OSHA’S NEW TEMPORARY ENFORCEMENT GUIDANCE

Here’s another in our continuing series of “Coronavirus Basics” articles, in which we’re trying to offer helpful information to folks trying to figure a whole bunch of stuff having to do with working during the coronavirus pandemic.

In this one, we want to give you a quick FYI that OSHA recently released a new Temporary Enforcement Guidance – Healthcare Respiratory Protection Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak.

It’s not too long, so do yourself a favor and click the link above and get the straight information directly from OSHA.

OK, are you done reading the full thing? Here’s a quick summary of what caught our attention, below.

Temporary: It’s temporary, put in place because of the coronavirus pandemic.

29 CFR § 1910.134: It has to do with enforcement of 1910.134, the Respiratory Protection standard, during this pandemic, and in particular, due to the shortage of N95 filtering respirators.

Annual Fit Testing: In particular, it’s about the annual fit testing requirement.

Health Care Providers: This doesn’t apply to everyone–its for health care providers and the health care industry.

Effective March 14, 2020 until “further notice”: ’nuff said.

OSHA’s Discretion on enforcement of the fit-testing requirement: As the document says, “OSHA field offices shall exercise enforcement discretion concerning the annual fit testing requirement, 29 CFR § 1910.134(f)(2).” But, you’ve got to meet these requirements to get this discretion on enforcement:

• Make a good-faith effort to comply with 29 CFR § 1910.134;
• Use only NIOSH-certified respirators;
• Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use, as discussed above;
• Perform initial fit tests for each HCP with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19 (initial fit testing is essential to determine if the respirator properly fits the worker and is capable of providing the expected level of protection);
• Inform workers that the employer is temporarily suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators for use in situations where they are required to be worn;
• Explain to workers the importance of performing a user seal check (i.e., a fit check) at each donning to make sure they are getting an adequate seal from their respirator, in accordance with the procedures outlined in 29 CFR § 1910.134, Appendix B-1, User Seal Check Procedures. See also, OSHA tutorial videos (English, Spanish).
• Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or obvious changes in body weight) and explain to workers that, if their face shape has changed since their last fit test, they may no longer be getting a good facial seal with the respirator and, thus, are not being adequately protected; and,
• Remind workers that they should inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.

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