On August 4, 2004, the U.S. Occupational Safety and Health Administration (OSHA) issued a final rule approving a new alternative protocol for quantitative fit testing of respirators. 69 FR 46986. Under OSHA’s existing Respiratory Protection Standard (29 C.F.R. § 1910.134), if an employer requires an employee to wear a respirator with a tight-fitting facepiece, the employer must test the respirator to ensure that it properly fits the employee’s face. The final rule adds a new controlled negative pressure (CNP) fit testing protocol, called CNP REDON, to Appendix A of the Respiratory Protection Standard as an additional OSHA-approved method for conducting the mandatory respirator fit testing. Employers may use the new CNP REDON protocol or any of the previously approved fit testing methods, including a previously approved CNP protocol, a generated-aerosol protocol and an ambient-aerosol condensation nuclei counter protocol.
CNP methods use an instrument to measure air leakage in the facepiece of a respirator to evaluate its fit. The CNP fit testing protocol previously approved by OSHA requires eight test exercises including one redonning of the respirator. In contrast, the new alternative CNP REDON protocol requires three different test exercises followed by two redonnings of the respirator. The new CNP protocol uses the same leakage testing instrument as the previously approved CNP method.
The procedures for administering the new CNP REDON protocol and for measuring respirator leakage during each test are:
- Facing forward – In a normal standing position, facing forward and without talking, the employee breathes normally for 30 seconds and then holds his or her breath for 10 seconds for test measurement.
- Bending over – The employee bends forward at the waist for 30 seconds and then, while facing parallel to the floor, holds his or her breath for 10 seconds for test measurement.
- Head shaking – The employee shakes his or her head back and forth vigorously several times while shouting for approximately three seconds and then, while facing forward, must hold his or her breath for 10 seconds for test measurement.
- Two redonnings – The employee removes the respirator, loosens all facepiece straps, redons the respirator mask and then, while facing forward, holds his or her breath for 10 seconds for test measurement. This redonning procedure is repeated a second time.
OSHA, pursuant to the Respiratory Protection Standard, conducted notice-and-comment rulemaking on the CNP REDON protocol after two peer-reviewed articles from industrial hygiene journals described the accuracy and reliability of the proposed alternative protocol were submitted to OSHA. OSHA found that the CNP REDON is an effective and reliable method for identifying respirators that do not fit properly. Because the CNP REDON will be an alternative to previously approved fit testing methods, OSHA determined that the final rule would not increase an employer’s compliance burden.
The final rule becomes effective on September 3, 2004. It affects employers in general industry, construction and shipyard employment. The complete final rule is available by clicking here.