United States Nuclear Regulatory Commission - Protecting People and the Environment

Information Notice No. 84-24: Physical Qualification of Individuals to Use Respiratory Protective Devices

                                                          SSINS No.: 6835  
                                                          IN 84-24         

                               UNITED STATES  
                       NUCLEAR REGULATORY COMMISSION 
                    OFFICE OF INSPECTION AND ENFORCEMENT 
                          WASHINGTON, D.C. 20555  

                               April 5, 1984 

Information Notice No. 84-24:   PHYSICAL QUALIFICATION OF INDIVIDUALS TO 
                                   USE RESPIRATORY PROTECTIVE DEVICES 

Addressees: 

All nuclear power plant facilities holding an operating license (OL) or 
construction permit (CP); research and test reactors, fuel facilities, and 
Priority I material licensees. 

Purpose: 

This information notice is provided as a notification of the death of an 
individual that recently occurred while the individual was wearing a 
respirator. The individual had been medically qualified by the licensee to 
use respiratory protective devices per the requirement stated in 10 CFR 
20.103(c)(2). Guidance is provided that licensees may find helpful in their 
continuing efforts to ensure respirator users are medically qualified. It is
expected that addressees will review the information provided for 
applicability to their respiratory programs. Suggestions contained in this 
information notice do not constitute NRC requirements and, therefore, no 
specific action or written response is required. 

Description of Circumstances: 

While working in a nuclear power plant's low-level radioactive waste 
handling building, a 24-year-old licensee contract employee collapsed while 
wearing a supplied-air hood. The individual died of acute heart failure 2 
hours later at a nearby hospital. 

The exact cause of death is not known. The individual had complained of 
fatigue before being stricken. An autopsy failed to uncover any underlying 
medical condition that could have accounted for the individual's death. An 
evaluation of the breathing air being supplied to the individual's 
supplied-air hood and supporting equipment indicated that the breathing air 
was safe to use and that the respirator and supporting equipment was 
functioning properly. Discussions with the licensee's physician and another 
physician indicated that it was also unlikely that circumstances surrounding
the incident, such as the stress of using a respirator, the degree of 
difficulty involved in performing the work task, or heat stress induced by 
the work, were sufficient to have caused the individual's acute heart 
failure. A consulting physician suggested the death  



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                                                            IN 84-24       
                                                            April 5, 1984  
                                                            Page 2 of 3    

may have been caused by irregular heart contractions or arrhythmia leading 
to heart fibrillation and finally to the inability of the heart to pump 
blood to the lungs and peripheral tissues. This condition is extremely rare,
especially in very young people; nonetheless, the incidence is not zero. 

Guidance: 

10 CFR 20.103(c) states that a licensee may make allowance for the use of 
respiratory protective equipment in estimating exposures of individuals to 
airborne radioactive material provided that certain minimum respiratory 
program requirements are implemented and maintained. One essential program 
element is the requirement for an initial determination by a physician 
before respirator use, and at least every 12 months thereafter, that the 
individual is physically able to use the respiratory protection equipment. A 
physician is to determine what health and physical conditions are pertinent 
and the proper method for effectively evaluating these conditions. All the 
regulatory requirements were apparently satisfied in the case described 
above. Additional guidance that licensees and their physicians may find 
useful in implementing and evaluating respiratory protection programs is 
presented in the following paragraphs. 

The degree of employee physical incapacitation, type of respirator, and 
degree of difficulty associated with the work assignment need to be 
considered in evaluating overall employee fitness to use respiratory 
protective equipment. Information concerning previous history or symptoms of
cardiovascular and pulmonary diseases are obviously important considerations
in making these determinations. Discussions with one physician having 
responsibility for determining if individuals are physically able to use 
respiratory protection equipment identified that more individuals fail to 
qualify as respirator users because of cardiovascular problems rather than 
pulmonary function problems. The additional stress caused by use of 
respiratory protective equipment on workers is not well understood in all 
cases and may be very difficult to account for when determining an 
individual's suitability for respirator use. The effects of respirator use 
range from the obvious physical burden incurred from the weight (up to 35 
pounds) of self-contained breathing apparatus to more subtle effects from 
inhalation and exhalation resistances and the psychological effect of 
reduced vision and mobility. Licensees should ensure that the physician's 
findings regarding an individual 's ability to use specific kinds of 
respiratory protective equipment are effectively and consistently 
implemented. Licensees are reminded of the 10 CFR 20.103(c)(3) requirements 
to inform respirator wearers of their right to leave the work area and to 
take relief in the event of physical/mental discomfort (among other things). 
Recognizing that a wearer's ability to effectively use a respirator can be 
diminished by such transitory factors as head/chest colds, headaches, and 
fatigue, one licensee has in place a policy encouraging users to report 
these temporary physical conditions so that, whenever possible, these 
affected workers are temporarily assigned routine job tasks not requiring 
respirator protection. 
.

                                                            IN 84-24       
                                                            April 5, 1984  
                                                            Page 3 of 3    

A recently published ANSI Standard, ANSI Z88.6, "Physical Qualification for 
Respirator Use," is a consensus standard written largely by a group of 
physicians. Licensee physicians may find it useful in evaluating the kinds 
of various medical conditions that might have contraindications to 
respirator use, the effect of different types of respiratory protective 
equipment on individuals, and the means of estimating and matching physical 
capability with work rates.  In some cases environmental factors such as 
heat and humidity may be the limiting factors in the selection of types of 
respirators and periods of respirator use. Special attention may be given to 
those circumstances that necessitate working in very hot or humid 
environments in protective clothing that impedes the worker's innate 
physical capability for ridding the body of excess heat. Selection of 
positive-pressure, air-purifying, or atmosphere-supplying respiratory 
protective equipment may provide some incidental body cooling but may not be 
adequate to allow for reasonable periods of respirator use. There are 
several type of body cooling systems available using various cooling schemes 
(i.e., ice-pocketed vests, liquid circulation through coils, and vortex 
cooling). 

Recipients should review the information discussed for possible 
applicability to the respiratory protection program at their facility. No 
written response to this information notice is required. If you desire 
additional information regarding this matter, contact the Regional 
Administrator of the appropriate NRC Regional Office or this office. 


                                   Edward L. Jordan, Director 
                                   Division of Emergency Preparedness 
                                     and Engineering Response 
                                   Office of Inspection and Enforcement 

Technical Contacts: L. Hendricks, RES 
                    (301) 443-7675 

                    J. E. Wigginton, IE 
                    (301) 492-4967 

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