U. S. Department of Labor

Occupational Safety and Health Administration

Directorate of Enforcement Programs

Office of Health Enforcement

Safety and Health Information Bulletin

SHIB 03-08-29 (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.

The Occupational Safety and Health Act requires

employers to comply with hazard-specific safety and

health standards. 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 these

recommendations is not, in itself, a violation of the

General Duty Clause. Citations can only be based on

standards, regulations, and the General Duty Clause.

CBRN Escape Respirators

Introduction

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 (http://www.osha.gov/dep/evacmatrix/

index.html). This tool provides guidance to

employers on how to assess a risk of a terroristinitiated 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 fullfacepiece 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, http://ww.cdc.gov/

niosh/respinfo.html, 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 workplacespecific 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

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.

Skin Protection

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.