In an enforcement memorandum dated March 14, 2020, the Occupational Safety and Health Administration (OSHA) provided temporary enforcement guidance for its compliance officers.
Due to supply shortages of N95 filtering facepiece respirators for healthcare workers, OSHA amended the enforcement of its respiratory protection standard for healthcare workers providing direct care of patients with known or suspected COVID-19.
Instead of exclusively providing N95 filtering facepieces, healthcare employers may provide:
- Respirators with equal or higher protection, such as N99 or N100 filtering facepieces
- Reusable elastomeric respirators with appropriate filters or cartridges
- Powered air purifying respirators (PAPR)
Another recommendation is for employers to change from a destructive fit testing method (quantitative) to a non-destructive method (qualitative) so that the mask can be reused.
OSHA is directing its field offices to use enforcement discretion regarding the annual fit testing requirement if employers:
- Make a good faith effort to comply with the respiratory protection standard;
- Use only NIOSH-certified respirators;
- Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use;
- Perform initial fit tests for each worker with the same model, style, and size respirator the worker will be required to wear;
- Inform workers that the employer is suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators;
- Explain to workers the importance of performing a user seal check at each donning to make sure they get an adequate seal;
- Conduct a fit test if they observe visual changes in the employee’s condition that could affect respirator fit and explain to workers that if their face shape has changed since the last fit test, they may no longer be getting a good seal; and
- Remind workers that they should inform their supervisor or respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.
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