purifying Respirators for Chem-Bioterrorism Response"). Powered air-purifying respirators also are candidates for some responders.
When determining the type of respiratory protection for responders, users need to remember that existing regulations provide a good framework, says Steve Weinstein, SCBA product manager for Bacou-Dalloz's Survivair. "There is a misunderstanding with uneducated people in the industry that all of the air-purifying respirator approaches to WMD environments are meant to replace SCBAs," Weinstein says. "It's no different than any other scenario where a respirator is needed. You still have to use the same selection criteria."
Delgado of Dallas' Office of Emergency Preparedness points out that training for responders to terrorist attacks does not vary greatly from what is required for more routine emergencies. The main difference is in the type of information provided, he says. Hazmat crews, for example, need additional training on toxicology and awareness of WMD agents.
Escaping. To protect workers escaping from a terrorist attack, the choice is between a respirator or an escape hood. Both have advantages and disadvantages.
Respirators. If escaping from a terrorist attack, Weinstein says, only some filter media will protect workers. "Normal air-purifying respirators won't provide the protection needed to escape from a WMD scenario."
Until NIOSH certifies respirators for use against CBRN agents, Lawrence Livermore's Johnson suggests a full-face respirator with a military (C2A1) cartridge containing a HEPA filter. The carbon will absorb volatile compounds, and the filter will block particulates. The military carbon is different from that used in industrial respirators because a special impregnated carbon, containing a different set of metals and organic materials, will protect from expected nerve agents.
A military mask, Johnson points out, uses a NATO thread with the C2A1 canister. It does not protect against a few industrial gases, such as ammonia, that require a special type of carbon. Manufacturers are attempting to develop an industrial cartridge with a carbon that will protect users from CBRNs and virtually all toxic industrial materials.
Also to be determined is whether CBRN respirators will be certified that filter carbon monoxide, an important concern for terrorist attacks involving fire. According to Lisa Mork, air-purifying product manager for Survivair, no manufacturer has developed a respirator that protects against CBRN agents and carbon monoxide because the filter technology has not been combined.
Respirators for use against CBRN agents will not be effective unless the hazard in question has been properly identified, the mask is fitted and used properly, and the product is used in areas containing sufficient oxygen. In addition, a tight-fitting respirator may not provide a proper seal for those with facial hair or who wear glasses, Mork says.
Escape hoods. Until recently, escape hoods mostly protected users from smoke inhalation. It's important that smoke escape hoods not be used for terrorist attacks, Johnson says, because they do not provide adequate protection against CBRN agents.
3M's Weber also points out that today's NIOSH-approved escape respirators may protect from specific chemicals such as chlorine or sulfur dioxide, but not a majority of hazards. "The biggest thing that will affect the entire respirator market in the coming years," he says, "is escape respirators with more universal protection that are NIOSH-approved." One type of escape hood contains an internal half-mask respirator. Other hoods contain a mouth bit (some with a nose clip) and cartridge, or short-term supplied air.
In addition to filter protection, CBRN escape hoods need to provide a tight-fitting neck seal, similar to a tight seal for full-face respirators. Johnson describes the neck seal as an elastic washer that fits over the head, then contracts to the user's neck size. Long hair needs to fit inside the hood.
Escape respirator devices likely would be used by workers not used to wearing respiratory protection, so training is needed on how to don the product. It should include checking to see if the user might become distressed or claustrophobic. Ensure that the user's neck size will fit the range, such as 10 to 22 inches, provided by the product.
Advantages of escape hoods over full-face respirators include fewer restrictions for users concerning facial hair and glasses, an important consideration because "you can't regulate the everyday work population like you can the military," Mork says.
While only escape hoods are available so far, Johnson says, work is under way to develop a hood respirator for responders who direct traffic or receive patients, for example, in environments where the hazard is known.
"Users need to understand what they're getting now vs. what might be available in six months," he advises. "Use of escape hoods for nonescape purposes would violate any NIOSH approval."
Until NIOSH finishes its work with certification to ensure that respirators meet minimum standards for protecting users from CBRN agents, there is no way to guarantee that all workers at a plant will have adequate respiratory protection in the event of a terrorist attack.
"The bottom line," NIOSH's Boord says, "is you just don't know."