On September 26, OSHA added two new protocols for ensuring employees’ respirators fit properly. When employers are required under personal protective equipment regulations to provide respiratory protection, they also are required to ensure the respirators properly fit each employee.
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The new protocols are variations of an existing OSHA-approved method, the ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol, often referred to as the “PortaCount® protocol.” The new protocols are:
- The modified ambient aerosol CNC quantitative fit testing protocol for full-face piece and half-mask elastomeric respirators; and
- Modified ambient aerosol CNC quantitative fit testing protocol for filtering face piece respirators.
The new protocols have fewer test exercises, shorter exercise duration, and a more streamlined sampling sequence than the existing ambient aerosol CNC quantitative fit testing protocol.
The protocols provide employers with alternatives to the four quantitative fit testing protocols already listed in the respiratory protection standard. The new protocols apply to employers in general industry, shipyard employment, and the construction industry.
Original, Modified Protocols
The original ambient aerosol CNC protocol uses a sample device installed on the respirator to quantitatively test the respirator’s fit. The probed respirator is used only for the fit test.
The PortaCount protocol employs a series of eight test exercises, performed in the following order: normal breathing, deep breathing, turning head side to side, moving head up and down, talking, grimacing, bending over, and then normal breathing again.
The modified ambient aerosol CNC protocol for full-face piece and half-mask elastomeric respirators differs from the original protocol as follows:
- It includes only three of the eight original test exercises (bending over, head side to side, and head up and down).
- It adds jogging in place as a new exercise.
- It reduces the total test duration from 7.2 to 2.5 minutes.
The modified ambient aerosol CNC protocol for filtering face piece respirators differs from the original protocol as follows:
- It includes only four of the eight original test exercises (bending over, talking, head side to side, and head up and down).
- It reduces the total test duration from 7.2 to 2.5 minutes.
Employers, States, Consensus Standard
Although employers are not required to use the new protocols, the agency believes having alternative fit testing methods gives employers greater flexibility and can reduce the burdens of complying with the respiratory protection standard.
Because the protocols are part of an appendix to the respiratory protection standard, states administering their own workplace safety and health programs are not required to adopt them. However, OSHA strongly encouraged states to adopt the new protocols to provide employers additional compliance options.
The agency also said the new protocols are consistent with the industry consensus standard developed by the American National Standards Institute (ANSI) and American Industrial Hygiene Association (AIHA)—ANSI/AIHA Z88.10-2010, “Respirator Fit Testing Methods.” OSHA concluded the new protocols meet the evaluation criteria outlined in the consensus standard.
The final rule amending the respiratory protection standards is effective immediately.