Understanding Compliance with OSHA’s Respiratory Protection Standard During the Coronavirus Disease 2019 (COVID-19) Pandemic

McCraren Compliance
Photo: CDC/NIOSH

The Coronavirus Disease 2019 (COVID-19) pandemic has had an unprecedented impact on the availability of respirators and fit-testing supplies. This document is intended to help employers understand and comply with OSHA’s temporary enforcement guidance for the Respiratory Protection standard (29 CFR § 1910.134).

Background
The COVID-19 pandemic has resulted in a public health emergency that has dramatically increased demand for respirators, particularly N-95 filtering facepiece respirators (FFRs), as well as fit-testing supplies ordinarily used to ensure that respirators fit workers properly and provide the expected level of protection. Shortages (either intermittent or extended) of both FFRs and fit-testing supplies have posed tremendous challenges. In order to allow essential operations to continue, many employers have had to utilize contingency and crisis strategies that are ordinarily not compliant with OSHA’s Respiratory Protection standard. Examples of contingency and crisis strategies include: extended use of disposable FFRs, decontamination and reuse of disposable FFRs, and the use of foreign FFRs not approved by the National Institute for Occupational Safety and Health (NIOSH). It is important for employers to understand that deviations from normal respirator use come with increased risk for workers that, in certain circumstances, may only be allowable during this public health emergency because the alternative of no respiratory protection presents a greater danger to workers. In order to ensure adequate protection for workers during the use of contingency and crisis strategies, OSHA has issued temporary enforcement guidance to its Compliance Safety and Health Officers (CSHOs). This guidance allows CSHOs to exercise enforcement discretion in cases involving workplace exposures and an employer that is unable to comply with certain provisions of the Respiratory Protection standard because of supply shortages and has thus found it necessary to implement contingency or crisis strategies for respirator use by workers. Read More»


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OSHA Approves New Respirator Fit Testing Protocols to Protect Workers From Airborne Contaminants

WASHINGTON, DC – The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) today issued a final rule that provides employers with two new fit testing protocols for ensuring that employees’ respirators fit properly.

The new protocols are the modified ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol for full-facepiece and half-mask elastomeric respirators, and the modified ambient aerosol CNC quantitative fit testing protocol for filtering facepiece respirators.  Both protocols are variations of the original OSHA-approved ambient aerosol CNC protocol, but have fewer test exercises, shorter exercise duration, and a more streamlined sampling sequence.

These two quantitative methods add to the four existing in Appendix A of OSHA’s Respiratory Protection Standard, which contains mandatory respirator fit-testing protocols that employers must choose from to protect employees from hazardous airborne contaminants. The rule does not require employers in general industries, shipyard employment, and construction to update or replace their current fit testing methods, and does not impose additional costs.

The rule becomes effective September 26, 2019.