By Jake Jacobson
Intech Equipment & Supply
I use a fresh air breathing system almost every day. It is legal, compliant, and very expensive. I have to change the filters frequently, and I need to clean it consistently. However, I can’t live without it. You see, I have sleep apnea, and the fresh air breathing system I am referring to is my CPAP machine, which helps me sleep at night. I change my hypoallergenic filters about every 3 weeks, I wash and sanitize my face mask weekly, and I have no issues. The CPAP machine operates just like an ambient air fresh air breathing system used in spray foam applications, which is the subject of this article.
The Spray Foam Markets have gained market share and popularity over the past decade. With that popularity comes visibility. With that visibility are regulations and oversight from organizations like OSHA, NIOSH, EPA. It is important to know the new rules of the spray foam game. This is no longer the wild, wild, west. The good news about spray foam application is that we know that with the proper protection, you can prevent any health and safety issues that may occur with your crews in the field. One of the biggest decisions a spray foam company or owner/operator faces is in the breathing systems deployed for his spray foam crews. Before we get into the details of the products, let’s review some basics of providing legal and safe breathing air to your crews.
First and foremost, you must have a respirator program in place. If you do not have one, don’t fret, they have already been created for you. Respiratory Protection Program Model: http://polyurethane.americanchemistry.com/Resources-and-Document-Library/7095.PDF
The buck stops with the employers of the spray foam installation companies. It is the employers responsibility to make sure that operations are safe for applicators and anyone that may be exposed to spray foam chemicals. The specific OSHA regulation is 29 CFR § 1910.134. Here is a link to the regulation. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=standards
My objective is to not get buried in the details of OSHA regulations, but to highlight the key components so that you can make an informed decision that will keep your company in compliance and profitable. As a foundation to this article, it is important to highlight some definitions you need to know. I took these directly out of the OSHA regulation 29 CFR 1910.134(b)
Air-purifying respirator (APR) means a respirator with an air-purifying filter, cartridge, or canister that removes specific air contaminants by passing ambient air through the air-purifying element.
Powered air-purifying respirator (PAPR) means an air-purifying respirator that uses a blower to force the ambient air through air-purifying elements to the inlet covering.
Supplied-air respirator (SAR) or airline respirator means an atmosphere-supplying respirator for which the source of breathing air is not designed to be carried by the user.
The employer is also responsible for providing Grade D Air. What is Grade D Air?
- Set by Compressed Gas Association www.cga.net
- Referenced by NIOSH 42CFR84.141(b)
- Oxygen 19.5%-23.5%
- Hydrocarbons or oil (condensed) 5mg/m3 max.
- Carbon Monoxide (C0) 10 ppm max
- Carbon Dioxide (CO2) 1,000 ppm max
- Odor – no noticeable taste or smell
- No toxic contaminants at levels that make the air unsafe to breathe
Now that we know the definition of Grade D air, we are going to look at the components that make up breathing systems certified to supply grade D air. Essentially you have an air source, and pump, a breathing tube, and a mask or hood. NIOSH has a 32 page document, entitled NIOSH Respirator Logic, which is referenced in the appendix. Forgive me for being over simplistic, but your decision on respirators really boils down to 3 decisions:
- Respirator Type: Air-Purifying (Cartridge) vs. Supplied Air
- Mask Style: Supplied Air Full Face Mask vs. Hood
- Supplied Air Method: Ambient Air vs. Compressed Air
Regarding respirator type, you are only going to use the cartridge style respirator in outside environments, such as exterior applications or inside your SPF truck or trailer. For the most part, your spray foam applicators and helpers in the spray area should be using a full face mask or hood. The mask style decision is based on a combination of factors including applicator preference, application type/area and spraying conditions. See table below comparing full-face mask to hood.
