As safety departments get squeezed for $, we are seeing a spike in a severe deficiency in a site’s respiratory protection training. I first got wind of this when a client I was scheduled to do some respiratory protection training for canceled the course. This is a client we provide other services for, so while I was on site recently, I asked him about the respirator training and how he got it done. His response was the same company that did the fit testing trained our people while they were being fit tested. Sound familiar? Is this how your employees get their annual training… during their fit-testing? What would you say if I told you that what is happening at the fit-testing is REQUIRED as part of the fit-testing procedure but in NO WAY replaces the actual ANNUAL respirator training…
emphasis by me, but this is from Appendix A to § 1910.134: Fit Testing Procedures (Mandatory)
Part I. OSHA-Accepted Fit Test Protocols
A. Fit Testing Procedures — General Requirements
The employer shall conduct fit testing using the following procedures. The requirements in this appendix apply to all OSHA-accepted fit test methods, both QLFT and QNFT.
1. The test subject shall be allowed to pick the most acceptable respirator from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user.
2. Prior to the selection process, the test subject shall be shown how to put on a respirator, how it should be positioned on the face, how to set strap tension and how to determine an acceptable fit. A mirror shall be available to assist the subject in evaluating the fit and positioning of the respirator. This instruction may not constitute the subject’s formal training on respirator use, because it is only a review.
So, as we can see, the fit testing protocols require the fit tester to demonstrate how to don and wear the respirator the employee will be fit-tested with. This is merely to ensure the fit test has some degree of quality control. Of course, if the training they attend is different than how they were shown during the fit-testing, that poses an entirely different set of concerns. So when trying to save $, counting the fit testing instruction as our annual training is NOT acceptable!