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Commonly Asked Questions Regarding OSHA’s Respiratory Protection Standard

By Tony Watson, CIH, CSP

Workplace Hygiene offers respirator fit testing courses several times during the year. Attendees generally consist of safety professionals, occupational nurses, industrial hygienists, program administrators, fit test technicians, and others. We have found that among the attendees there are some recurring questions regarding OSHA’s revised Respiratory Protection Standard, 29 CFR 1910.134. Some of the more common questions, along with answers, are listed below.

Q: It only takes me about two minutes to conduct qualitative fit tests using saccharin or Bitrex™. Is this OK?

A: These tests cannot be done following OSHA protocols in this period of time. There are seven exercises required when conducting these qualitative fit tests, in addition to the screening portion of the tests. Each exercise is performed for one minute. If done correctly and no problems with the fit of the respirator are encountered, these tests will take between 10 and 15 minutes to complete.

Exercises to be performed during a qualitative fit test include:

1. Normal Breathing
2. Deep Breathing
3. Turning Head Side to Side
4. Moving Head Up and Down
5. Talking (Rainbow Passage)
6. Bending over or Jogging
7. Normal Breathing

Q: Do tight fitting elastomeric respirators that are used on a voluntary basis need to be fit tested?

A: OSHA does not require fit testing for any respirator used voluntarily. It is not required because the employer is essentially certifying that an atmospheric exposure hazard does not exist by allowing voluntary use. However, the employer must establish and implement procedures for medical qualification, cleaning, storage and maintenance in order to assure that respirator use itself does not present a hazard when any respirator other than a filtering facepiece respirator (dust mask) is used voluntarily.

Q: Can employees with beards use respirators?

A: OSHA clearly states that nothing (including facial hair) is to come between the sealing surface of a tight-fitting respirator and the face when respirator use is required. Beards may be worn with loose fitting respirators (e.g., such as hoods or helmets) that do not require a face-to-facepiece seal.

OSHA has also stated that voluntary respirator users may have beards, again because voluntary use presumes there is no atmospheric exposure hazard to protect against. Employers should recognize that allowing use in these circumstances may undermine other program elements.

Q: Do Self Contained Breathing Apparatus (SCBA) respirators have to be quantitatively fit tested?

A: The standard allows tight fitting, positive pressure respirators such as SCBAs, supplied-air respirators or powered air-purifying respirators to be fit tested either qualitatively or quantitatively.

Q: What are the criteria that OSHA uses in determining whether respirator use and development of a written respiratory program is required?

A: OSHA requires employers to establish and implement a full written respiratory protection program when employee exposures to airborne contaminants are above the Permissible Exposure Limits (PELs) or when the employer requires respirator use. A limited written program is required for voluntary users of all but filtering facepiece respirators.

Q: How often are training, fit testing, and medical evaluation and/or program evaluation required?

A:
Training
Training is required prior to initial use and at least annually thereafter. Additional training is required if changes in the workplace or respirator make previous training obsolete, if inadequacies in the employee’s knowledge or respirator use indicate additional training is needed, or if any other situation arises in which retraining appears necessary to ensure safe respirator use.

Fit Testing
Fit testing (tight fitting facepiece respirators only) is also required prior to initial use and at least annually thereafter, and whenever a different size, style, or brand of respirator is to be used. Additional fitting is required based on inputs from employees, program administrators, medical services providers, and physical changes in the respirator user.

Medical Evaluation
Medical evaluation is required initially, prior to fit testing, and whenever an employee reports medical signs or symptoms that are related to the ability to use a respirator.

Other situations that require additional medical evaluations include:

  1. A PLHCP, supervisor, or respirator program administrator informs the employer that an employee needs to be reevaluated;
  2. Information from the respiratory protection program, including observations made during fit testing and program evaluation indicates a need for employee reevaluation; or
  3. A change in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

Program Evaluation
Program evaluation should be conducted as frequently as necessary to ensure continued effectiveness of the program. The employer is to regularly consult with employees to obtain their input regarding the program so that any problems can be addressed.


   
 

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