||U. S. Department of Labor
Occupational Safety and Health Administration
Directorate of Enforcement Programs
Office of Health Enforcement
Safety and Health Information Bulletin
SHIB 08-29-03 (A)
| This Safety and Health Information Bulletin is not a standard or regulation, and it creates no new legal obligations. The Bulletin is advisory in nature, informational in content, and is intended to assist employers in providing a safe and healthful workplace. Pursuant to the Occupational Safety and Health Act, employers must comply with hazard-specific safety and health standards promulgated by OSHA or by a state with an OSHA-approved state plan. In addition, pursuant to Section 5(a)(1), the General Duty Clause of the Act, employers must provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm. Employers can be cited for violating the General Duty Clause if there is a recognized hazard and they do not take
reasonable steps to prevent or abate the hazard. However, failure to implement any recommendations in this Safety and Health Information Bulletin is not, in
itself, a violation of the General Duty Clause. Citations can only be based on standards, regulations, and the General Duty Clause.
OSHA has developed the information in this safety and health bulletin so that employers
may provide their employees with the best possible protection from injuries and illnesses
resulting from terrorist incidents. As concerns over the potential for future terrorist actions
against the United States remain high, OSHA is committed to working with employers to
strengthen their workplace planning and preparedness. Our goal also is to provide guidance to
employers and employees on the larger concept of emergency management.
Emergency Planning and Preparedness
Employers are responsible for providing a safe and healthful work environment for their
employees. Planning for all types of emergencies including terrorist events has become
increasingly important for employers and employees. To assist employers in developing an
emergency action plan, OSHA encourages all employers to review the Evacuation Planning Matrix. This tool provides guidance to
employers on how to assess a risk of a terrorist-initiated event, and provides notification,
shutdown and isolation procedures, training and equipment guidelines, along with information on
evacuating, sheltering, and accounting for employees.
Emergency Escape Masks
Recently, a number of U.S. Government departments and agencies have purchased and
distributed emergency escape masks to employees with the purpose of protecting against
chemical, biological, radiological, and nuclear (CBRN) warfare agents. These escape masks
have not gone through the NIOSH approval process at this time, and their performance in a
CBRN event has not been fully validated. Our goal is to provide useful information to the users
of these masks. It is not an endorsement, nor is it an objection to the use of the emergency
escape masks. We want to encourage employers to provide meaningful training on the use and
limitations of these devices. Described below is OSHA's guidance and our concerns related to
workplace use of the emergency escape masks.
National Institute for Occupational Safety and Health (NIOSH) Approval
In December 2001, NIOSH established criteria for certifying open-circuit, self-contained
breathing apparatus (SCBA) for occupational use by emergency responders for protection against
CBRN agents. Since then, SCBA models from several manufacturers have been approved. If
responders are expected to participate in an emergency response or remain in the area of a
chemical/biological weapon attack, then only a NIOSH-approved CBRN SCBA respirator would
currently be allowed under OSHA's Respiratory Protection Standard. This requirement is
especially critical since workers would be exposed to atmospheres that are largely unknown and
could possibly present a hazard that is immediately dangerous to life or health (IDLH). Where
the employer cannot identify or reasonably estimate the employee exposure, the Respiratory
Protection Standard requires the employer to consider the atmosphere IDLH.
NIOSH began accepting applications on March 24, 2003 to test and evaluate full-facepiece
air- purifying respirators (APRs) for use against CBRN agents. The evaluation criteria specify
that the respirator must meet minimum requirements identified in applicable paragraphs of 42
CFR Part 84, requirements based on existing national and international standards, and special
requirements for CBRN use. The special requirements testing provides for protections against
139 potential CBRN respiratory hazards, including chemical warfare agents and selected toxic
industrial chemicals. Some of the masks presently on the market have been tested by SBCCOM
(U.S. Army Soldier, Biological, and Chemical Command) against only three chemical/biological
warfare agents. It is unknown how effective they will be against other test chemicals.
There are as yet no CBRN air-purifying escape respirators that are NIOSH-approved.
NIOSH has initiated a standards development program that will result in new certification test
criteria for CBRN air-purifying escape respirators by the end of this year. Guidance on these
respirators will be found on NIOSH's website on their
Respirator Topic page, as more information becomes available.
