Respirator Requirements in Industry and a Concern on Double Masking

I worked in heavy industry for 25 years, and due to various respirable hazards, wearing Respirators were a constant thing. At one point in my career there, for 8+ years, I was a union representative. During that time, I was an Instructor of Negative Pressure Air Purifying Respirators. We used the usual types.

Respirators Image Line 1

Respirators Image Line 2

Half Face (First Row, First 2). The Disposable one (Third) wasn’t really used at work, it’s known as a Filtering Facepiece Respirator (FFR).

Second Row, the Full Face.

The Half and Full Face Respirator types use 2 External Cartridges, Filters, or Filter Cartridge Combinations and had Exhaust Valves. (Exhaust Valves are taboo for the Pandemic Usage, the FFR shown in the First Row has an Exhaust Valve as well).

We also had applications for Breathing Air Situations, for performing certain jobs, and using hoses (Air Lines) to supply Breathing Air (and the employee wears a small pressurized bottle with 5 minutes of Air to escape if the Air Line malfunctions), and for SCBA Rescues and Emergency Work, for Escape in general (we had potential and actual exposures to Cyanide, Hydrogen Sulfide, Anhydrous Ammonia, etc.). Pressurized Full Face Respirator Facepieces assured that any leakage was from Inside the Facepiece to the Outside, preventing the contaminant from getting in.

Shown below is a Facepiece for use with Supplied Air delivered through an Airline. It can also be used with SCBAs (Self Contained Breathing Apparatus like Firemen use).

Respirators Image Line 3

Since some of our exposures were so severe, Breathing Air was requisite in many situations to work, and some of the work atmospheres (rarely) were so extreme, employees needed to wear Level A Totally Encapsulated HazMat Suits where the Breathing Air SCBA (Self Contained Breathing Apparatus) is contained within the suit.

This is how men and women at work needed to dress, at times, for Work. All the way, on occasion, to the Level A Suit.

Behind the Swirl: Levels of PPE

Since ALL RESPIRATORS FACEPIECES LEAK, Negative Pressure Air Purifying Respirators have usage restrictions, there has to be:

• 19.5% Oxygen or more, but not more than 23% (Oxygen Enrichment can lead to Fires)
• The Exposure can’t be Immediately Dangerous to Life and Health (IDLH)
• The Filters, Cartridges, or Combination Filter Cartridges must be appropriate for the exposure
• It must be a Known Exposure at a Known Exposure Level
• The Respirator Must be Appropriate for that Level
• And there’s probably more things.

Half Face Tight Fitting Respirators have an Assigned Protection Factor (APF) of 10. This means they reduce the contaminant inside the Facepiece by 10x to what is found outside.

Benzene was a concern for us. OSHA has set the Permissible Exposure Limit (PEL) for Benzene to 1 Part Per Million (PPM), up to that level you didn’t need a respirator. Over 1 PPM to 10 PPM, you could wear a Half Face Respirator, and in theory, at 10 PPM, the level inside the Mask is 1 PPM or Lower. It reduces it by a factor of 10.

For Benzene over 10 PPM up to 50 PPM, you have to wear a FullFace Negative Pressure Air Purifying Respirator since they have an Assigned Protection Factor of 50 and will reduce the concentration Inside the Mask (compared to the outside) by 50x.

We were protecting against Gases, Vapors, Fumes, and Particles, but viral particles are minute. How much leakage past a Tight Fitting Respirator Facepiece is permissible with viruses?

So, Surgical Masks, they aren’t Tight Fitting, they aren’t designed to seal to the face, and if they sealed to the face, or closely approximate N-95 Filtering Facepiece Respirators (FFR), here’s the issue I have with them, from an OSHA Letter of Interpretation I found, online:

OSHA Standard Interpretations

“This is in response to your letter of March 31, addressed to Ms. Bonnie Friedman, in the Occupational Safety and Health Administration’s (OSHA’s) Office of Public Affairs. We apologize for the long delay of this response. Enforcement of this standard will begin on the compliance date, October 5, 1998.

In your letter, you requested clarification on several respiratory protection issues. There were several statements listed that you sought to determine if they were true or not. The statements are responded to in the same order as given in your letter.

Please note that in your letter, you used the term “medical surveillance.”The respiratory protection standard 1910.134 uses the term “medical evaluation”.

Statement: Use of the disposable paper type dust respirators does not require medical surveillance.


Non-voluntary use of a filtering facepiece (dust mask/disposable paper type dust respirator) requires that the employer establish and implement a written respiratory protection program with worksite-specific procedures. The respiratory protection program must include the medical evaluation of employees.

