For decades, businesses have used the TSI Porta-Count QNFT method to fit test tight-fitting respirators. Today, new variations of this NIOSH-approved method (e.g., Condensation Nuclei Counter(CNC) are faster, and we have seen many organizations adopt these new methods. However, changing our Fit-Testing method may require an MOC.
I say “may” as not all PSM processes may have a Respiratory Protection (RP) program, and the same facility may not have an Emergency Response Team (ERT). But, if the operators are wearing RP for line breaks, entry into PRCSs, sampling, etc., then the RP will undoubtedly be a PSM-safe work practice, and any changes to this program must be managed via the MOC. The same would apply if the facility has its own ERT who wear RP.
And yes, I know that 19101.119(f) does not explicitly mention 1910.134 as one of the Safe Work Practices covered by the PSM standard, but I practice actual Process Safety and not OSHA Compliance. There is little doubt in any safety professional’s mind of the critical nature of fit-testing within a respiratory protection program. It may be one of the more crucial aspects of the entire program. Changing the type AND/OR method of fit-testing can impact the safety and health of the workers – can it not? Thus, when we truly look at this change in the QNFT method, we realize we can use the MOC tool to manage this change.