The Respiratory Protection Program is in place, the fit testing has been completed and documented, BUT what about the other regulatory requirements and considerations of the program?
All participants of the Respiratory Protection Program are expected to be diligent in observing practices pertaining to ensuring the safe use of respirators. As time goes by and wearing a respirator becomes old hat, is adherence falling along the wayside? For example:
- Are set procedures for inspecting, putting on, removing, and using the respirators being followed?
- Are wearers performing user seal checks in accordance with manufacturer’s instructions and the training provided at the time of fit testing, each time he or she puts on a tight-fitting respirator (such as N95 filtering facepiece respirators)?
- Has each wearer been monitored to determine if conditions have surfaced that prevent the good seal of respirators relying on tight facepiece-to-face contact? Such conditions may be a beard, long moustache, sideburns, or even razor stubble as well as scars, other facial deformities, piercings, and temple pieces on glasses. In addition, the absence of one or both dentures can seriously affect the fit of a facepiece.
- Are wearers leaving the respirator use area to adjust, change or inspect respirators-i.e. when they are not fitting correctly or impeding their ability to work (e.g., fogging of eyeglasses)?
- Are procedures outlined in the program for maintenance, storage, and cleaning or safe disposal of respirators that have been contaminated with chemicals or hazardous/infectious biological materials being observed?
On October 2, 2020, OSHA issued a temporary guidance for enforcing initial and annual fit-testing requirements related to NIOSH-approved tight-fitting powered air-purifying respirators (PAPRs) during the current pandemic. Things to note:
- This guidance is NOT referring to N95 Filtering Facepiece Respirators, such as N99, N100, R95, R99, R100, P95, P99, and P100. The current temporary enforcement guidance for these units still requires initial fit-testing, but annual testing may be suspended if supplies of respirators and fit-testing kits remain limited. Other conditions apply.
- The use of tight-fitting PAPRs as described in the guidance document, is only acceptable if using N95 type respirators is infeasible due to respirator and fit-testing supply shortages.
- An employer must be able to “show” the OSHA inspector the attempts they’ve made to purchase N95 type units and fit-testing kits, so efforts should be in writing. Employers should also be able to show they have someone knowledgeable of the OSHA requirements in order to make a decision to purchase a respiratory protection alternative.
- The guidance does not exempt medical evaluations.
- The guidance applies ONLY to personnel in high or very high exposure risk activities as they pertain to the Coronavirus.
- The guidance does NOT apply to PAPRs used by workers with low or medium exposure risk to the Coronavirus, units used by workers for protection against airborne hazards other than the Coronavirus or to loose-fitting PAPRs.
- If respirators are required, employers should consider accommodations for religious exercise for those employees who, for instance, have or cannot trim facial hair due to religious belief.
For more information on respirator usage during the current pandemic click on the links below:
- US. Department of Labor Confirms N95 Respirators Protect Against the Coronavirus
- Top OSHA and FDA Updates on Mask and Respirator
- COVID-19 and OSHA Guidance on N95 Respirator Mask
In September 2020, OSHA cited a dental practice for failing to provide medical evaluations and fit testing for employees required to wear N-95 respirators as protection against coronavirus. OSHA Respiratory Protection Standard
OSHA has provided a guidance document specific to COVID-19 and dentistry workers and employers. With this information in place, it is no doubt that OSHA expects adherence. Be sure to have a comprehensive Infectious Disease Preparedness Plan in place so you are ready if OSHA comes knocking!
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