Voluntary use of a filtering facepiece respirator does not require medical evaluation. The employer needs only to ensure that the dust masks are not dirty or contaminated, that their use does not interfere with the employee’s ability to work safety, and provide a copy of Appendix D to each voluntary wearer.

Statement: Use of an air supplied positive pressure face mask does not require medical surveillance unless intended for rescue or emergency purposes.

Statement: Use of an air supplied positive pressure hood does not require medical surveillance unless intended for rescue or emergency purposes.


The new respiratory protection standard, 29 CFR 1910.134, states, “The employer shall provide a medical evaluation to determine that the employee’s ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace.” Employees that use any respirators including respirators such as air supplied positive pressure face masks or hoods must have a medical evaluation before use. Medical evaluations are needed to prevent injuries and illnesses that can arise from respirator use. Clinical studies show that even positive pressure respirator use can harm an employee. Respirator use of all kinds can cause alterations in breathing patterns, hypoventilation, retention of carbon dioxide, and an increase in workload on the body.”

Governments are mandating Mask Use, and with the CDC Pushing Double Masking, are violating the principles that have been imposed on Employees by Government Regulations concerning the Safe use of Respiratory Protection. If Double Masking Approximates the use of an N-95, and an N-95 Requires a Medical Evaluation and Fit Testing, if we disregard the Fit Testing at this time, we are still in a position where the Government is making Decisions on Mask Use that, logically, may be harmful to people wearing them. Clearly, OSHA Makes this comment, and I agree:

“Medical evaluations are needed to prevent injuries and illnesses that can arise from respirator use. Clinical studies show that even positive pressure respirator use can harm an employee. Respirator use of all kinds can cause alterations in breathing patterns, hypoventilation, retention of carbon dioxide, and an increase in workload on the body.”

Did you know that the CDC presides over the National Institute of Occupational Safety and Health, otherwise known as NIOSH, that NIOSH researches Industrial Hygiene Issues, Including Respiratory Protection, and they usually are more rigid in protection recommendations than OSHA (OSHA is trying to balance Jobs and Health, NIOSH tends to focus more on Health)?

How did the CDC end-up suggesting Double Masking without considerations of the issues OSHA detailed in the Letter of Interpretation, above?


If Double Masking approximates an N-95 (If worn correctly, but who’s been given proper instructions) then the issue with “alterations in breathing patterns, hypoventilation, retention of carbon dioxide, and an increase in workload on the body” must, logically, come into play.

If NIOSH is part ofthe CDC’s decision about Double Masking, IMHO, it’s more than problematic, since NIOSH should have considered the possible deleterious effects.

If the CDC did not consult NIOSH, it’s IMHO, more than problematic, as NIOSH is the Agency to do Research on Respiratory Protection Products and not the CDC.

If the CDC reasons that the fit will still be so poor that Breathing won’t be a problem, they are promoting something that likely won’t work as effectively as believed and therefore, IMHO, is still problematic.

The following is a Fit Test Machine (like the one used at my workplace to assess the Fit of Tight Fitting Respirators), and it’s being used at the link to Fit Test a Disposable Filtering Facepiece Respirator (FFR). At one point during the pandemic, OSHA at least Temporarily Suspended Fit Testing Due to the Destructive Nature of the Fit Test on Disposable FFR Respirators (they poke a hole in if for the sensing tube). Instead of temporarily suspending Fit Testing, they should have emphasized it, for the more the mask leaks, the greater the likelihood that people will become infected. FFR are generally for particles 0.3 Microns and Larger. covid-19 is 0.125 Microns and Smaller. Yet Tuberculosisis 1 to 5 Microns, so an FFR, properly fitted and worn, will clearly work for Tuberculosis.

Respirator Fit Testing / Mask Fit Testing∣ Intrinsic Analytics

And health issues from wearing Masks for prolonged periods of time, look at this:

A Case of Goggle/Mask Related Impetigo During COVID‐19 Pandemic

Admittedly, they said that the skin disorder is usually self limiting and generally resolves without medication over time, but it’s from Bacteria being held against the face due to a Mask and Goggles. Part of the cure, in this case, was to stay home where she could stop wearing the Mask and Goggles until otherwise approved by her doctor.

I’d suspect that other harmful bacteria can also be so held and introduced to the system, possibly the respiratory system.

When I go where Masks are needed, I clean Shave and Wear an N-95, I’m not anti-Mask, but I’m concerned that the “Science” behind them is not honest and not inclusive of other possible harms.

Author: Dr-Artaud

A Doctor that is not a Doctor, but named after a character in the movie "No Such Thing", as is the Avatar.

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