By: Dave Risi, CIH, CSP, Contributor
Respirators are the last line of defense between workers and harmful air contaminants, irritants and other workplace respiratory hazards. Yet, simply wearing a respirator isn’t enough. If respirators don’t fit properly, they provide little or no protection for workers. That’s why regulations like OSHA’s Respiratory Protection Standard require employers to perform and document respirator fit tests (RFTs) for every worker who wears a respirator—and for every respirator type they may use in their workplace—to make sure workers are protected to the highest possible degree.
The challenge is that OSHA’s RFT regulations are complex, and the lack of awareness (and understanding of its requirements) among employers is why testing is done incorrectly or not completed at all. At the same time, respiratory hazards are unique to every workplace. Depending on the work activities performed; the respiratory hazards that workers are exposed to; the types of respirators in use; and the respiratory protection requirements that apply at each work site, EHS professionals may need to perform multiple tests on individual workers to ensure compliance. Simply stated, workers must be tested on each and every respirator type and brand they wear in the workplace.
The following is a breakdown of OSHA’s RFT requirements and information about the tools available to help ensure tests are accurate, consistent, on-time and in compliance.
Fit Test Protocols
Appendix A of OSHA’s Respiratory Protection Standard contains the agency’s approved fit test protocols, which are the testing methods and evaluation criteria employers are permitted to use when performing fit tests. There are a variety of approved protocols, and they represent some of the more technical aspects of the Respiratory Protection Standard. Generally speaking, the RFT protocols you select will be determined by the type of respirators used in your workplace, and the test reagents/substances and testing equipment appropriate to those types of respirators.
The various RFT protocols can be broken down into two methods: quantitative fit testing and qualitative fit testing.
Qualitative fit testing is a non-numeric pass/fail test that uses the wearer’s response to a substance to determine respirator fit. In qualitative fit testing, after performing user seal checks, the respirator wearer stands in an enclosure or wears a hood, and a test agent is introduced for them to detect. These test agents include:
- Isoamyl acetate (banana oil)
- Irritant smoke
If the individual can detect the test agent, this indicates that the agent leaked into the facepiece and the respirator has failed the test, because a good seal has not been achieved. Also, if the employee cannot successfully complete the qualitative test with a particular respirator, the employee must then be tested with another make, size or model of respirator—until they find one that passes the fit test.
For quantitative testing, a machine or computer is used to measure leakage into the facepiece. During this test, a probe is attached to the facepiece and connected to the machine by a hose. The OSHA-acceptable quantitative tests are:
- Generated aerosol
- Ambient aerosol condensation nuclei counter (CNC)
- Controlled negative pressure (CNP)
- Controlled negative pressure (CNP) (REDON)
- Modified ambient aerosol condensation nuclei counter for full- and half-facepiece elastomeric respirators
- Modified ambient aerosol CNC for filtering facepiece respirators
OSHA approved the last two testing protocols in 2019, which are variations of the original ambient aerosol CNC protocol but have fewer test exercises, shorter exercise duration and a more streamlined testing sequence.
It’s important that RFTs aren’t confused with user seal checks. This quick test verifies the respirator has been properly positioned on the user’s face and should be performed each time the user puts it on. Ensuring a proper seal also improves the likelihood of passing the RFT, therefore saving time. Instructions for completing the user seal check can be found in the respirator manufacturer instructions.
OSHA gives employers quite a bit of flexibility when it comes to choosing the RFT protocol that’s right for them. In general, qualitative protocols are only used to fit test either powered air-purifying respirators (PAPRs), self-contained breathing apparatuses (SCBAs) or negative pressure air-purifying respirators (APRs) that must achieve a fit factor of 100 or less. Quantitative protocols are used in all situations where a negative pressure respirator is intended to protect workers from contaminant concentrations greater than 10 times the permissible exposure limit (PEL). When quantitative testing protocols are used to fit negative pressure respirators, a minimum fit factor of 100 is achieved for tight-fitting half facepieces and 500 for full facepieces.
One advantage of quantitative testing is that it doesn’t rely on the wearer’s response to a substance to determine whether the respirator fits and a good seal has been achieved. The NIOSH Guide to Industrial Respiratory Protection recommends quantitative testing be implemented when facepiece leakage must be minimized for work in highly toxic atmospheres or those immediately dangerous to life or health. Such tests, though, require more expensive equipment and more training for test administrators compared to qualitative tests.
Regardless of what protocol you use, all RFTs must be conducted with the same make, model, style and size that the employee will be expected to use at the worksite. Also, following the initial RFT, subsequent fit tests must be performed at least annually and whenever an employee switches to a different type of tight-fitting facepiece respirator or their facial structure changes enough to potentially affect the seal of the respirator. Examples of this are significant weight gain/loss and facial scaring.
Scheduling & Recordkeeping
One of the most difficult parts of compliance with OSHA RFT requirements is scheduling and sufficiently documenting results for all tests performed on all employees who require them, for every covered respirator type used in your workplace. Sounds like a big task, right? The more employees that require the use of respirators—especially temporary workers who are enter and leave the workplace on a frequent basis—the greater this challenge becomes.
OSHA requires employers establish a record of the qualitative and quantitative fit tests administered that includes:
- Name or identification of the employee tested
- Type of fit test performed
- Specific make, model, style and size of respirator tested
- Date of test
- Test results (pass/fail results for qualitative tests, or fit factor and strip chart recording or other recording of the results for quantitative tests)
While OSHA only requires these records be retained until the next test is administered, it is good practice to have some form of long-term record storage for tests performed. This could prove to be beneficial should there be any future litigations.
How Technology Can Help
Employers should consider implementing an all-in-one industrial hygiene software solution that standardizes the scheduling, documentation and follow-up for all RFT protocols and activities. This is particularly true for employers who need to manage RFT compliance across multiple locations or for large numbers of employees who use respirators in the workplace. If you can quickly and easily determine which employees use which types of respirators; what fit testing protocols are required for those respirator types; when tests must be performed; and then quickly document results, you’ll be well on your way to ensuring compliance with OSHA RFT requirements.
Today’s IH software solutions are especially beneficial at easing the complexities and time needed for RFTs. Normally, RFT protocols can take as much as 7-8 minutes per worker, and documenting test results using paper forms takes an additional 3-5 minutes. However, software solutions like VelocityEHS greatly improve fit test efficiency by allowing users to quickly select from OSHA-approved protocols and document results using pre-built data collection forms, reducing total test times to just 2.5 minutes when using the modified CNC protocols.
Failure to provide necessary respiratory protection is one of the most common workplace safety violations, often resulting in significant noncompliance fines and devastating effects on employee health. The more familiar you are with RFT requirements—and with the right tools in place—the easier it is to implement an efficient and effective respiratory protection program that keeps your workers safe and your organization compliant.
Dave Risi, CIH, CSP is a Principal Solutions Strategist, Industrial Hygiene, at VelocityEHS, the global leader in cloud environment, health, safety (EHS) and sustainability software. To learn more about how software can help you build a world-class IH program, visit www.EHS.com.