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US | COVID-19 | OSHA Issues Three Enforcement Guidance Memos on the Use of Respirators
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Original Guidance Memo
OSHA’s original memo, issued on March 14, 2020, directed OSHA field offices to use enforcement discretion regarding the annual fit testing requirements as long as employers took a certain set of prescribed steps including:- Making a good-faith effort to comply with the respiratory protection standard
- Using only NIOSH-certified respirators, and
- Implementing CDC and OSHA strategies for optimizing supply of N95 filtering facepiece respirators (FFR) and prioritizing their use.
Updated Enforcement Guidance
The first memo published this week on April 3, 2020, titled “Enforcement Guidance for Respiratory Protection and the N95 Shortage Due to the Coronavirus Disease 2019 (COVID-19) Pandemic,” addressed additional concerns not dealt with in the March 14 memo. In this memo, OSHA stated that it is permitting, in limited situations, the extended use and reuse of NIOSH-approved N05 FFR and N95 FFRs with expired shelf life as long as there are no alternative respirators available and employers take certain steps detailed in the memo. The memo provides examples of situations in which N95s cannot be reused such as when its functional integrity and filter material are physically damaged, soiled, or contaminated. The memo also provides direct guidance on when healthcare professionals (HCPs) cannot use expired N95s such as when they perform surgical procedures on patients infected with, or potentially infected with, COVID-19 or when they perform or are present for procedures expected to generate aerosols. OSHA then updated this memo on April 8 to address concerns regarding a shortage of fit-testing kits and test solutions. OSHA pointed out that most respirator manufacturers produce multiple models that use the same basic head form for size/fit and may have a list of their respirators with equivalent fit. As a result, if a user’s respirator model is out of stock, according to OSHA, employers should consult the manufacturer to see if it recommends a different model. OSHA issued another memo on April 3, 2020 titled “Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries or Jurisdictions During the Coronavirus Disease 2019 (COVID-19) Pandemic.” In this memo, OSHA announced that it was permitting the use of non-NIOSH approved FFRs and air-purifying elastomeric respirators that are either:- Certified under certain standards of other countries; or
- Previously certified under the standards of other countries, but beyond their manufacturer’s recommended shelf life only if equipment certified under standards of other countries is not available.
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