NukeWorker Forum
Career Path => Radiation Safety => Topic started by: mars88 on Aug 26, 2009, 03:59
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does anyone know of a specific regulation that requires this? at all the DOE sites i've worked, it has always been required. the site i am now working (a private site under NRC license), says it is not.
it is the mask-type, which is NIOSH certified at 4cfm, but does not come with an electronic flow meter. if it is not verified daily with a flow calibrator, how do you know if it is still at 4cfm prior to use, and thus justifiying the 1000 APF?
any regulatory link is appreciated.
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The NRC does state guidelines for PAPR operational testing
Regulatory Guide 8.15 - Acceptable Programs for Respiratory Protection
5.5 Operational Checks
Non-face-sealing respirators (e.g., airline-supplied hoods) should be operationally checked to ensure proper operation a short time before the wearer enters the radiological environment for which the device is to be used for protection. For example, once an individual has donned a supplied-air hood, the air should be allowed to flow for a period of time (e.g., one minute) before the wearer enters the contaminated area. During this time support personnel should verify that the air pressure at the distribution manifold is within the proper range specified by the manufacturer and that the wearer feels that the airflow is adequate.
In most plants that utilize PAPR's this is done with a weighted cone inserted into the end of the air hose, where a float must occur, verifying pressure is adequate. Also after filter, gaskets and hoses are changed and battery packs are charged a complete visual check is done as well. The flow is tested before issue and pre job as well.
This is why they call me PAPRina lolol....kudos out there to the STP resp. dept...they have a fantastic program there.
n
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MSA sales a Flow Check Tube that screws onto the PAPR Hose. We check every PAPR just prior to placing them into service. Every PAPR should be checked for flow prior to use.
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Did you read it? It specifically quotes the applicable section of NuReg 8.15 which DIRECTLY answers the original question.
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http://www.nrc.gov/reading-rm/doc-collections/reg-guides/occupational-health/active/8-15/#_1_46
This is the link to the NRC regs. NRC sets the guidelines for PAPR use in nuclear facilities, not OSHA. OSHA does have regs on the standard for Chemical resp wear..the guidelines there are in the 29 CFR 1910.134
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=standardss
this is the link for that
There are standards that do apply IN a nuclear facility that OSHA has standards on..ermmm..like when peroxide is used in a cavity etc...but OSHA states that the NRC guidelines be the equivalent or MORE than OSHA requires to be in compliance.
I do agree that battery wear is an issue, and areas that have high PAPR traffic ie: generators, etc, should have battery recharging stations at the HP checkpoints and flow test tools so testing and battery replacement is easily accomplished.
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http://media.msanet.com/NA/USA/APR/PoweredAirPurifyingRespiratorsPAPRs/OptimAir6APAPRwithOptiFilterCartridges/490883PDF.html
Above link is MSA instruction manual for respirator that you are talking about and on the front page it says " The warranties made by MSA with respect to the product are voided if
the product is not used and serviced according to the instructions in this
manual. For any additional information relative to use or repair, write or
call 1-800-MSA-2222 during regular working hours."
and on page 15
PARTICULATE FILTER AND CHEMICAL CARTRIDGE
AND BATTERY PACK SERVICE TIMES
The PAPR high efficiency filter cartridges and the battery
pack are designed to supply a minimum of six cubic feet
per minute (cfm) of respirable air to the facepiece (or hood)
for a shift. Actual service time may vary. However, air flow
must not drop below 4 cfm for a facepiece or 6 cfm for
hoods. The type and concentration of the contaminant, as
well as the relative humidity of the air, may affect how long
filters may be used. See the Accessories section for available
flow check devices.
It doesn't actually tell you to check the flow, but does tell you that they will not warrant the assigned protection factors if flow falls below 4cfm for masks. (how would you know if you don't check)
NIOSH is the orginization that sets protection factors for respiratory protection and the reg for that states that the equipment must be used in accordance with manufacturers instructions.....
I hope that was helpful.
Mike
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Please note that OSHA is a Federal Regulation and it specifies that NIOSH sets the protection factors for Respiratory Protection..... Any other regulations that you are following at any workplace (NRC, DOE, Private Labs) are derived from OSHA and NIOSH. One of OSHA's requirements is that an employer establish a Respiratory Protection Program. NuReg is just NRC's way of "helping"/ensuring that all licensees Comply with the applicable Federal Standards (the law). The original question was about a situation that is potentially outside NuReg but it still must show compliance with the law.
Mike
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NuReg applies to all NRC sites with NRC licenses. There are some locations (some waste sites and low level labs) that have modified NRC licenses that exempt them from some or all of NuReg. I just put that last statement in to cover all bases since I don't know the specifics....
Mike