Fit testing N95 Disposable Respirators

Our office has received numerous calls from healthcare facilities including dental offices and other employers, requesting fit testing of disposable N95 respirators in light of the COVID pandemic.  We have instructed the callers that according to Cal/OSHA 8CCR5144, that if respirator use is required, the employer must:

• Have a written respiratory protection program;
• Ensure that the individuals who are required to wear the respirator are medically evaluated for the use of a respirator;
• Provide employee training; and,
• Provide fit testing, which needs to occur annually.

This seems to come as a surprise to the callers, particularly the need for medical evaluation. All of the above points are required.

A March 14, 2020 memorandum from Federal OSHA regarding temporary enforcement guidance states that “for filtering facepiece respirators [another name for disposable N95], qualitative and quantitative fit-testing methods are effective at determining whether the respirator fits properly.” An April 8, 2020 memorandum extended the guidance regarding the use of filtering facepiece respirators and the need for fit testing to all industries.  The latest OSHA memo makes the point that most respirator manufacturers produce multiple models that use the same head form for size/fit.  This is particularly important given the demand and limited supply of disposable respirators.

Regarding fit testing for filtering facepiece respirators, qualitative fit testing is most common.  This requires the use of a substance that has an odor which is released in air to determine if the user can detect the substance’s presence while wearing the N95.  If the substance is not detected, fit of the respirator is considered acceptable.

Whenever we do fit testing, we also perform a seal check. This is a test to verify that the respirator is properly worn and is stable on the face.  The process will not be described in this article, but as part of our training, we ensure the user understands this test should be performed each time a respirator is worn.

If respirator use is not required (voluntary use) fit testing is not required. It is however strongly recommended that instruction on the proper use of the respirator is provided to the user as well as how to perform a seal check. The Cal/OSHA regulation states that an employer is to provide the employee with the information in Appendix D of the regulation, even for the use of a respirator when it is not required.

The Cal/OSHA regulation states that a respirator “may place a physiological burden on the employee that varies with the type of respirator worn” and therefore a medical evaluation is required, which is to be performed by a physician or other licensed health care professional.  This medical evaluation is based on completion of a questionnaire which can be found in Appendix C to the regulation.

We understand that some employers simply want a fit test and to move on.  We want to assist these employers and employees, but doing so in compliance with Cal/OSHA requirements.  Let us know if you have any further questions regarding N95 respirators and the fit testing process.