April 21, 1986
Mr. Derek Mullins
Compliance Industrial Hygiene
The Industrial Commission of Arizona
P.O. Box 19070
Phoenix, Arizona 85005-9070
Dear Mr. Mullins:
This is in response to your letter of March 24, concerning the use of
nonapproved M-17 gas masks.
The M-17 gas mask is used for the protection of army personnel against
chemical warfare. The Mine Safety Appliance Company (MSA) was the principal
manufacturer of the mask under contract with the Department of Defense. From
my conversation with a technical representative of MSA, I learned that the
production of the M-17 was terminated in the early seventies. Since the
Defense Department owns the mold, MSA no longer stocks spare parts for this
mask. Furthermore, this mask was made in accordance with specifications for
military use. It may not pass the certification tests currently administered
jointly by the Mine Safety and Health Administration (MSHA) and[by]
the National Institute for Occupational Safety and Health (NIOSH) under the provisions of
[42 CFR 84]. MSA does not recommend the use of this mask by civilians.
[This document was edited on 03/22/99 to strike
information that no longer reflects current OSHA policy.]
Since the M-17 is not approved by
MSHA and NIOSH, this respirator may not be
used by workers other than enlisted military personnel. There are many
approved gas masks available with modern design, improved construction
materials, and with different types of canisters for protection against a
wide variety of air contaminants. There is no reason for OSHA to accept the
M-17 under a variance situation on the basis of unavailability. Furthermore,
the currently available M-17 masks were manufactured at least ten years ago.
The facepiece may have deteriorated and the sorbent probably has lost
effectiveness over such a long storage time. Besides, users can no longer
obtain spare parts and fresh canisters from MSA. Although the M-17 may be
purchased at an attractive price as compared to the currently approved gas
masks, the level of protection provided by this mask is questionable.
We hope we have addressed your concerns.
Supervisory Industrial Hygienist
Office of Science and