This post was sponsored by AccuTec-IHS.

Emergency use authorizations. Temporary enforcement guidance. Experimental methods for decontaminating “disposable” N95s. All types of respirators with different form factors and filtering media not typically found in North America flooding the market. Shiploads of counterfeit “N95s” confiscated on arrival at our shores, and far worse—like the ones not detected and subsequently used by people who incorrectly believed they were approved PPE.

These were times like none had seen before, much less anticipated. Everyone was scrambling to get much-needed PPE into the hands and onto the faces of first responders and others on the frontlines fighting to save lives during the peak of the SARS-CoV-2 outbreak.

Despite the chaos, the response by EHS professionals—especially AIHA members—was swift, strong, and sure. Applying cumulative centuries of knowledge and experience, CIHs were and continue to be a constant source of technical guidance and assurance to those in need.

Without any doubt, everyone now knows that the availability and proper use of PPE for respiratory protection is essential for slowing the spread of the virus to workers. And while proven methods for ensuring the proper fit and function of respirators have been around for decades, the huge increase in the number of persons wearing PPE cast new light on how they are selected and fit tested. Many moved from qualitative to quantitative fit-test methods due to diminished sensory response from COVID-19 infection and other concerns.

In 2005, the Wicker amendment to the federal spending bill barred the use of federal funds to enforce annual fit testing in the healthcare industry. The amendment was repealed a couple years later, but in March 2020 OSHA “temporarily” suspended the annual fit-test requirement, ostensibly to reduce the number of N95s rendered unusable by quantitative fit testing (a result of inserting the probe) and to allow time for initial fit testing of new wearers.

Effective June 21, 2021, OSHA’s COVID-19 emergency temporary standard (ETS) for the healthcare industry (29 CFR 1910.504) introduced the concept of a “mini respiratory protection program.” According to OSHA (PDF), this program

applies only to specific circumstances specified under the ETS, generally when workers are not exposed to suspected or confirmed sources of COVID-19 but where respirator use could offer enhanced worker protection. The mini respiratory protection program does not replace or substitute for OSHA’s normal Respiratory Protection standard (29 CFR 1910.134).

This mini program does away with the medical evaluation, fit testing, and written program requirements of 29 CFR 1910.134.

While OSHA’s relief of some of the burdens of a fully compliant respiratory protection program under 1910.134(c) appears well intentioned, the ETS also seems to reinforce the exclusion of the healthcare industry from proven best practices in RPP implementation. Ironically, this exclusion could affect the workers most likely to be at risk in future outbreaks.

Regulatory and technical standards often have disparities when compared to current best practices, but these are usually unintentional. In this instance, healthcare workers could be at greater risk from an intentionally less stringent overall regulatory environment.

Further, it’s my opinion that filling the gap between regulatory compliance and best practice is often the difference between a mediocre work environment and an outstanding one. The highest-performing organizations illustrate their use of best practices in their quest to attract and retain the best and brightest talent by supporting a healthy, safe, and productive environment for all.

Read more about qualitative fit testing on the AccuTec-IHS website.