OSHA has a Respiratory Protection Standard that deals with respirators just as it has a Bloodborne Pathogens Standard that deals with exposure to blood and certain other body fluids. The N95 is the basic workhorse for healthcare applications for airborne biological pathogens. N95s differ from surgical masks because they are designed to seal tightly against the user’s face. The Respiratory Protection Standard requires the following whenever the employer requires employees to wear N95s in the workplace:
- Written Respiratory Protection Program (RPP)
- Qualified Administrator
- Medical Clearance for employees to wear an N95
- Annual Fit Testing
- Annual Training
This article provides a roadmap on how to meet each of these five requirements in your workplace.
What is a Filtering Facepiece Particulate Respirator?
An N95 is an example of a filtering facepiece particulate respirator. National Institute for Occupational Safety and Health (NIOSH) approved filtering facepiece respirators include three different filter efficiencies and three different levels of oil resistance.
- The three levels of filter efficiency include:
- 95%
- 99%
- 99.97%
- The three levels of oil resistance include:
- N for non-oil resistant
- R for oil resistant
- P for oilproof
An N95 is a filtering facepiece particulate respirator that is 95% effective and is not oil resistant. Another variation is known as a Surgical N95, which not only provides respiratory protection but also acts as a barrier against large droplets of blood and other body fluids. It is important to note that the N95 is specifically designed to protect against particulates and does not offer protection from vapors such as formaldehyde. For guidance on selecting the appropriate respirator for vapor protection, refer to the Small Entity Compliance Guide.
There are numerous other types of respirators that deliver different levels and types of protection. However, these alternatives tend to be more expensive and typically require more comprehensive training and fit testing. For instance, the California Aerosol Transmissible Diseases Standard mandates the use of Powered Air Purifying Respirators (PAPRs), or respirators with equivalent or greater protection, when performing high-hazard aerosol-generating procedures on patients who are known or suspected to have aerosol transmissible diseases.
How can you comply with each of OSHA’s five requirements?
Complying with OSHA’s five requirements for respiratory protection can be straightforward with the right resources and understanding.
Written Respiratory Protection Program (RPP)
To begin, every organization must develop a written Respiratory Protection Program (RPP). OSHA offers a helpful template for this in its Small Entity Compliance Guide, while the CDC provides another template in its Respiratory Protection Toolkit. Additionally, companies like Stericycle offer disposable filtering facepiece RPP templates and guides, which are accessible through the Steri-Safe® OSHA program.
Qualified Administrator (QA)
Appointing a Qualified Administrator (QA) is also essential. This individual should be trained or experienced enough to oversee the RPP and evaluate its effectiveness. Specifically for N95s, the QA should clearly understand the workplace hazards that warrant N95 use as well as the relevant requirements laid out in OSHA’s Respiratory Protection Standard.
Medical Clearance
Before any employee can use a respirator, including N95s, they must receive medical clearance. While a medical exam may sometimes be necessary, often it is sufficient for a healthcare professional to review the responses on the OSHA-provided questionnaire, which is found in Appendix C of the Respiratory Protection Standard. It’s important to note that this questionnaire is confidential. The completed form must be submitted directly to the healthcare professional who will review it if a physical exam is necessary, not the employer, to maintain privacy. The healthcare professional will inform the employer whether the employee is cleared to use an N95 respirator based on the information provided in the questionnaire.
Medical clearance is not an annual requirement; it must be obtained before the employee first wears the N95 and only needs to be repeated if there is a change that would require re-evaluation.
Annual Fit Testing
Annual fit testing is indeed required for N95 respirators whenever their use is mandated. The requirements of the Respiratory Protection Standard apply, which means both initial and annual fit testing must be conducted, even for N95 models. Employers can choose to send their employees to external organizations for fit testing or perform the process internally. Materials needed for conducting fit tests are readily available from N95 respirator manufacturers and suppliers. In addition, many manufacturers offer excellent instructional videos online, particularly on YouTube, which demonstrate proper fit testing techniques for workers required to use N95 respirators. For comprehensive guidance, refer to the video resources mentioned below under Annual Training, which provides full instructions on performing N95 fit testing.
Annual Training
Training on N95s must be provided to workers before they use an N95 respirator, and refresher training is required on an annual basis. The training should ensure that workers are familiar with all necessary procedures and information before they begin using the equipment and that their knowledge is kept current every year. Training must cover, but is not limited to the following:
- Requirements of the Respiratory Protection Standard as it applies to N95s
- Limits of N95s (not for vapors, etc.)
- How to properly put on an N95
- How to properly remove an N95
- How to perform user seal tests of the N95 each time an N95 is put on, etc.
Everything you need for training is readily available online at no charge.
- OSHA makes Respiratory Protection Training for N95s available at https://www.youtube.com/watch?v=Tzpz5fko-fg.
- A longer video is also available at www.youtube.com/watch?v=6qkXV4kmp7c&t=17s.
- CDC makes training available on YouTube (including specific guidance for protection from Ebola).
- N95 respirator manufacturers also have excellent videos available on YouTube.
What about Voluntary Use?
- Q: What if N95s for a particular use or application are not specifically required by OSHA or recommended by CDC, but an individual simply chooses to wear an N95?
- A: In such a situation, a filtering facepiece respirator, such as an N95, is the only type of respirator that OSHA will permit a worker to wear on a voluntary basis without first obtaining medical clearance. Other respirators are permitted to be worn voluntarily; however, they must follow certain components of an RPP.
OSHA does require the employer to provide the worker with a copy of Appendix D to the Respiratory Protection Standard regardless of the respirator type when they are worn on a voluntary basis. A copy of Appendix D is available on OSHA.gov as part of the Respiratory Protection Standard. Be aware, however, that when respirator use is required, employers cannot use the voluntary exception to avoid developing a written respiratory protection program, appointing a qualified administrator, obtaining medical clearance for employees who will use the respirators, or providing annual training and annual fit testing.
Resources are available to help you achieve compliance
- CDC provides a resource, the Hospital Respiratory Protection Program Toolkit (HRPPT), that deals with the use of respirators in hospitals specifically at www.cdc.gov/niosh/docs/2015-117/pdfs/2015-117.pdf?id=10.26616/NIOSHPUB2015117.
- OSHA provides another thorough resource in a document called the Small Entity Compliance Guide to the Respiratory Protection Standard (SECG) at https://www.osha.gov/Publications/3384small-entity-for-respiratory-protection-standard-rev.pdf. At first glance this document can appear daunting, but much of it deals with higher level respirators, and only a few pages are applicable to N95s.
- In addition, both OSHA and CDC have online videos available on YouTube that pertain to N95s.