|Medical evaluation required||Medical evaluation required|
|Annual fit test required||Annual fit test NOT required|
|Facial hair can not interfere with seal||No facial hair limitations|
|Available with APR, PAPR, SAR||Only available on PAPR and SAR|
|Good vision, can fit into tight spaces||May decrease range of vision|
|Minimal cooling||More cooling air and comfort|
|4 cfm minimum||6 cfm minimum|
|Portions of head and neck exposed||Full head and neck coverage|
|Mask replacement cost higher and cartridges change schedule needed||Lower replacement cost for hood; Due to overspray|
The next decision, choosing your supplied air method, is based on how you pump a positive air flow to your applicators. The Spray Foam Market predominantly uses either Ambient Air Pumps or High Pressure Systems supplied by an air compressor, utilizing a multi-stage filtration system. Please see comparison table below on Supplied-Air Pump Systems:
Ambient Air (Low Pressure)
High Pressure (Compressor)
|Breathing Hose (typical)||
Allegro – 3/8” by 100’
Bullard – 1/2” up to 300’
100’ to 300’
|Purchase Price (1 man, 100’)||
$ 1,100 to $1,300
$ 2,300 to $2,500
|Purchase Price (2 man, 100’)||
$1,600 to $1,800
$3,600 to $3,800
$ 200-400/ year
$ 400-800 /year
|Air Quality Testing||
|Test Frequency, $/test||
3-12 months; $100-$200/test
Simple, Low Maintenance, No CO Monitoring
Longer Hose, More Masks, Cooling capable
In summary, the ambient air systems are less expensive to purchase, have lower maintenance costs, and do not require ongoing CO Monitoring and testing. The main difference between ambient air system manufactures are the breathing hoses. For example, Bullard uses ½” i.d. breathing hose, which allows more volume of air to the mask compared to a 3/8” i.d. breathing hose. The inside diameter of the fittings in the system also affects the CFM or volume of air. The high pressure systems have higher purchase price, more maintenance, and require ongoing testing of CO monitoring. The advantage to the high pressure system is that you can use longer breathing hose, up to 300’. High pressure systems can also add cooling air to hoods and torso, which allows applicators to spray longer without taking breaks to cool down. Another big issue in making your breathing system decision is what is required to keep your system compliant with regulations.
Regarding compliant systems, we recently emailed a question, in quotes below, directly to NIOSH.
“I had a question about fresh air respirator systems. If dealing with approved systems (filtration panel, breathing air hose, mask) would one be able to mix components from both? In other words could someone use a filtration panel from one manufacturer and hose + mask from another manufacturer?” – Jay A. Parker, Physical Scientist with NIOSH-
NPPTL, replied as follows. “NIOSH approves supplied- air respirators, and the approved assembly must include the air supply hose, i.e. the air supply hose is a required component and must be part of the approved assembly. NIOSH does not approve respirable breathing air systems or filtration panels. A NIOSH approved supplied –air respirator could be used with a filtration panel for the breathing air that was manufactured by another manufacturer because the filtration panel along with any other component of the breathing air supply system, such as the compressor or pump, are not part of the approved respirator assembly. NIOSH supplied -air respirator approvals include NIOSH Cautions and Limitations which are shown on the NIOSH approval label for the respirator. One of these Cautions and Limitations for airline supplied-air respirators is: D-Air-line respirators can be used only when the respirators are supplied with respirable air meeting the requirements of CGA G-7.1 Grade D or higher quality. These requirements for respirable breathing air are covered in the OSHA requirements in 29 CFR 1910.134 Section i, Breathing Air Quality and Use. OSHA requirements include the requirement to use grade D breathing air quality or better (1910.134 (i)(1)(ii). OSHA requirements also include requirements for ensuring that the levels of carbon monoxide do not exceed 10 parts per million, as well as other requirements. Please refer to the OSHA regulation 29 CFR 1910.134(i) for further information on breathing air quality and use.”
Compliance issues are of more concern with the high pressure systems, as they are required to have sensors and monitors on board that require maintenance and testing to prove they are working. Testing can be done with self testing kits, or third party testing companies. Cost of each test ranges between $100 and $200.
There might be a comfort factor that weighs heavily in your decision. A good analogy would be to compare two single family homes, same floor plan, next door to each other, with identical back yards. One house has a pool and the other doesn’t. Which house has more maintenance and higher maintenance costs? Most logical people would say the house with the pool has more maintenance and higher costs. Which house is going to be more comfortable and enjoyable in the hot months? Unless you have a fear of water, most people would choose the house with the pool. There is a cost to that comfort, whether you maintain the pool yourself, you hire a pool guy, or you let the pool go without maintaining. I think the same can be said for your breathing systems. The high pressure systems do offer more comfort and cooling capacity, and higher productivity potential, but the cost is higher ongoing maintenance costs and higher cost of failure if equipment is not properly maintained. However, one might justify the benefits of having a high pressure system by adding cooling capability to increase spray time, production, and profits. The cooling capability alone might justify the system in extreme hot climate zones. However, most companies will need to see increased productivity and profitability to justify the additional maintenance costs.
Speaking of maintenance, we polled some industry officials and breathing system manufactures on the subject of testing and maintenance and summarized them below:
Frequency of testing for Grade D:
- Acknowledges OSHA does not provide specific guidelines as to how often to test for Grade D air or better
- Recommends, but by no way requires quarterly testing
- Requires that Grade D or better be supplied at all times
Uniformity of manufacturer in a system:
- Fresh air systems are submitted for OSHA and NIOSH approval as systems. Therefore, mixing and matching any parts or pieces is not allowed
- Employers who are found to be non-compliant with OSHA regulations may face fines and possible Imminent Danger Postings.
