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OSHA has released an Enforcement Memorandum that provides temporary guidelines for enforcement of respirator fit testing due to the supply shortage of N95 respirators and limitations on the availability of employees, consultants and contractors who normally provide training and fit testing.
Inspectors now have enforcement discretion, such as not citing the business, for employers who have made a good faith effort to comply by completing the following:
- Use only NIOSH-certified respirators
- Inform workers that annual fit testing is temporarily suspended due to shortage or service disruption
- Explain to workers the importance of performing a user seal check each time the respirator is put on
- Remind workers that they should inform their supervisor if the integrity and/or fit of the respirator is compromised
- Communicate a target date of when the annual fit test will be rescheduled based on estimates of when respirators will become more readily available in supply chains, shelter orders are loosened and/or third-party services resume.
It is important to note that the following still require a fit test regardless of the above:
- Initial fit tests for new employees with the same model, style and size respirator that the worker will be required to wear.
- Follow-up fit test if visual changes are observed in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, etc.).
Facilities are being encouraged to provide alternative respirators to employees using N95 masks to conserve inventory for health care workers.
If you have any unused N95 respirators that you would like to donate, contact your local public health agency.
For more information or to enroll in free coronavirus prevention training, email [email protected]. For more information, call GMG EnviroSafe at (800) 619-9733.