COVID-19 pandemic: OSHA issues temporary enforcement guidance for respirators in health care

Washington — In an effort to preserve the supply of N95 filtering facepiece respirators during the COVID-19 pandemic, OSHA has temporarily suspended its requirement for annual respirator fit testing in the health care industry.

The temporary enforcement guidance will remain in place until further notice, according to a March 14 memo from Patrick Kapust, acting director of OSHA’s Directorate of Enforcement Programs. The agency is directing its field offices to “exercise enforcement discretion” on its annual fit testing requirements – 1910.134(f)(2) – if employers:

• Make good-faith efforts to comply with regulations.
• Use only NIOSH-certified respirators.
• Perform initial fit tests for each of their health care providers with the same model, style and size of respirator that the worker will need to protect against COVID-19. “Initial fit testing is essential to determine if the respirator properly fits the worker and is capable of providing the expected level of protection.”
• Explain to workers the importance of performing a seal check (i.e., a fit check) each time they put on a respirator to ensure the respirator is providing an adequate seal, in accordance with 1910.134, Appendix B-1.
• Conduct a fit test when observing visible changes in an employee’s physical condition, such as facial scarring, dental changes or changes in body weight. “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 with the respirator and, thus, are not being adequately protected.”
• Remind workers they should inform their supervisors or respirator program administrators if the integrity or fit of their N95 respirator is compromised.
• Implement strategies from OSHA and the Centers for Disease Control and Prevention for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use.

Two such strategies are:

• Use of respirators with equal or higher protection than an N95, such as N99 or N100 filtering facepiece respirators, powered air-purifying respirators, or reusable elastomeric respirators with the correct filters or cartridges.
• Use of qualitative fit testing for N95 respirators instead of quantitative fit testing, because the former is a “nondestructive method.”

Workers should visually inspect their N95 respirators to ensure the structural and functional integrity is not compromised.

“Over time, components such as the straps, nose bridge and nose foam material may degrade, which can affect the quality of the fit and seal,” the memo states. “If the structural and functional integrity of any part of the respirator is compromised, or if a successful user seal check cannot be performed, discard the respirator and try another respirator.”