Respiratory Protection Program Management & Fit-Testing Update

By: Rob Brauch, COHC, Contributor

photo courtesy AccuTec-HIS, Inc.

Let’s start with the obvious—the worldwide response against COVID-19 has impacted just about every facet of our daily lives. 

At first, there was conflicting information about how the disease was passed from person-to-person and what the death tally might become if the disease was left unchecked. Meanwhile, governments and the medical community were trying to find ways to better treat those affected and decrease mortality rates.

From the onset of COVID, the reassuring voice of the industrial hygiene community was there as a crucial resource of rational, science-based guidance, combined with known best practices for controlling the spread of biohazards and pathogens. As it became clear that the virus was spread primarily through the air, it was also recognized that there are proven ways to protect oneself by utilizing protective equipment already found in the workplace. 

PPE, such as tight-fitting respirators, became a major focus of attention. Frontline workers and first responders in healthcare and public services needed well-functioning PPE to mitigate exposure. Yet, the global market was being inundated with PPE of all types that were arguably shoddy at best (and outright counterfeit at worst), due to demand that far outstripped supply. 

The U.S. saw Emergency Use Authorizations from the FDA; Temporary Enforcement Guidance documents from DOL/OSHA; and many advisements from CDC and others in government and academia regarding things like use of non-NIOSH-approved respirators with lower protection ratings, possible decontamination and reuse of N95s, etc.  Suddenly, it all got very complicated.   

Proper Use of PPE

Availability and proper use of PPE for respiratory protection is essential for slowing the spread of the virus to workers. Methods for ensuring proper fit and function of respirators have been around for many years, but the massive increase in individuals wearing PPE sheds new light on how they get selected and fit-tested. Some healthcare facilities moved from qualitative fit-test methods to quantitative, due to concerns about loss of taste and smell from COVID infection and to increase the number of workers who could be fitted on any given day.  

The healthcare industry was exempted from part of OSHA’s Respiratory Protection Program requiring annual fit-testing, after the Wicker Amendment passed in 2005, although that was repealed not long after. During COVID, OSHA temporarily suspended the annual fit-test requirement on March 14, 2020. On the surface, this was done to cut down the number of individual N95s used up during testing (i.e., probe-inserted, not usable) or perhaps time taken to do qualitative fit-testing (OSHA’s 2019 RFT protocol using particle counting devices takes 2.5 minutes).

Effective June 21, 2021, OSHA issued a “COVID-19 Healthcare Emergency Temporary Standard,” with a “mini respiratory protection program” component (29 CFR 1910.504). Per OSHA: “It 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).”

The mini program does away with the Medical Evaluation, Fit Testing and Written Program requirements of 29 CFR 1910.134. 

While this ETS has good intentions for relaxing the burdens of a compliant RPP under 1910.134(c), it seems to reinforce the exclusion of the healthcare industry from proven best practice in RPP implementation. What that may mean for future outbreaks is something worth considering. 

The Best of Best Practices

Regulatory standards sometimes have differences that appear at odds with current best practice—but it seems, in this instance, to lead to a less demanding regulatory environment—no matter how well-intentioned.    

Today, we might say we are winning the battle against COVID-19 and its variants. With the U.S. closing in on herd immunity, it’s reasonable to step back and review what we learned and what has changed. But we should also consider whether these changes in regulatory environment could put healthcare workers at greater risk when the next pandemic occurs. 

It is this author’s view that applying best practice is superior to meeting minimal levels of compliance, regardless of the hazard, and should be considered especially in times of global crisis. 

[Rob Brauch, COHC, is President of AccuTec-IHS, Inc.]