OSHA has issued a Notice of Proposed Rulemaking to add two (2) quantitative fit-testing protocols to the agency’s Respiratory Protection Standard. The protocols would apply to employers in the general, shipyard and construction industries. This proposed rulemaking would allow employers greater flexibility in choosing fit-testing methods for employees. The proposed rule would NOT require an employer to update or replace current fit-testing methods, as long as the fit-testing method(s) currently in use meet existing standards. The proposal also would not impose additional costs on any private- or public-sector entity.
Appendix A of the standard contains mandatory respirator fit-testing methods that employers must use to ensure their employees’ respirators fit properly and protect the wearer. The standard also allows individuals to submit new fit-test protocols for OSHA approval. TSI Incorporated submitted an application for new protocols for full-facepiece and half-mask elastomeric respirators, and filtering facepiece respirators.
The existing standard contains mandatory testing methods to ensure that employees’ respirators fit properly and are protective. The standard also states that additional fit-test protocols may be submitted for OSHA approval. TSI Incorporated submitted an application for new protocols for full-facepiece and half-mask elastomeric respirators, and filtering facepiece respirators. The proposed protocols are variations of the existing OSHA-accepted PortaCount® protocol, but differ from it by the exercise sets, exercise duration, and sampling sequence.
Both proposed protocols are variations of the existing OSHA-accepted PortaCount® protocol, but differ from it by the exercise sets, exercise duration, and sampling sequence. If approved, the modified PortaCount® protocols would be alternatives to the existing quantitative fit-testing protocols already listed in an appendix of the Respiratory Protection Standard. In addition, OSHA is proposing to amend an appendix to clarify that PortaCount® fit test devices equipped with the N95-Companion™ Technology are covered by the approved PortaCount® protocols.
All three of TSI’s modified PortaCount® protocols use the same fit-testing requirements and instrumentation specified for the standard PortaCount® protocol in paragraphs (a) and (b) of Part I.C.3 of appendix A of the Respiratory Protection Standard, except that they differ from the standard PortaCount® protocol by the exercise sets, exercise duration, and sampling sequence. The major difference between the proposed Fast-Full and Fast-Half methods and the standard
PortaCount® protocol is they include only 3 of the 7 current test exercises (i.e., bending, head side-to-side, and head up-and-down) plus a new exercise (i.e., jogging-in-place), and reduce each exercise duration, thereby reducing the total test duration from 7.2 minutes to 2.5 minutes. The peer-reviewed articles describe studies comparing the fit factors for the new modified PortaCount® protocols to a reference method based on the American National Standards Institute (ANSI/AIHA) Z88.10-2010 Annex A2 “Criteria for Evaluating New Fit Test Methods” approach. This approach requires the performance evaluation study administer sequential paired tests using the proposed fit-test method and reference method during the same respirator donning.
The agency invites the public to comment on the accuracy and reliability of the proposed protocols, their effectiveness in detecting respirator leakage, and their usefulness in selecting respirators that will protect employees from airborne contaminants in the workplace. More specific issues for public comment are listed in the Federal Register notice.
Individuals may submit comments electronically at www.regulations.gov, the Federal e-Rulemaking Portal. Comments may also be submitted by mail or facsimile; see the Federal Register notice for details. The deadline for submitting comments is Dec. 6, 2016.