OSHA has issued interim enforcement guidance to help combat supply shortages of disposable N95 filtering face piece respirators (N95 FFRs). OSHA is encouraging businesses to reassess their engineering controls, work practices and administrative controls to identify any changes they can make to decrease the need for N95 respirators.
If respiratory protection must be used, employers are encouraged to consider use of alternative classes of respirators that provide equal or greater protection compared to an N95 FFR, such as National Institute for Occupational Safety and Health (NIOSH)-approved, non-disposable, elastomeric respirators or powered, air-purifying respirators.
When these alternatives are not available, or where their use creates additional safety or health hazards, employers may consider the extended use or reuse of N95 FFRs, or use of N95 FFRs that were approved but have since passed the manufacturer’s recommended shelf life, under specified conditions.
OSHA field offices have the discretion to not cite an employer for violations of the annual fit testing requirement as long as 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 temporarily 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.
These respiratory protection requirements are waived for healthcare providers, but not necessarily other ‘essential’ businesses that remain open. Regardless, new user fit tests, medical clearance and training are still required. interim enforcement guidance
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