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WORKING DRAFT 9.15.92—Performance Evaluation of DM and DFM Filter Respirators

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— In the real world no respirator is used 100% of the time while in the workplace.^[1]

After 39 years of professional experience in respiratory protection, Revoir stated in 1990:

Major problems frequently encountered by employers in using respirators to protect employees against respiratory hazards in workplaces include:

Respirator Selection.
Selecting the proper respirator for protecting persons against harmful air contaminants in workplaces is a difficult task. Employers often fail to consider all the factors necessary for making the correct decision such as workplace characteristics and conditions, nature of the process, location must be worn, properties of the respiratory hazard (physical, chemical, toxicological, actual concentration of hazardous substance in workplace atmosphere, Permissible exposure levels, physical and functional capabilities and limitations of each type of respirator, and assigned protection factors for various types of respirators. Frequently employers select respirators by reading brief descriptions of respirators in catalogs or sales bulletins. Employers often select respirators based upon advice from salespersons employed by safety products distributors who may be poorly trained in respiratory protection technology. . . .

Respirator Fit Testing.
Many employers do not conduct either qualitative or quantitative fit testing of respirators to insure that each employee is provided with a respirator that provides an adequate seal to his/her face. Carrying out a proper fit test is tedious and time-consuming.^[2]

In a report prepared for OSHA by Centaur Associates, survey results estimated the actual working conditions in typical U.S. respirator programs.^[3] For the approximately 3.6 million wearers covered by OSHA's respirator-use regulation, Centaur Associates estimated the following levels of noncompliance with respirator-use regulations by American employers in the early 1980's:

↑ Gaboury, A. and D. H. Burd: Workplace Protection Factor Evaluation of Respiratory Protective Equipment in a Primary Aluminum Smelter, presented at the International Society far Respiratory Protection Conference, San Francisco, CA (November 1989)
↑ Ravoir, W. H.: Comments on OSHA's Proposal to Modify Existing Provisions for Controlling Employee Exposure to Toxic Substances Found in 29 CFR 1910.1000(3) and 29 CFR 1910.134(a)(1). Comments submitted to OSHA (May 30, 1990), pp. 22-23.
↑ Centaur Associates, Inc.: Preliminary Regulatory Impact Analysis of Alternative Respiratory Protection Standards, Volume II, contract report prepared for the U. S. Department of Labor, Occupational Safety and Health Administration under Contract No. J–9–F–20067, Washington, D.C. (March 30, 1984), Section 5, The Costa of Compliance.

[1] Gaboury, A. and D. H. Burd: Workplace Protection Factor Evaluation of Respiratory Protective Equipment in a Primary Aluminum Smelter, presented at the International Society far Respiratory Protection Conference, San Francisco, CA (November 1989)

[2] Ravoir, W. H.: Comments on OSHA's Proposal to Modify Existing Provisions for Controlling Employee Exposure to Toxic Substances Found in 29 CFR 1910.1000(3) and 29 CFR 1910.134(a)(1). Comments submitted to OSHA (May 30, 1990), pp. 22-23.

[3] Centaur Associates, Inc.: Preliminary Regulatory Impact Analysis of Alternative Respiratory Protection Standards, Volume II, contract report prepared for the U. S. Department of Labor, Occupational Safety and Health Administration under Contract No. J–9–F–20067, Washington, D.C. (March 30, 1984), Section 5, The Costa of Compliance.

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