Common respirator questions and violations

Date Posted: 10/12/2020
Respiratory Protection

When employees must wear respirators, they must undergo a medical evaluation to ensure that they can safely use a respirator. Generally, the employer identifies a health care professional to use the questionnaire from the OSHA regulation, or to conduct an exam that obtains the same information.

Medical evaluations do not need to be repeated annually, unless a healthcare provider prescribes annual tests to ensure the employee can continue to safely wear a respirator. The regulation at 1910.134 notes that additional medical evaluations are necessary if:

  • Employees report medical signs or symptoms related to their ability to use a respirator;
  • The physician (or a supervisor) reports that the employee should be reevaluated;
  • Information or observations during fit testing indicates a need for reevaluation; or
  • A change in workplace conditions (e.g., physical work effort, protective clothing, temperature) may increase the physiological burden placed on an employee.

After the medical evaluation, the worker must be fit tested with the same make, model, style, and size of respirator that will be used. The fit test must be repeated annually because changes such as gaining or losing weight can affect how a respirator fits. In addition, fit testing is required if a different respirator is used.

Training and maintenance

Employees using respirators must be trained, and the training must recur annually. Changes in the workplace or the type of respirator may require additional training. Also, training must be delivered if any other situation arises in which retraining appears necessary, such as when the employee’s knowledge or understanding seems to be lacking.

Among other topics, training must cover cleaning and disinfecting procedures. OSHA frequently issues citations for failing to maintain respirators in a sanitary condition. Each employee’s respirator must be cleaned “as often as necessary” but if a respirator is shared among workers, it must be cleaned and disinfected after each use.

Using dust masks

If employers require dust masks or N95s (called “filtering facepiece respirators”), the respiratory protection standard applies, including medical evaluations. However, if employees voluntarily use these devices, the employer must simply determine that such use will not create a hazard and provide the information from 1910.134 Appendix D.

Cloth face coverings or surgical masks are not “respirators” and do not trigger these provisions, even if wearing them is mandatory. However, some employees might voluntarily wear dust masks or N95s instead, in which case the employer must verify that wearing the device will not create a hazard and provide a copy of Appendix D. Employers should ask workers desiring to wear dust masks or N95s to report that use so the company can meet those obligations.

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How Safety Management Suite Can Help

If you have employees required to use respirators, you need a written respiratory protection program. Numerous other regulations also require written plans. Creating and updating these programs is easy using the Plans and Policies tool in the J. J. Keller® SAFETY MANAGEMENT SUITE. The tool gives you the framework you need, covering all required elements from the applicable regulations, allowing you to enter you information and save the plan.

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