OSHA recently posted a Letter of Interpretation where they reference their Compliance Directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, and the standard’s preamble in establishing the medical evaluations for “voluntary use” of negative pressure (tight-fitting) respirators. This issue has been made clear in the CPL for years, but I thought I would share the LOI with everyone, as it is direct and to the point.
Bottom line… medical evaluations ARE REQUIRED for negative pressure (tight-fitting) respirators – they are NOT required when the respirator being used on a voluntary basis is a filtering facepiece respirator (or dust mask). Here is more from OSHA… (emphasis by me, and I have reformatted it)
SAFTENG Members should also see my 50+other respiratory protection articles where we cover this topic
Question 1: Does a respirator meeting OSHA’s definition of a filtering facepiece respirator (regardless of its elastomeric) need to be included in the medical evaluation of the respiratory program when used voluntarily?
Response: First, we would like to clarify that a filtering facepiece respirator (or dust mask) and an elastomeric respirator are both air-purifying respirators, but they are not equivalent respirators. OSHA defines 29 CFR 1910.134(b) a filtering facepiece respirator (dust mask) as a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium (as mentioned in your incoming letter) (see 63 Fed. Reg. 1152, 1183 (January 8, 1998)). On the other hand, the elastomeric respirator is a tight-fitting, air-purifying respirator with replaceable filters, cartridges, or canisters. The design of elastomeric respirators is such that the filtering medium is not the only fundamental part needed to make the facepiece functional. The elastomeric (e.g., rubber, silicone, neoprene, plastic) material allows the respirator to be cleaned, and reused. If equipped with the proper cartridges, elastomeric respirators can be used for many gases and vapors.
As OSHA explained in the respiratory protection compliance directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, the requirements for voluntary use of respirators can be divided into two (2) categories:
- requirements for filtering facepieces (i.e., dust masks) and
- for all other respirators, including elastomeric facepieces and powered air-purifying respirators.
If an employer ONLY allows voluntary use of filtering facepiece respirators after determining that such use will NOT itself create a hazard, the employer’s only further obligation under the Respiratory Protection standard is to provide a copy of Appendix D of the standard to each voluntary user of a filtering facepiece. See 29 CFR 1910.134(c)(2).
If employers allow the voluntary use of elastomeric facepiece and powered air-purifying respirators (again, after determining that such use will not itself create a hazard), the employer must implement the elements of a written respiratory protection program necessary to ensure that employees voluntarily using such respirators are medically fit to do so, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. See 29 CFR 1910.134(c)(2)(ii).
The preamble to the standard explains that medical evaluation is necessary even for voluntary use of negative pressure (tight-fitting) respirators because they impose a significant physiologic burden on the respirator user, and it is crucial to determine that the user can withstand that burden without suffering adverse health consequences (63 Fed. Reg. at 1190).