Bear with me on this, as I know this is getting deeper than most think about Respiratory Protection. But the vast majority of the people I train and fit test are personnel who enter/work in IDLH environments, so I get very picky about my RP practices.
OSHA’s long-standing Fit Test Procedures in Mandatory Appendix A state:
13. The fit test shall be performed while the test subject is wearing any applicable safety equipment that may be worn during actual respirator use which could interfere with respirator fit.
The question is, what would you consider…
“applicable safety equipment that may be worn during actual respirator use which could interfere with respirator fit.”
I have to admit that in all my years, I never considered the hard hat as a piece of PPE that could affect the fit of a respirator; therefore, I never did FTs with a hard hat on the individual, even though 100% of those workers will be wearing a hard-hat/safety helmet while donning the RP.
But recently I did some Fit Testing for a client, and their OSH Nurse required the FT be done with a hard hat. When I began researching this topic, AI did say… “Hard hat suspensions or straps can push against the harness of a respirator, shifting it out of position.” This got me thinking about my old days when wearing the PRCS Rescue Helmets and how those were very different from hard hat suspensions and, in fact, possibly could impact the RP straps.
We had a grerat discussion in this group earlier this year about workers wearing their Chem Suit Hoods UNDER the RP straps and I tried to make it clear that if that is their PPE donning procedures then the FIT TEST would have to be done with those Chem Suits hoods (all brands, models and sizes) to ensure a good fit of the RP; which is WHY we should NEVER put the RP over a hooded suit! But what about hearing protection, or a faceshield worn over a 1/2 face APR? Welding helmets?
What say you?
Do you require workers to wear other PPE during their Fit Testing?
What if the business revised a Certified PPE Hazard Assessment and began requiring some type of additional PPE that “could” impact the fit of a respirator? Do we do an MOC and re-test all impacted users with the new PPE requirements?
What about the change from the old hard hats to the new safety helmets? Did we retest all the personnel when they got their new safety helmets?