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Throughout the course of my occupational health career, I have come across many myths and misconceptions. Below are some common misconceptions regarding the OSHA respirator standard (29 CFR 1910.134) I have encountered during my time managing respiratory protection programs.
A medical clearance for respirator use should be completed prior to initial respirator fit testing.
I frequently have found a large number of individuals unaware that a medical clearance for respirator use should be completed prior to initial respirator fit testing. The physician or licensed healthcare provider (LHCP) would indicate the person was cleared for use for a particular type of respirator (Face Filtering (dust mask), half-face, full face, etc.). At a minimum, the employer would need to provide additional evaluations if the employee shows signs or symptoms that are related to their ability to wear a respirator as a follow-up. There is no specific annual requirement for medical evaluations in the standard. We do find most physicians or LHCP would also indicate how long the person is cleared for use. This is typically one or two years from the initial clearance. This is totally at the discretion of the physician or LHCP who may prescribe annual testing to ensure employees’ continued ability to wear a respirator.
I also find that individuals are not aware that pulmonary function testing is not required. Pulmonary function testing alone does not constitute medical clearance for respirator use either. Those OSHA standards that include medical surveillance and have provisions for pulmonary function testing are 29 CFR 1910.1001 Asbestos, CFR 1910.1043 Cotton Dust, 29 CFR 1910.1028 Benzene and 29 CFR 1910.1048 Formaldehyde. The physician or LHCP may require pulmonary function and other testing if they deem it necessary for the medical determination for use of the respirator.
When it comes to respirators, one size or manufacturer may not fit all.
Respirator Fit Testing
I am often challenged when providing fit testing with having only one brand of respirator in use at the facility. Remember, the 29 CFR 1910.134 Respirator standard requires that you have sufficient number of respirator models and sizes that the respirator is acceptable to, and correctly fits, the user. We understand employers would like to use only one brand of respirator, however one size or manufacturer may not fit all. With many years of fit testing I have learned that size from brand to brand varies greatly in the fit.
Should you be doing your own fit testing, please refer back to Appendix A 1910.134 Fit Testing Procedures. These are mandatory and we have heard OSHA actually checks your fit testing accuracy by observation and have cited many employers for missed protocols (returning to normal breathing, etc.) not being followed. The timing of each exercise and ensuring the challenge agent (Bitrex or Saccharin) is maintained at the appropriate levels is very important during testing. Please take a few minutes to refresh yourself on these mandatory procedures if you are providing your own fit testing.
EI is available and ready to meet your medical clearance, fit testing and pulmonary function testing needs. Our physicians can provide respirator medical clearances utilizing our online service while EI’s NIOSH approved technicians are happy to provide on-site pulmonary function testing and respirator fit testing services for your convenience.