OSHA Position on Fit Testing During COVID-19

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OSHA’s Position on Fit Testing during COVID-19 Pandemic

The US Occupational Safety and Health Administration (OSHA) is the agency that enforces respirator use and selection in US workplaces. The OSHA respiratory protection standard [29 CFR § 1910.134(f)(2)] requires a fit test prior to initial use of any tight-fitting respirator new to the employee. This includes anytime an employee switches to a different size or model of tight-fitting respirator. This includes filtering facepiece respirators.

OSHA also requires a repeat fit test annually for each respirator the employee uses. In an enforcement memo dated March 14, 2020, OSHA field offices declared that they will exercise enforcement discretion concerning the annual fit testing requirement, 29 CFR § 1910.134(f)(2), for healthcare facilities using N95 filtering facepieces during the COVID-19 outbreak. Subsequently, in an enforcement memo dated April 8 2020, OSHA expanded this guidance to include all workplaces and expanded it to cover all types of filtering facepiece respirators (FFRs). 

OSHA states that a good faith effort to comply with 29 CFR 1910.134 includes stressing the importance of visual inspection, user seal checks and proper training as part of an overall respiratory protection program.

Selecting Alternate Models of Filtering Facepiece Respirator (FFR)

Due to the significant increase in demand for respirators, many healthcare providers have had to select alternate models of respirators during the COVID-19 pandemic. Many facilities have found that they can increase their available supply by including standard FFRs in addition to the surgical N95s that they typically use. Standard N95s are appropriate for many tasks in healthcare.

Employers originally using surgical N95 models and now trying to decide on a standard respirator model to incorporate into their respiratory protection program may want to identify models that are similar in construction to the ones familiar to their employees. Other employers may face similar supply challenges.

When respirators and fit testing supplies are constrained or not available, it may be preferred to use a respirator with similar construction and fit characteristics than providing a “non-similar” model. 3M laboratory testing indicates respirator models with similar construction may be more likely to fit a worker similarly.

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