NIOSH Testimony on Respirator Fit Testing in the OSHA Lead Standard by J. D. Millar, October 1981.
NIOSH 1981 Oct:5 pages
This testimony concerns the interim rule proposed by OSHA to amend a section of the lead (7439921) standard and permit employers the option of using two or more proposed qualitative fit test protocols instead of the required quantitative fit test. NIOSH has reviewed the material submitted to the OSHA hearing record and concluded that the interim rule is not justified on the basis of relative health risks to workers. NIOSH believes that existing quantitative fit test methods are intrinsically and empirically superior to the qualitative methods and that respiratory protection programs based on quantitative tests are more likely to achieve the intended level of protection. NIOSH concludes that the quantitative method provides an objective, observable and verifiable measure of actual mask leakage not available with the quantitative method, and that the quantitative method has a superior capability for training the wearer in proper donning and wearing techniques. NIOSH also stresses that there is no need to sacrifice the greater protection afforded by the quantitative fit test due to concern for the potential hazards of di-2-ethylhexyl-phthalate as suitable alternatives to this substance exist.
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