April 30, 2020

OSHA Issues Enforcement Guidance for Reuse of Decontaminated N95s

A temporary enforcement memorandum from federal OSHA outlines conditions under which employers may reuse N95 filtering facepiece respirators that have been decontaminated. The memo, dated April 24, states that reuse of respirators that have been decontaminated via three methods—vaporous hydrogen peroxide, ultraviolet germicidal irradiation, and moist heat—may be acceptable provided employers meet several requirements related to training workers and ensuring respirators maintain their fit and integrity.

NIOSH has identified vaporous hydrogen peroxide, ultraviolet germicidal irradiation, and moist heat as decontamination methods that may be effective on filtering facepiece respirators. The OSHA memo states that if these methods are not available, decontamination via microwave-generated steam or liquid hydrogen peroxide may also be acceptable.

Despite the method chosen, employers must be able to demonstrate its effectiveness, according to the memo. Employers must also make a good-faith effort to provide workers with the most appropriate respiratory protection; ensure that decontamination is accomplished according to CDC guidance; and ensure users perform a seal check each time they don a respirator. In addition, employers must train users to follow appropriate precautionary measures prior to using a decontaminated respirator and to understand that respirators with structural or functional defects should not be worn. Visual inspection of the respirators is also required.

OSHA will use “enforcement discretion” in cases where employers have used engineering and administrative controls to protect employees; have tried to obtain alternative appropriate respiratory protection; and have monitored their supply of filtering facepiece respirators and prioritized their use according to CDC guidance.

For complete guidance, view the memo on OSHA’s website.