OSHA Compliance

Proposed Removal of Medical Evaluations for FFRs and Loose-Fitting PAPRs

OSHA advanced a deregulatory proposal to amend 29 CFR 1910.134 that would alter pre-use medical clearance protocols. The amendment would REMOVE the requirement for mandatory medical evaluations for employees using filtering facepiece respirators (FFRs, such as N95s) and loose-fitting PAPRs. The agency cited substantial administrative costs to employers and noted that physicians rarely disqualify workers […]

NIOSH Advancing Final Rules for Combination Unit Respirators and PAPR100s

According to the federal regulatory agenda, the Department of Health and Human Services (HHS) and NIOSH are finalizing major updates to respirator certification standards under 42 CFR Part 84. Targeted for a final rule in November 2026, NIOSH is establishing a new approval class for CURs. These advanced hybrid devices integrate an open-circuit Self-Contained Breathing

What is the margin of error in the computed respirator change-out schedules?

There is no single, universal “margin of error” for computed respirator cartridge change-out schedules. Because software calculators—such as NIOSH’s MultiVapor™ or manufacturer-specific tools like 3M™ Select and Service Life—rely on predictive mathematical models (most commonly Gerry Wood’s adsorption model), their accuracy depends entirely on how closely the inputted parameters match real-world workplace conditions. In controlled

What is the minimum pressure for a sensitivity “bubble test” (Piping Leak Test)?

For a formal liquid bubble leak test using a detector like Swagelok Snoop, the industry-standard minimum pressure governed by ASME Section V, Article 10 and ASME B31.3 is 15 psig or 25% of the system design pressure, whichever is less. While SNOOP itself will bubble at virtually any positive pressure where gas escapes, engineering codes

Do you consider “Fit Testing” records to be “medical records” and off-limits to a 2nd/3rd-party auditor?

In the past 12-months I have been told by three (3) organizations that I can not audit the fit testing records because they are “personal medical records”. After some time, I finally convinced their legal team that fit tests are not medical records, and I was then allowed to audit the records. And of course,

Medical Evals for Respiratory Protection (RP) standard do NOT qualify as the HAZWOPER Medical Surveillance

The Respiratory Protection (RP) standard medical questionnaire for 1910.134 will NOT satisfy the HAZWOPER medical surveillance requirement. The intent and requirements for medical surveillance under HAZWOPER are very different from those required by the Respiratory Protection standard. The intent of the HAZWOPER medical surveillance requirements are two-fold:

Fireproofing piping supports

Fireproofing piping supports — specifically the application of Passive Fire Protection (PFP)— is a critical mitigation strategy designed to prevent the structural collapse of pipe racks during a flammable liquid fire. In most state fire codes and the IFC, flammable liquid piping supports inside a secondary containment are REQUIRED to be protected from the effects

Does federal OSHA require a “swing gate” at a vertical point of ladder access at the edge of a walking/working surface?

The simple answer is yes. Federal OSHA requires either a self-closing swing gate or an offset barrier at the point of access where a fixed ladder meets the unprotected edge of a walking-working surface. While the regulatory text in Subpart D sometimes causes confusion by referring to these access points as “holes,” OSHA consistently enforces

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