Hold respirator fit testing annually, OSHA says

Question: I’m confused about the requirements for fit testing for respirators. Once you do the initial fit testing for a worker, is that sufficient until circumstances change, or do you have to repeat the fit testing annually? What if the worker is fit tested but very rarely, if ever, actually wears the respirator because it is only for emergencies?

Answer: Fit testing is required annually, but of course, the answer is not quite that simple. Occupational Health Management consulted with the federal Occupational Safety and Health Administration (OSHA), which provided this guidance from a memorandum sent to field investigators in August 1998:

The OSHA respirator standard, 42 CFR Part 84, requires that all tight-fitting respirators be fit tested on the employee. This applies to both positive and negative pressure tight-fitting respirators. Self-contained breathing apparatus (SCBA) also must be fit tested. But the employer does not have to conduct fit tests for any respirators that are worn voluntarily by the worker or for any type of loose-fitting respirator, even if it is required by OSHA or the employer.

The employee must pass a fit test before being initially cleared for respirator use, and "an annual fit test is required after the initial fit test." Additional fit tests also are required whenever there are changes in the employee’s physical condition that could affect respirator fit. New fit tests also are necessary if the employee changes to a different respirator with a face mask that fits differently.

OSHA points out that a "user seal check" does not qualify as a fit test. A user seal check is the procedure the employee follows each time he or she dons the face mask to ensure that it is seated properly on the face. The respirator standard makes no allowances for seldom-used respirators. Even if the employee in question never uses the respirator because it is intended only for emergency use by a fire brigade member, for instance, OSHA requires that the employee undergo fit testing on the same schedule and with the same requirements as one used on a daily basis.

However, the rules are different for "escape-only respirators," says Craig Moulton, an industrial hygienist with OSHA’s Office of Health Compliance Assistance in Washington, DC. He explains that OSHA does not require fit testing, not even initial fit testing, for escape-only respirators. If you choose to, you’re free to conduct fit testing on employees who might need to use an escape-only respirator, but it is not required.

Be careful. Moulton points out that escape-only respirators are not necessarily the same as seldom-used respirators. An escape-only respirator is provided only for exiting a hazardous environment in an emergency — a small, easily used respirator that provides only short-term protection. A SCBA does not count as an escape-only respirator.