Less Frequently Asked (But Still Important) Questions About Respirator Use

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Arecent Google search on the term “respirator articles” produced over 1.6 million hits. Many of these articles cover the same information. This Q&A series answers some of the less frequently asked but still very important questions about the safe and effective use of respirators.

The questions are fielded by 3M Company construction respirator and regulatory specialist Don Garvey, CIH, CSP, 3M Occupational Health and Environmental Safety Division.

OSHA requires a program administrator to oversee respirator use. What qualifications does that person need to have?

The Occupational Safety and Health Administration (OSHA) Respiratory Protection Standard 29CFR1910.134(c) states the employer must designate a program administrator who is qualified by appropriate training or experience that is commensurate with the complexity of the program. While no specific training requirements (e.g., course titles or hours) are specified, courses on how to establish and administer a program are often available from local branches of the National Safety Council, National Institute for Occupational Safety and Health (NIOSH) Educational Resource Centers, universities with occupational health and safety programs, and PPE manufacturers.

If workers bring their own personal respirators to the job site, is the employer still responsible for their safe use?

Yes, the employer is responsible for the functionality and appropriateness of all respirators used in their facility. The respirator program administrator must ensure the worker is trained and understands the capabilities and limitations of the particular respirator chosen.

Can workers wear contact lenses with a respirator?

There is no OSHA regulation against wearing contact lenses, but employers may want to prohibit them in certain situations – like when a 1/2 facepiece respirator is used in a dusty environment or when irritating or corrosive materials are used. A full-face respirator or powered-air respirator with a hood or helmet that protects the eyes may be a better option in these cases.

“29CFR1910.134(m)(4) requires fit test records be made available to the employee for inspection and copying.”

When must medical evaluations be completed? And do they have to be done by a physician?

With the exception of strict voluntary use of filtering facepiece respirators, a satisfactory medical evaluation must be made before any use of a respirator – including prior to fit testing. OSHA specifies a “physician or other licensed health care professional” (PLHCP) operating within the scope of the person’s practice may conduct the evaluation. The evaluation may be made by a “hands on” examination covering OSHA-specified topics or may be conducted using the OSHA Respirator Medical Evaluation Questionnaire in Appendix C of the respirator regulations. Some companies offer this evaluation using the questionnaire as either a mail-in or online service.

How often does the medical evaluation need to be repeated?

OSHA does not state a specific time requirement but says the evaluations must be repeated if:

  • An employee shows medical signs or symptoms related to the ability to wear a respirator
  • The PLHCP or program administrator deems it necessary
  • Observations during fit testing or while wearing the respirator indicate a need for reevaluation
  • Significant changes occur in the work-place that may increase the physical burden on the worker

If none of the above triggers occur, the NIOSH Guide to Industrial Respiratory Protection suggests that, for most respirator usage, medical evaluations should be repeated every two to five years, depending on age NIOSH Guide to Industrial Respiratory Protection DHHS [NIOSH 87-116. 1987.]

Is a chest X-ray or spirometry exam required as part of the evaluation?

OSHA does not require it, but the PLHCP may require it as part of their evaluation process. X-rays or spirometry may be required due to exposure to certain hazardous materials like asbesto, but not simply because of wearing a respirator. Spirometry or a chest X-ray alone would not be considered a complete respirator medical evaluation.

Can a fit test be done before the medical evaluation?

No. A satisfactory medical evaluation must be made before any fit testing.

If a worker has a beard but still passes the fit test, can he keep the beard?

No. Where respirators are required to be worn, it is not permitted to have facial hair that protrudes under the respirator seal or interferes with respirator valve function. This applies to all tight-fitting facepieces, including those facepieces used as part of a powered-air or supplied-air respirator system. While this requirement does not apply if the respirator is used in a strictly voluntary situation – when airborne contaminants are below the permissible exposure limit and respirator use is not required by the employer, it is still recommended as good practice. For workers with limited facial hair, powered-air or supplied-air respirators with loose-fitting hoods or helmets may be an option.

Can a qualitative fit test be used for a tight-fitting powered-air purifying respirator (PAPR) or supplied-air respirator (SAR)?

Yes, a qualitative fit test can be used for PAPR or SAR. The facepiece must be tested in the negative pressure mode.

If the respirator is used strictly voluntarily with no airborne contaminant hazard and no employer requirement to wear a respirator, is a fit test still required by OSHA?

No, but a medical evaluation may still be required, depending on the specific situation.

How long must I keep fit test records?

OSHA 29CFR1910.134(m)(2)(ii) only requires fit test records to be kept until the next fit test is completed. Employers may keep the records longer if desired.

If a worker leaves the employer, can they get a copy of the fit test record?

Yes. 29CFR1910.134(m)(4) requires fit test records be made available to the employee for inspection and copying. Record must include:

  • Employee name
  • Type of fit test
  • Specific make, model, style, size of respirator
  • Test date
  • Pass/fail result for qualitative test
  • Fit factor for quantitative test

The N or P95 filters are stated to be at least 95 percent efficient for particle size of 0.3 micrometer (µm) mass median aerodynamic diameter. Does that mean these filters are not able to capture particles smaller than that size?

No. Particle filters do not act like a sieve or strainer. Three primary mechanisms act in filters to remove particles:

  • Impaction – dominant for large particles greater than 0.6 µm
  • Interception – operative for particles greater than 0.1 µm
  • Diffusion – operative for particles less than 0.4 µm; dominant for particles less than 0.1 µm

Due to the filtration mechanism of diffusion, filters have been shown to have high filtration efficiency of even sub-micron-sized particles. Particle penetration into the respirator is primarily due to an inadequate seal between the respirator and the wearer’s face rather than leakage through the filter. This is why obtaining a proper fit is so important.

How long will the organic vapor cartridge last before it needs to be replaced?

There is no standard answer for that. Cartridge service life is dependent on the specific chemical in question, the airborne concentration of the chemical and the breathing rate of the respirator wearer. To a lesser extent, the worksite temperature and humidity will also impact cartridge service life. Most respirator manufacturers have online programs to help customers estimate service life. The above-listed factors must be known, however, to make use of these programs. APC


Be sure to consult OSHA regulations and your respirator manufacturer’s user instructions and literature for all the details. Further information on respiratory protection programs and proper respirator selection and use can be found at www.osha.gov and www.cdc.gov/niosh.

 

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