RECORD IDD95-08-034

STANDARD NUMBER
1926.62(f), 1926.62(j)

INFORMATION DATE
8/17/1995 12:00:00 AM

SUBJECT
respirator fit factors and post exposure ZPP testing

DISCLAIMER
The information contained in this response is a technical clarification to a DOE Rule or Directive and should only be applied to the specific conditions described in this response. These responses represent the best available technical knowledge available from the Department’s subject matter experts and are NOT binding upon the DOE. These responses DO NOT represent approval of a variance, exemption, or equivalence for any requirements. Requests for exemptions or equivalences for Directives requirements must follow the procedures in DOE O 251.1C. Interpretive rulings, that are binding on DOE, may only be made the Office of General Counsel.

QUESTION
1. Appendix D to the lead standard, 1926.62 calls for interpretation of quantitative respirator fit test results by establishing the fit factor. Can the fit factors so established for each employee be used to assign protection factors instead of the respirator selection criteria provided in Table I under 1926.62(f)(2)? 2. Is ZPP testing required when an employee has been exposed to lead at levels above the PEL?

REGULATORY REVIEW
1. Appendix D of 1926.62 not only requires establishing the quantitative fit factor in paragraph (j) of section C, it also requires in paragraph (h) that successful completion of a quantitative fit test depends upon each of three independent tests exceeding the minimum fit factor needed for the class of respirator. Therefore every successfully fit tested respirator user exceeds the fit factors established in Table 1 of 1926.62(f). Understanding that the personal fit factor must exceed the assigned factor, coupled with the wording in 1926.62(f)(2) which states that "the employer shall select the appropriate respirator or combination of respirators from Table 1", it is clear that personal fit factors may not be used to assign respirators. Respirators must be selected on the basis of the criteria in Table 1. This protocol is consistent with other respirator selection protocols, such as ANSI Z88.2-1992 which states that, "The proper respirator shall be selected as follows:...Select a respirator with an assigned protection factor greater than the value of the hazard ratio, as listed in table 1." ANSI Z88.2-1992 requires that "a fit factor that is at least 10 times greater than the assigned protection factor (table 1) of a negative-pressure respirator shall be obtained before that respirator is assigned to an individual." 2. The lead standard, 1926.62(j) requires an initial medical evaluation for an employee who is exposed to lead at levels above the action level. This consists of blood testing for lead and ZPP and must be performed before this exposure occurs or offered within 48 hours after the first exposure above the action level. However, if the employee has already received the initial medical surveillance within the past 12 months and does not experience 30 or more days above the action level within a 12 month period, there is no requirement under 1926.62 to provide further medical evaluation, unless one of the conditions described in 1926.62(j)(3)(i)(B) or (C) occurs: "As soon as possible, upon notification by an employee either that the employee has developed signs or symptoms commonly associated with lead intoxication, that the employee desires medical advice concerning the effects of current or past exposure to lead on the employee's ability to procreate a healthy child, that the employee is pregnant, or that the employee has demonstrated difficulty in breathing during a respirator fitting test or during use". "As medically appropriate for each employee either removed from exposure to lead due to a risk of sustaining material impairment to health, or otherwise limited pursuant to a final medical determination." In a previous DOE interpretation, D93-10-023, DOE has stated that initial medical surveillance must be repeated every 12 months. Under DOE Order 5480.8A, Contractor Occupational Medical Program, the site occupational medical director should be furnished information about chemical hazards in the workplace and should determine medical examination frequency and content. An overexposure to lead would be reportable under DOE Order 5000.3B. Please see three previous interpretations issued by the Response Line, D94-04-041, D95-03-005 and D95-04-051. Copies of Unprecedented DOE interpretations, D94-02-065, D93-10-023, D93-10-026 and D93-10-053 were faxed to the caller under separate cover.