OSHA’s Temporary Fit Guidance for Respiratory Protection Concerning Covid-19

On March 14, 2020 OSHA issued a temporary fit guidance for respiratory protection for Health Care Providers (HCP) in light of the current Covid-19 pandemic crisis. The guidance was in response to a memorandum by the President and was done to ensure HCP have proper and adequate access to N95 or greater respiratory protection.

On March 11, 2020 President Trump authorized the Memorandum on Making General Use Respirators Available. In the memorandum President Trump stated “It is the policy of the United States to take proactive measures to prepare for and respond to public health threats, including the public health emergency involving Coronavirus Disease 2019 (COVID-19), which was declared by the Secretary of Health and Human Services on February 4, 2020.” He further stated “We must ensure that our healthcare providers have full access to the products they need. …Unfortunately, at present, public health experts anticipate shortages in the supply of personal respiratory devices (respirators) available for use by healthcare workers in mitigating further transmission of COVID-19.

To help prevent the spread of COVID-19, the Secretary of Health and Human Services shall take all appropriate and necessary steps with respect to general use respirators to facilitate their emergency use by healthcare personnel in healthcare facilities and elsewhere… Additionally, the Secretary of Labor shall consider all appropriate and necessary steps to increase the availability of respirators.”

OSHA has provided temporary guidance for 29 CFR § 1910.134, regarding required annual fit-testing which took effect March 14^th and remains in effect until further notice.

The Centers for Disease Control and Prevention (CDC) currently recommends that Health Care Providers (HCP), who are providing direct care of patients with known or suspected COVID-19, practice infection control procedures. These include engineering controls (e.g., airborne infection isolation rooms), administrative controls (e.g., cohorting patients, designated HCP), work practices (e.g., handwashing, disinfecting surfaces), and appropriate use of personal protective equipment (PPE), such as gloves, face shields or other eye protection, and gowns. Appropriate respiratory protection is required for all healthcare personnel providing direct care of these patients. (For additional guidance, see COVID-19 Hospital Preparedness Assessment Tool, https://www.cdc.gov/coronavirus/2019-ncov/hcp/hcp-hospital-checklist.html.)

OSHA recommends HCP employers follow existing CDC guidelines, including taking measures to conserve supplies of these respirators while safeguarding HCP. One such measure is that healthcare employers may provide HCP 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. They may also change the method of fit testing from a destructive method (i.e., quantitative) to a non-destructive method (i.e., qualitative).

Workers should visually inspect the N95 respirator to determine if the structural and functional integrity of the respirator has been 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. 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.

OSHA field offices should use their own discretion regarding enforcement of the annual fit testing requirement as long as employers:

• 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 fit check each time they put it on to make sure they are getting an adequate seal from their respirator;
   
• Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit 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 with the respirator and, thus, are not being adequately protected; and,
   
• Remind workers they must inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.

For our Respiratory Protection Training Program in English or Spanish and other training products related to Respiratory Safety, please visit: https://www.osha-safety-training.net/product-category/topic/subject-respiratory-safety/

For our PPE Training Program in English or Spanish and other training products related to PPE, please visit: https://www.osha-safety-training.net/product-category/topic/subject-personal-protective-equipment/

If you prefer to train your employees remotely or from any computer, please visit the PPE Safety Training or Respiratory Safety Training section at Online OSHA Training by National Safety Compliance