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Review requirements for respirator fit testing to ensure OSHA, CMS compliance

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June 1, 2019

Ensure whoever oversees fit testing of respirators on employees at your workplace — whether it’s someone within your organization or an outside contractor — understands what is required to correctly conduct the test to meet OSHA standards.

The failure to conduct proper fit testing of respirators can be cited under OSHA’s respiratory protection standard, 29 CFR 1910.134 and 29 CFR 1926.103, as well as CMS Conditions of Participation (CoP) for infection control. Hospitals were cited by CMS surveyors on at least two occasions in 2018 for either not having a respiratory protection program at all or for not conducting fit testing according to CDC or OSHA requirements.

Beware that OSHA may be stepping up its respiratory standard compliance. It recently issued a reminder that each employee must pass a medical evaluation before being fit tested for a respirator.

You have a choice between a quantitative or qualitative test method for respirator fit testing. Whoever oversees your respiratory protection program must know enough about each method to ensure the tests are done right and employees are well protected by the respirator in which they choose to work, says Jessica Hauge, CIH, CSP, an Application Engineering Specialist with 3M’s Personal Safety Division in St. Paul, Minnesota.

Hauge has published research on respirator products and conducts training on proper fit testing and the use of respirators in general.

According to the CDC’s National Institute for Occupational Safety and Health, a fit test is a “protocol conducted to verify that a respirator is both comfortable and correctly fits the user. Fit testing uses a test agent, either qualitatively detected by the wearer’s sense of taste, smell, or involuntary cough (irritant smoke) or quantitatively measured by an instrument, to verify the respirator’s fit.”

Hauge discussed what supervisors need to know about respirator fit testing and why.

Q Who should oversee the fit-testing? Can that be someone on staff and if so, what qualifications must they have to do it correctly and to meet OSHA compliance standards?

Hauge: According to OSHA, one person in the organization needs to be designated the respiratory protection program administrator. That person is ultimately accountable for all elements of the respiratory protection program. But they may delegate any element, including fit testing, to another person to oversee. That fit tester can be another person within the organization, or the program administrator can hire an external service to conduct the fit testing on his or her behalf.

OSHA says that all fit testers must be able to calibrate equipment, perform tests properly, recognize invalid tests, and ensure that test equipment is in proper working order. Additionally, OSHA says that fit testers that conduct qualitative fit testing must be able to prepare test solutions, and fit testers that conduct quantitative fit testing must be able to calculate fit factors—although these days, commercially available field quantitative fit test equipment calculates the overall fit factor automatically.

Q How often should fit testing be done, after the initial time? Every year? Every month? Every time a respirator is needed? Or just when the type of respirator changes? What about if the employee gains or loses a lot of weight? What’s best practice?

Hauge: Per OSHA 29 CFR 1910.134, fit testing needs to be repeated at least annually.  It should be repeated sooner if anything changes with a respirator wearer’s physiology that could impact the respirator’s ability to fit his or her face adequately.  That can include weight loss or gain, as well as changes to the teeth, jaw, or skin. A new fit test should be conducted if a new respirator model is assigned.

Q What if you don’t have any respirators to fit a particular employee—fit them in the closest one? Get them a new one? Or just assign someone else to jobs that require that respirator?

Hauge: No one respirator model is capable of fitting every single person. For that reason, OSHA requires that employers offer a variety of respirator models and sizes, to try to find one that not only fits but is also acceptable for every employee in the respirator program. If no tight-fitting respirator can be found that both fits and is acceptable to an employee, then a respirator that includes a loose-fitting headtop—such as a powered air-purifying respirator (PAPR) or supplied-air respirator—can be considered instead.

Q What are the most common mistakes organizations make with fit testing? Any tips to avoid those mistakes?

Hauge: Fit testers need to make sure they are proficient at conducting fit testing using the method or methods they will be using.  Before conducting OSHA-required fit testing for a worker in a respirator program, fit testers should: 1) read OSHA 29 CFR 1910.134 Appendix A, Fit Testing Procedures (see link below); 2) attend a class if possible; 3) read the user instructions of their fit test equipment; and 4) practice fit testing with a friend, or ask a knowledgeable colleague to oversee their first fit tests.

Fit testing, just like many new skills, can be challenging at first. But when fit testers take the time to practice and become familiar with their equipment, they can be competent and confident in their ability to recognize and avoid invalid fit test practices.  For example, since the Bitrex and Saccharin methods are both taste tests, fit testers need to instruct their subjects to breathe through their mouths for the entire fit test.  And when fit testers use the ambient aerosol method to fit test N95 respirators, they need to ensure that they have configured the fit test instrument to use a particle classifier, to ensure that they are detecting only particles that enter the respirator through any leaks in the seal, and not particles that penetrate the filter media.

Finally, no fit tester should ever deviate from the fit test procedures that are required according to OSHA 29 CFR 1910.134 Appendix A. The fit test protocols that are published in the standard are written there exactly as they were validated. If deviations, such as different-length exercises, or different challenge agent generation methods are employed by fit testers, then those tests may not be valid.

Q The quiz on (see June PDF) offers a lot of specifics—do all supervisors need to know all these things? Or just the ones overseeing the fit testing?

Hauge: Anyone conducting fit testing should know all the specifics of the particular methods he or she will be using. In addition, a respirator program administrator should know enough of the details of the fit test methods that are employed in their respirator program to be able to ensure that fit testing is being  conducted correctly—since the program administrator is ultimately accountable for the effectiveness of that program, including the fit testing.

Many fit testers may only need to know the specifics of one single fit test method.  Many organizations only employ one single quantitative fit test method. Although the fit tester(s) and program administrator for that organization need to be very familiar with the details of that method, it wouldn’t be necessary for them to know details of all other methods as well.

On the other hand, if an organization employs a qualitative method as their primary fit test method, they will likely need to have a second or third method available for use, in case a subject fails a sensitivity test. In that case, fit testers may need to be familiar with the details of multiple fit test methods.

Q Should supervisors go through fit testing even if they don’t expect to ever wear a respirator?

Hauge: Employees who might need to wear a respirator need to undergo a fit test. If supervisors expect to spend time in respirator-required areas, they should consider undergoing a fit test. Even if supervisors don’t expect to spend enough time in the respirator-required area that their exposure would exceed an exposure limit, wearing respirators just to lead by example can go a long way toward fostering buy-in and a positive safety culture among the workers who have to wear respirators.

Q Is there anything particular to the health care industry that supervisors should be aware of regarding respirators and ensuring that they fit an employee when needed – as you probably know, sometimes things happen quickly at a hospital and you can’t always look things up on the spot.

Hauge: Healthcare workplaces can be fast-paced and unpredictable.  But no one should ever be in a situation where they suddenly need to wear a respirator but haven’t yet been fit tested.  The hospital’s programs should account for both routine exposures to potentially infectious diseases and also the possibility of a pandemic outbreak. All staff who might be involved in the hospital’s operations while accommodating patients affected by an infectious disease outbreak should be fit tested and trained on the respirators that would be available during that event.

Resources

For more on fit testing, you can find NIOSH-approved resources on the CDC’s “Respirator Trusted-Source Information” webpage: https://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/respsource.html

For more on OSHA’s Respiratory Protection requirements: https://www.osha.gov/SLTC/respiratoryprotection/index.html

NIOSH/OSHA/CDC Hospital Respiratory Protection Program Toolkit: https://www.osha.gov/Publications/OSHA3767.pdf
 




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