OSHA’s requirements for respiratory protection

According to the Occupational Safety and Health Administration (OSHA), "An effective [respiratory protection] program requires a systematic approach to evaluating workplace conditions, selecting the appropriate respirator, ensuring the respirator fits, and maintaining the respirator properly." Here are some provisions of the standard (1910.139):

I. Training and Information

Employees must be trained prior to their initial use of a respirator, unless another employer has provided "acceptable" training within the past 12 months. They then must be retrained annually or when workplace conditions change, a new type of respirator is used, or inadequacies in the employees’ knowledge or use indicates that they need additional training. The training must include information explaining:

  1. why the respirator is necessary and how improper fit, use, or maintenance can compromise the protective effect of the respirator;
  2. limitations and capabilities of the respirator;
  3. use in emergency situations;
  4. how to inspect, put on and remove, use, and check the seals;
  5. procedures for maintenance and storage;
  6. recognition of medical signs and symptoms that may limit or prevent effective use;
  7. general requirements of the standard.

II. Medical Evaluation

Before the first fit-testing and use, employers must provide a medical evaluation to determine an employee’s ability to use a respirator. An annual review of the employee’s medical status is not required. The medication evaluation must include:

  1. A. identifying a physician or other licensed health care professional to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire;
  2. B. a written recommendation regarding the employee’s ability to use the respirator from a physician or other licensed health care professional;
  3. C. additional medical evaluations under certain circumstances, such as:

    1. if an employee reports medical signs or symptoms related to ability to use respirator;
    2. a physician or other licensed health care professional, program administrator, or supervisor recommends reevaluation;
    3. information from the respirator program, including observations made during fit-testing and program evaluation, indicates a need;
    4. 4. a change occurs in workplace conditions that may increase substantially the physiological burden on an employee.

III. Fit-Testing

All employees using a negative- or positive-pressure tight-fitting face-piece respirator must pass an appropriate qualitative fit test (QLFT) or quantitative fit test (QNFT). Fit-testing is required prior to initial use, whenever a different respirator face piece is used, and at least annually thereafter. An additional fit test is required whenever the employee reports or the employer or physician or other licensed health care professional makes visual observations of changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or an obvious change in body weight).

IV. Record Keeping

  1. Records of medical evaluations must be retained and made available per 29 CFR 1910.1020.
  2. A record of fit tests must be established and retained until the next fit test.
  3. A written copy of the current program must be retained.

V. Program Evaluation

The employer must conduct evaluations of the workplace as necessary to ensure proper implementation of the program and consult with employees to ensure proper use.

(Editor’s note: For a copy of the Respiratory Protection Standard, go to: www.osha.gov/SLTC/respiratoryprotection/standards.html. Additional information is available from the Small Entity Compliance Guide for Respiratory Protection at www.osha.gov/Publications/SECG_RPS/secg_rps.html.)