NIOSH Comments to DOL on Review of the Chlorine Institute Request for Variance by J. B. Moran, June 25, 1985

摘要

The testimony concerns a NIOSH review of the Chlorine Institute request for variance. NIOSH approves chlorine mouthpiece respirators for escape only from atmospheres containing 10 parts per million (ppm) or less of chlorine (7782505). The mouthpiece respirator requires the wearer to inhale through the mouth only and is equipped with a nose clip. Without the sense of odor warning, the wearer may not be able to detect breakthrough at the end of the respirator service life. The Chlorine Institute proposed five conditions to justify the use of the chlorine mouthpiece respirator for general work practice tasks lasting up to 15 minutes in 10ppm or less chlorine. All of these conditions are administrative controls which are therefore variable in their effectiveness. The request for variance outlines some advantages that the Institute feels the mouthpiece respirator has in regard to short term usage in the chlorine battery facility. However, there are two major disadvantages which the Chlorine Institute did not address. First, dentures or other mouth or dental problems may cause some employees to be unable to use the mouthpiece respirator. Second, the mouthpiece prevents communication.