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June 1999 New CalOSHA Respiratory Protection Standard Fit Test Requirements Even though you may have a respiratory
program in place that addresses fit testing procedures, you may need to make a few minor adjustments to meet the new standard requirements. The following is a brief outline of the new fit testing requirements, including some
common questions and answers surrounding this issue. GENERAL REQUIREMENTS
The CalOSHA Respiratory Standard went into full effect on May 23, 1999. At that time all employees who are required to wear either a positive or negative
pressure tight-fitting facepiece respirator must be given a fit test. This requirement includes both air-purifying and atmospheric-supplying respirators (such as SCBA's) that operate in either a positive or negative pressure mode. Fit testing is
not required
for any loose-fitting respirator such as a dust mask or helmet respirator, nor is fit testing required for employees who voluntarily wear a tight-fitting facepiece respirator. Fit testing must be performed prior to initial use, whenever a different tight-fitting facepiece (size, type, make, model, etc.) is worn and at least
annually thereafter. Under the old standard annual fit testing was a strong CalOSHA recommendation - now it is mandatory. As before, there are two types of fit testing methods: ¨ Quantitative Fit Test (QNFT) which measures the amount of leakage into a respirator and provides a numeric assessment of how well a respirator fits a particular individual. CalOSHA has approved three QNFT protocols; the generated aerosol protocol, the condensation nuclei counter (CNC) method offered by Portacount ™, and the controlled negative pressure (CNP) method offered by Dynatech Nevada.¨ Qualitative Fit Test (QLFT) which is a non-numeric pass/fail test that relies on the respirator wearer's response to a test agent. In addition to the three QLFT protocols already approved under the old standard (Isoamyl Acetate, Saccharin Solution Aerosol, and Irritant Smoke) CalOSHA has added the Bitrex protocol which is similar to the Saccharin taste test.
MANDATORY FIT TESTING PROCEDURES In addition to the fit
test protocols found in appendix A of the standard, there are general fit testing procedures which must be followed such as: ¨ Allowing employees to choose the most acceptable respirator. This means there must be a sufficient number of models and sizes available to try on so that the respirator correctly fits the user.¨ Showing the user how to properly put on a respirator. This includes providing a mirror so that the fit testing subjects can evaluate and position the respirator to fit correctly. ¨ Ensuring that the user wears the facepiece for at least five (5) minutes to assess the comfort of the facepiece. For example, is the facepiece positioned properly on the nose, face and cheeks? Does the facepiece leave room for eye protection and room to talk? ¨ Ensuring the fit test includes a negative or positive user seal check. ¨ A fit test may not be performed if there is any hair growth between the skin and the facepiece sealing surface. This includes beards, stubble beard growth, mustache or sideburns that cross the facepiece sealing surface. Once a facepiece has been selected that fits the user and is comfortable, a fit test using one of the approved CalOSHA protocols is given. Except for the CNP quantitative method, fit testing must include performing all of the following exercises for one (1) minute, except for the grimace test that is performed for 15 seconds: q Normal breathingq Deep breathing q Turning head side to side q Moving head up and down q Talking q Grimace q Bending over q Normal breathing
In summary, some of the major differences between the prior fit testing requirements and the new requirements are: ¨ Mandatory annual fit testing¨ An additional qualitative fit test agent - Bitrex ¨ New quantitative test protocols ¨ Mandatory fit testing of positive pressure respirators such as SCBA's ¨ The requirement for positive pressure respirators to be temporarily converted to negative pressure mode during fit testing.
New Fit Testing Requirements – Questions and Answers Who must be fit tested? All employees, who must wear either a positive or negative pressure tight-fitting respirator, must be fit tested. What is a tight-fitting facepiece? A tight-fitting facepiece is intended to form a complete seal with the wearer's face. Examples include full-face SCBA masks, and full-face or half-mask cartridge respirators.
Although dust masks are considered a ½ mask respirator, they are not considered tight-fitting and therefore do not require fit testing. Do employees who wear tight-fitting respirators strictly for voluntary reasons need to be fit tested? No. However, if the employer allows voluntary respirator use they must provide certain information to the employee that is contained in Appendix D of the standard and the employee must still receive a medical evaluation (see CSRMA Bulletin – April 1999). What is considered voluntary use of respirators? If it is not required to wear a respirator, but an employee wishes to wear one anyway, this is considered voluntary use. The respirator may be provided by the employer or by the employees themselves, however, the employer must first determine that such use will not in itself create a hazard. If a job activity requires a respirator to be worn (e.g. exposures greater than the PEL or company policy requires it) this is not considered voluntary use. Examples of voluntary use is wearing an air-purifying respirator when sweeping, mowing grass, or other activities that create "nuisance" dusts or pollens. Can we continue to use qualitative fit testing for Supplied-Air Respirators such as SCBA's? Currently, the answer is yes as long as the respirator is used in the positive pressure (pressure demand) mode and the facepiece is temporarily converted into a negative pressure respirator during fit testing. If the respirator is going to be used in a negative pressure, or demand mode, then a quantitative fit test must be performed. Since supplied-air respirators are generally worn for protection in dangerous (or potentially dangerous) atmospheric conditions, and since the quantitative method is more reliable and more accurate than qualitative fit testing, users are assured a higher degree of protection. For this reason, CalOSHA is considering changing this requirement to mandatory quantitative fit testing for all supplied-air respirators regardless of the mode they are used in. How can get our employee's quantitatively fit tested? There are numerous vendors throughout the state who will come to your facility and perform quantitative fit testing using the Cal OSHA approved equipment. An informal survey performed by CSRMA Risk Control revealed that prices range from $25 to $75 per person depending on the vendor and on the number of fit tests performed.
Listed below are three vendors that David Patzer, CSRMA Risk Control Advisor, and Lorri McAuliffe, former CSRMA Risk Control Advisor, have previewed and can recommend:
How do we convert a Supplied-Air respirator into a negative pressure respirator? Check with the respirator manufacturer or your supplier. All of the Supplied-Air respirator manufacturers have adapters that will accommodate your respirator type and model. Another option is to use an identical negative pressure facepiece (same size, make and model).
Where can we go for more information? You can either call the CSRMA Hotline number at (415) 371-5430, dial up the CSRMA web page at www.CSRMA.org. call your nearest CalOSHA Consultation office, or go to the CalOSHA web page at www.dir.ca.gov. CalOSHA's web site has a variety of excellent documents available such the "Small Entity Compliance Guide for the Revised Respiratory Protection Standard." This document is an easy-to-ready, step-by-step informative compliance guide that includes a sample written respirator protection program.
Don't Forget to Complete Your CSRMA Y2K Preparedness Survey and Return to CSRMA Risk Control if You Haven't Already Done So!
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