Use and Selection
Most of the masks presently marketed are devices to be used for emergency escape from a
chemical/biological warfare agent-contaminated area or release zone. These masks are currently
not NIOSH-approved respirators, and OSHA regulations would prohibit their use for employees
who are required to respond to (rather than escape from) an incident.
Another area of concern is that such masks may offer little or no protection from many
chemicals. Testing of these masks has been limited; some have been tested only to three or four
substances at fairly low concentrations rather than the 107 chemicals that NIOSH believes this
type of mask should be effective against. NIOSH is currently conducting benchmark evaluations
as part of the effort to determine potential certification test concentrations.
OSHA's Respiratory Protection Standard, 29 CFR 1910.134 (or its State Plan equivalent),
mandates that all employees required to wear a respirator be included in a written respiratory
protection program that details workplace-specific procedures. Key procedures which must be
addressed in the program are the proper selection of respirators, medical evaluation of employees
required to wear the respirators, fit testing, proper use and maintenance of respirators, training,
and an annual evaluation of the program. The standard requires that only NIOSH-approved
respirators be used.
However, emergency escape masks may allow people to safely escape from an incident
where their work area has been contaminated by chemical or biological agents. In this case,
when such use is voluntary on the part of the employees and not required by their employers, the
requirements of the voluntary-use provisions (i.e., paragraph (c)(2)) of the Respiratory Protection
Standard would apply. This paragraph does not require that all elements of the Respiratory
Protection Standard be implemented for those whose use of respirators is voluntary and the
masks are used for escape only. Instead, these employees would need to be provided the
information in Appendix D of the standard and the employer would need to establish and
implement those elements of a written program that would ensure that the use of the respirator
did not present a health hazard to the user. Employers would also need to establish and
implement procedures for the proper use of these escape masks. Escape hoods/masks must be
used only for escape.
Training is necessary to ensure that the respirator itself does not become a hazard. Even
when the use is voluntary, it is essential that workers be thoroughly trained in the proper use of
escape masks. In addition, workers need to know the conditions that limit use of the escape
mask, e.g., these masks neither supply clean breathing air nor filter carbon monoxide, so their use
in a fire or other oxygen-deficient atmosphere would not provide the necessary protection.
Training should include the opportunity to actually wear the escape mask. For example, one
manufacturer cautions that improper use of the nose clip can cause a negative pressure in the
hood and render the mask ineffective. In a building evacuation, it may be necessary to move
quickly. The physical condition of the person with regards to respiratory rate, heart rate, and
facial perspiration may compromise mask performance. Training should be done initially, and
then repeated at least annually.
At least one manufacturer advertises that their masks have been found effective for over an
hour for several chemical agents. However, effectiveness depends on such variables as humidity,
temperature, and amount of exertion by the user. This advertisement may give some employees a
false sense of security (and lull them into thinking they can linger in the area) since some
manufacturers make no mention about a more critical variable: the concentration of the chemical
in the air. Employees should be taught to don the mask properly and leave the area immediately.
Another area of concern is that although several of the available masks were tested against a
few chemical warfare agents, they may offer little or no protection from many of the other
chemicals likely to be used by terrorists. Many experts believe a terrorist attack would more
likely involve a large quantity of other, more readily obtained, industrial chemicals such as
chlorine or ammonia, rather than one of the chemical warfare agents. Employees need to know
the location of, and how to access, their masks. Accordingly, escape masks should be readily
available to employees. If they are kept in an inaccessible location, e.g., a locked closet, it may
be more effective to quickly retreat to a safe area without a mask.
Masks do not offer general skin protection. If there were a chemical attack, no mask or
respirator alone would be enough to protect employees since many chemical warfare agents can
also penetrate through the skin. Consequently, there will be a continued risk to employees who
remain in the release area due to skin absorption of the chemical agent. In cases where
employees are required to remain in the area of release, full-body chemical protection, such as
chemical suits, would be needed.
Poor Communication Capability
The design of many escape masks make communication difficult. Wearing a nose clip and
a mouth bit, or speaking through a nose cup, prohibits or strongly impairs speech. Hoods that
cover the wearer's head may also impair hearing.
We hope you find this information helpful. If you have any further questions, please feel
free to contact our Directorate of Enforcement Programs at (202) 693-2100.