Dr. Stephanie Lynch - Mar 18, 2020

New guidance on OSHA 1910.134

On March 14, 2020, the Occupational Safety and Health Administration (OSHA) released new temporary guidance concerning OSHA’s Respiratory Protection standard. This guidance is meant to ensure that healthcare workers have access to the respiratory protection they need to protect against COVID-19. Previously, OSHA recommended the use of N95 filtering facepiece respirators, but there are now anticipated shortages of N95 filtering facepiece respirators.

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It is important to understand that N95 respirators provide the lowest level of acceptable protection against COVID-19. Therefore, OSHA now recommends that employers supply healthcare personnel who provide direct care to patients with known or suspected coronavirus with other respirators that provide higher protection than N95s. This includes N99 or N100 filtering facepieces, reusable elastomeric respirators with appropriate filters or cartridges, or powered air purifying respirators (PAPR).

This temporary enforcement guidance also recommends that healthcare employers change from a quantitative fit testing method to a qualitative testing method to preserve integrity of N95 respirators. This is because quantitative testing of filtering facepiece respirators destroys the respirator in the process. Quantitative fit testing methods will still be appropriate for elastomeric respirators and tight fitting PAPRs.

Reuse of filtering facepiece respirators or the use of elastomeric respirators or PAPRs will require a post-use cleaning process. Elastomeric respirators can be assigned to a specific employee. They also store easily and for long periods of time, which may save money over time. PAPRs with loose-fitting hoods do not need to be fit tested and they can be used by health care workers for whom an acceptable seal cannot be achieved due to facial hair or other factors. However, PAPRs (loose and tight fitting) are much more expensive. Elastomeric respirators and PAPRs are not currently and have not historically experienced the equipment shortages that now impact disposable N95 respirators.

With regards to compliance with this new guidance, OSHA field offices have the discretion to not cite an employer for violations of the annual fit testing requirement if employers:

Make a good faith effort to comply with the respiratory protection standard;

Use only NIOSH-certified respirators;

Implement strategies recommended by OSHA and Centers for Disease Control and Prevention for optimizing and prioritizing N95 respirators;

Perform initial fit tests for each healthcare employee with the same model, style, and size respirator that the employee will be required to wear for protection from coronavirus;

Tell employees that the employer is suspending the annual fit testing of N95 respirators to preserve the supply for use in situations where they are required to be worn;

Explain to employees the importance of conducting a fit check after putting on the respirator to make sure they are getting an adequate seal;

Conduct a fit test if they observe visual changes in an employee’s physical condition that could affect respirator fit; and

Remind employees to notify management if the integrity or fit of their N95 respirator is compromised.

The temporary enforcement guidance is in effect beginning March 14, 2020 and will remain in effect until further notice.

If you decide to switch to the use of a new, higher protection respirator, please note that this will require an initial fit test. Before the fit test, employees will need to be educated on the use and care of their new respirator. As always, OHD is here to help with your respiratory protection program in every way possible.

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Written by Dr. Stephanie Lynch