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ISEA says a NIOSH respirator testing proposal needs more work.


ISEA has told the National Institute for Occupational Safety and Health (NIOSH) that it should rethink its proposal to add a fit test procedure to the certification process for half-mask respirators.
NIOSH had proposed what it calls a Total Inward Leakage (TIL) test, addressing concern that workers are at risk when they use respirators that don’t fit. The proposal is supposed to provide increased assurance that a particular respirator will fit a certain set of workers, based on a test procedure that uses representative face sizes and shapes.
ISEA supports individual fit testing of respirators as the only way to ensure that workers are properly protected against airborne hazards. This fit testing must be done to the individual worker, as required by OSHA, rather than as part of a generic process when the respirator is undergoing certification testing.  Manufacturers do not believe that the evaluation of TIL performance proposed by NIOSH will produce useful, repeatable results. It could also complicate user fit testing and selection of respirators, with the unintended consequence of less fit testing of individual workers. 
ISEA and member companies testified at a December 3, 2009 public meeting on the TIL proposal. Following that meeting,  ISEA’s Respiratory Protection Group commissioned an independent study to determine whether the NIOSH proposed TIL test would produce consistent, reproducible results.  Researchers tested filtering facepiece and elastomeric respirators from different manufacturers, selected by an independent advisory panel, using the test protocol proposed by NIOSH. In addition, the study panel evaluated the results of NIOSH benchmark testing of 24 respirators and compared them to the results obtained in the ISEA testing.  The findings of the study confirmed weaknesses in the test protocol, and ISEA included the test report when it submitted its comments to the NIOSH docket on March 27. 
Among the conclusions of the ISEA study was the recommendation “that NIOSH consider conducting additional tests of representative filtering facepiece and elastomeric respirators with multiple trials, donnings, and panels, following the methodology used in its study. Results would lead to a better understanding of between- and within-subject variability and may suggest methods for simulating and predicting fit performance for the population of respirator wearers.”

ISEA has reiterated its request, first made in a petition to the Secretary of Health and Human Services in January, that NIOSH delay a final TIL rule until additional research can be conducted. ISEA’s comments, including the research report, are available here. To review all the documents in the TIL rulemaking, go to the NIOSH docket.


UPDATE:  On April 20, NIOSH officially reopened the comment period until September 30, 2010.  The agency will hold another public meeting on the TIL proposal in June or July.