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.
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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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