Lesson Learned Statement:To safeguard the health and safety of respirator users, facilities need to verify that service received from respirator vendors is adequate and appropriate. Facilities need to verify that respirators issued to workers are clean, in good repair, and that cartridges/canisters supplied by the vendor provide adequate protection in hazardous atmospheres.
Discussion:Inadequate respirator cleaning and maintenance services resulted in respirators that were unclean, disassembled, and potentially unsafe due to vendor installation of re-used cartridges. The vendor-installed combination (chemical and HEPA) respirator cartridges were re-used \ to the point that they had the potential to no longer protect users in hazardous atmospheres. Vendor-installed HEPA cartridges were re-used to the extent that breathing resistance was very high. An internal audit of the LITCO Respiratory Protection Program revealed that the vendor supplying cleaning and maintenance services, including testing and replacement of respirator cartridges, was not performing to contract specifications. An examination of respirators at several INEL facilities revealed problems with inadequate cleaning and maintenance, combination cartridges that showed evidence of multiple DOP tests, and high breathing resistance on many HEPA (Type H) cartridges. Multiple DOP tests (up to six times) were deemed to be a good indicator of the number of times the cartridge had been sent to the vendor and returned to the facility. The recycled combination cartridges were not limited in use to radiological atmospheres, but re-used in chemical environments. Based on this evidence of cartridge re-use and interviews with respirator users, the level of protection provided by these cartridges in hazardous atmospheres was deemed to be potentially inadequate.
Analysis:A LITCO quality assurance program is not in place to ensure that respirators are returned from the respirator servicing vendor in a condition adequate to provide protection to users in hazardous atmospheres. The vendor contract with Interstate Nuclear Services (INS) to perform respirator cleaning and maintenance for LITCO is technically inadequate to assure that necessary services are effectively performed. Changes to the contract have not been effectively managed, and vendor performance to approved contract specifications has not been monitored. An adequate means has not been implemented to monitor earned value associated with respirator services.
Recommended Actions:Several facilities at the INEL purchased respirator cartridges directly from the manufacturer to replace all those installed on cleaned respirators returned from the vendor. Site-wide actions are pending.
Originator:Idaho National Engineering Laboratory
Contact:Chris Snyder, Phone No.: (208)526-8390
Name Of Authorized Derivative Classifier:Dale J. Claflin
Name Of Reviewing Official:
Priority Descriptor:Yellow / Caution
Keywords:RESPIRATOR, CARTRIDGES, CANISTERS, AIR SUPPLY, FILTER
References:29 CFR 1910.134 ANSI Z88.2-1992 LITCO Program Requirements Document - 66, Respiratory Protection Program, Rev. 0
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DOE Function / Work Categories:Occupational Safety & Health - General
Hazard:Personal Injury / Exposure - Airborne Materials
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