Issue Date: November 27, 2013
From: Roland Berry Ann, Acting Chief, Technology Evaluation Branch, National Personal Protective Technology Laboratory
Subject: Chemical Warfare Agent (CWA) Testing for NIOSH CBRN Respirator Approvals
BACKGROUND: The National Institute for Occupational Safety and Health (NIOSH) employs the Army Edgewood Chemical Biological Center’s (ECBC) Test Laboratory to conduct the Chemical Warfare Agent (CWA) testing portion of Chemical, Biological, Radiological, and Nuclear (CBRN) testing. These services support the NIOSH respirator approvals providing CBRN protections.
On November 18, 2013, ECBC notified NIOSH of errors with some of its test data. ECBC’s internal assessment of these data indicates that concentrations of the CWAs used in testing were less than that required by NIOSH test procedures.a Testing conducted during the period of July 2012 through October 2013 is affected. The majority of the affected testing was conducted in support of NFPA 1981, 2013 edition approvals in process.
AFFECTED PROTECTIONS: NIOSH evaluations for granting approval for CBRN protection require a broad range of testing in order to ensure protection at the levels indicated on the approval labels.
The particular tests in question relate only to the ability of the respirator configurations to protect against CWAs. The affected respirator configurations will provide all of the non-CBRN protections for which the NIOSH approvals are issued. The non-CBRN protections are verified by NIOSH-conducted tests and evaluations. These NIOSH-conducted tests have not been compromised by the errors discovered in the CWA testing.
However, the affected respirator configurations MUST NOT BE USED TO PROVIDE PROTECTION AGAINST CWA HAZARDS until retesting has verified that these protections are provided.
REQUESTED MANUFACTURERS’ ACTIONS:
On November 22, 2013, NIOSH requested that manufacturers immediately stop labeling any affected respirator configurations as CBRN approved, and notify customers who may have purchased the affected respirator configurations.
These testing errors adversely affect pending and/or completed approvals conducted for Avon, Draeger, Immediate Response Technologies, MSA, and Scott Safety. Since receiving the approval, Scott Safety has delivered respirator configurations affected by these testing errors.
Their Technical Bulletin, Scott Safety End User Notification: NIOSH CBRN Testing will be available at: https://www.scottsafety.com/en/us/Pages/servicecommunication.aspx
Scott Technical Support: 1-800-247-7257 or 1-800-AIR-PAKS
Scott Safety will notify you within the next ten business days if you have been identified as having affected respirator configurations. IF YOU ARE IN DOUBT about whether your respirator configuration is affected, please contact Scott Safety immediately.
NIOSH met with ECBC on November 19, 2013 to discuss the impact of the errors on current and pending NIOSH CBRN respirator approvals. As a result, ECBC has temporarily halted operations and, in agreement with NIOSH, will validate all test procedures before resuming operations. CWA re-testing at ECBC of all respirators previously submitted for approval for which CWA testing was conducted during the July 2012 through October 2013 period is expected to resume with an expedited schedule by January 2014 and be completed by April 1, 2014.
NIOSH and ECBC regret the impacts of this situation. Both NIOSH and ECBC are committing additional resources to increase testing capacity to expedite the re-testing schedule as much as feasible. We are working together to resume ECBC operations as quickly as possible and to incorporate additional checks and balances to ensure that this situation will not be repeated.
In addition to continuing to work with ECBC to complete CWA testing and coordinate with Safety Equipment Institute to issue CBRN SCBA approvals as expeditiously as possible, NIOSH is:
1. Working with all five affected manufacturers to expedite identification and NIOSH receipt of appropriate configurations to be re-tested and expedite resolution of the current issues,
2. Working with the National Fire Protection Association (NFPA) to mitigate the impact of these delays in completing NFPA 1981, 2013 Edition approvals and to enable NFPA to take appropriate actions, and
3. Working with the Department of Homeland Security/Federal Emergency Management Agency– Assistance to Firefighter Grant Program Office to discuss the need to extend the availability of the funds for equipment grants.
NIOSH will keep all interested parties informed until this matter is resolved.
aURLs for the NIOSH Standard Testing Procedures for the chemical warfare agent tests conducted on CBRN respirators, both air-purifying and atmosphere-supplying.