The American Chemistry Council offers a sample of a complete Respiratory Protection Program. Listed below are areas that may be a challenge to implement:
- A qualified program administrator is required to oversee the implementation, maintenance, and reevaluation of respiratory protection program and to ensure the effectiveness of the program
- The administrator is responsible for seeing that all work areas are in accordance with OSHA standards
- Detailed documentation must be maintained regarding air system inspection, maintenance, and repairs
- Detailed documentation must be maintained regarding breathing air quality/grade
- Detailed documentation must be retained regarding the training of employees and these records must be updated as new employees are trained and when existing employees receive refresher courses
THIRD PARTY TESTING
Frequency of testing: All depends on manufacturer’s specifications, application, and OSHA regulation
- Purchase or rent an air sampling kit (depending on the lab used)
- Take a sample using supplied kit (instructions vary from lab to lab)
- Return sample to lab
- Results are available online for viewing or mailed within 1-7 days (depending on lab and service requested)
- Single sample kits available for $100-120
- Analysis available for $100-120 per sample
Frequency of Testing – No definitive time table provided. Instead:
Provided a FAQ page that did not mention having air tested to ensure Grade D or better is being provided to end user
Provided a table with definition of Grade D air
- Provided two pages from a 3M Respirator Education brochure with a section on Frequency of Air Quality Testing:
“American National Standards Institute (ANSI) Z88.2-1992 recommends “acceptance” (initial) and “periodic” testing for breathing air systems. 7 ANSI allows the frequency of testing to be adjusted to the performance characteristics and history of each system. For example, if quarterly testing of a well maintained system reveals no significant contamination over the course of a year, sampling might be reduced to semi-annual or annual frequency.” -3M Respirator Education, Breathing Air Quality, Page A34, Frequency of Air Quality Testing
Bullard’s Respiratory Protection Guidance for the Spray Foam Insulation Industry:
How often must I test the breathing air?
1910.134(c)(1)(ix) This section says that the employer must have procedures for regularly evaluating the effectiveness of the program. “Regularly” is not defined in this sub part. In other parts of the standard, such as with fit testing, most tests are specified as at least annually. 1910.134(i)(5)(iii) This section says that the supplied air system must have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically, following the manufacturer’s instructions. In addition, OSHA expects respirator wearers to follow manufacturer instructions for respirators and other equipment.
*In short, one won’t find a simple answer.
Frequency of Testing for Grade D testing, from a manufacturer’s standpoint: annually
AIR SYSTEMS INTERNATIONAL
- Interprets OSHA testing requirements as “whatever the “provider”/company, of the breathing air decides.”I
- Frequency of Testing recommended twice a year, when an issue comes up, and as needed.
INTECH EQUIPMENT & SUPPLY
Maintenance of Compressor Systems and bringing up to compliance:
- Service all air systems, compressors, filters, and panels to manufacturer’s specifications and at the recommended intervals
- Remove ATF as lubricant
- Verify installation of coalescing filter in systems
- Pertains to Screw, Piston, and Hydrovane Air Compressors
General comments on breathing system set ups:
- Two man pump with ½” breathing hose is best for one man
- Three man pump with ½” breathing hose is best for two man
- Two different cooling vests available.
- The best set up is the two man pump with ½” breathing hose set up for one man.
In doing my research for this article, there were plenty of quotes directly from OSHA 29 CFR 1910.134, but not many recommendations on preventive maintenance and frequency of testing. I have tried to present the facts so they were easy to understand. If you don’t understand, or need further clarification, there is a list of resources at the end of this article. You can make the determination as to what types of breathing systems will meet your needs. I hope that you feel better about your knowledge of Grade D Breathing Air. Now you can breathe easier and get a good nights sleep.
For more information on Grade D Breathing Systems and Spray Foam Equipment please contact:
About Intech Equipment & Supply
Intech Equipment & Supply, founded in 1995, is an independent, full service spray foam equipment integrator and parts supplier, offering equipment, parts, turn-key mobile spray systems and expert technical assistance. Their main customers are commercial roofing contractors, insulation contractors, and the materials suppliers that serve those customers. Typical markets served are spray foam roofing, spray foam insulation, single ply roofing, and commercial roof coatings applications. Intech Equipment & Supply has been recognized by Graco as a Top 20 Graco HPCF North America Distributor for 3 years in a row 2010, 2011, and 2012. For more information, visit www.intechequipment.com.
Bullard Web Site Respiratory Standards
FREE Online Health & Safety Certification
National Institute of Occupational Safety & Health
NIOSH Respiratory Decision Logic
Occupational Safety & Health Adminstration
SPF Health and Safety
Spray Polyurethane FoamAlliance