COVID-19 Updates: OSHA Issues Temporary Enforcement Guidance on Respirator Fit Testing for Health Care Providers

In the ongoing fight against the COVID-19 outbreak, OSHA’s Respirator Fit Testing (RFT) requirements are probably the last thing on the minds of health care providers. However, proper fit of respiratory PPE is essential to protecting health care workers from exposure to COVID-19. After all, if a respirator is not fitted properly, it provides little if any protection.

OSHA has acknowledged the unprecedented rise in the use of N95 filtering facepiece respirators in response to the COVID-19 outbreak, and that this increased use is likely to put an unreasonable strain on health care providers who must address the needs of patients, while still ensuring compliance with OSHA’s Respiratory Protection Standard — specifically the standard’s RFT requirements.

To address these concerns, OSHA issued a March 14, 2020 memo to regional administrators containing temporary enforcement guidance for certified safety and health officers (CSHOs) when inspecting health care provider (HCP) establishments for compliance with the Respiratory Protection Standard’s RFT requirements.

What Enforcement Guidance is OSHA Issuing?

OSHA’s enforcement guidance only applies to RFT requirements for health care facilities, and does not affect other Respiratory Protection Standard requirements. For the foreseeable future, OSHA will be relaxing enforcement of RFT requirements under 29 CFR § 1910.134(f)(2) as long as HCPs:

• Make a good-faith effort to comply with 29 CFR § 1910.134;
• Use only NIOSH-certified respirators;
• Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use;
• Perform initial fit tests for each HCP with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19
• Inform workers that the employer is temporarily suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators for use in situations where they are required to be worn;
• Explain to workers the importance of performing a user seal check (i.e., a fit check) at each donning to make sure they are getting an adequate seal from their respirator, in accordance with the procedures outlined in 29 CFR § 1910.134, Appendix B-1, User Seal Check Procedures. (See OSHA Respiratory Fit Testing tutorial videos)
• Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or obvious changes in body weight) and explain to workers that, if their face shape has changed since their last fit test, they may no longer be getting a good facial seal and are not being adequately protected;
• Remind workers that they should inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.

The enforcement guidance memo concludes by reminding HCPs that all other provisions of the Respiratory Protection Standard remain in force, and employers who fail to comply with requirements for initial fit testing, maintenance, care and training in the Respiratory Protection Standard will be cited under the applicable section(s) of 29 CFR § 1910.134.

For additional information on RFT procedures visit the CDC’s Healthcare Respiratory Protection Resources web page

How Do I Ensure Compliance with RFT Requirements?

Due to shortages of N95 respirators, OSHA is advising that HCPs may change the method of fit testing from a destructive method (i.e., quantitative) to a non-destructive method (i.e., qualitative) in order to conserve available N95 respirators. (see CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use)

Additionally, OSHA’s enforcement guidance notes that “healthcare employers may provide health care personnel with another respirator of equal or higher protection, such as N99 or N100 filtering facepieces, reusable elastomeric respirators with appropriate filters or cartridges, or powered air purifying respirators (PAPR).” However, if you use an alternate respirator type, you must ensure that you are using the appropriate OSHA-approved RFT protocols for those respirator types.

For more information on selecting the proper respirator types for health care workers, visit the CDC’s article on Understanding respiratory protection options in Healthcare

OSHA specifically notes that its RFT enforcement guidance is only temporary, and that health care employers should still strive to meet the requirements for initial and annual respirator by performing fit tests according to OSHA-accepted RFT protocols for the respirator types being used.

VelocityEHS Can Help

OSHA RFT protocols can be difficult to interpret, let alone put into practice. In addition to the time required to perform the tests themselves, the complexity of these protocols can make compliance a significant burden for HCPs, and for other employers who use respirators in the workplace.

The VelocityEHS Respirator Fit Test (RFT) solution simplifies the scheduling, documentation and follow up of RFT activities, and gives you a powerful platform for managing RFT requirements across multiple locations and large numbers of employees. You can easily determine which employees use which types of respirators, schedule and assign fit tests, and document results to demonstrate compliance.

VelocityEHS RFT Solution features include:

• Built-in OSHA-approved testing protocols and a complete library of editable pre-test procedures that make it easy to select and perform the right RFT protocols for the respirator types in your workplace
• Time-saving RFT capabilities like dynamic data fields that guide you through the testing process based on selected protocols and respirator types, reducing fit testing time by an average of 60%
• Intuitive RFT program controls let you manage RFT schedules and protocols through one easy-to-use interface, helping standardize RFT programs across each of your locations
• Streamlined regulatory compliance & reporting tools make it easy to track RFTs across a range of user-defined parameters to quickly filter and search RFT records and demonstrate compliance
• Fast, simple system implementation means you can be up and running with the industry’s best RFT capabilities in as little as a few days!!

The VelocityEHS RFT solution is part of our comprehensive suite of Industrial Hygiene software. To learn more, visit our Solutions Page or give us a call at 1.866.919.7922