OSHA to Use Discretion When Enforcing Fit-Testing Requirements for PAPRs in Healthcare

A new OSHA enforcement memo directs agency compliance safety and health officers (CSHOs) to use discretion when enforcing OSHA’s fit-testing requirements for NIOSH-approved, tight-fitting, powered air-purifying respirators, or PAPRs, used for protection against SARS-CoV-2. The directive applies to PAPRs worn by healthcare personnel or other workers with high risk of exposure to the virus, and only when fit-testing is infeasible due to shortages of respirators and fit-testing supplies.

The directive takes immediate effect and is intended to apply for the duration of the public health crisis brought about by the COVID-19 pandemic.

OSHA clarified that the directive does not apply to PAPRs that are not NIOSH approved or to PAPRs used by workers with low or medium exposure to the virus. Also not covered are PAPRs used for protection against other airborne hazards, as well as loose-fitting, hooded PAPRs that do not require fit testing.

Global shortages of N95 filtering facepiece respirators have led organizations to employ decontamination and reuse of FFRs even though they are intended to be single-use items. Tight-fitting PAPRs, in contrast, are designed to be cleaned and reused. Increased use of PAPRs could help reduce demand for FFRs.

The discretion granted by the OSHA directive will be applied on a case-by-case basis. When considering issuing citations under the agency’s Respiratory Protection Standard requirements for fit-testing, CSHOs will consider whether the employer has provided workers with NIOSH-approved tight-fitting PAPRs with a high-efficiency particular cartridge or filter; made good-faith efforts to obtain fit-testing supplies; implemented controls that reduce the need for respiratory protection; and maintained a fully compliant respiratory protection program.

Updates regarding this directive will be posted to OSHA’s COVID-19 webpage.