On March 14th, OSHA released a memo allowing employers to suspend Annual Respriator Fit testing due to a shortage of fit-testing kits and masks themselves. Until further notice the following guidance has been given by OSHA:
OSHA field offices shall exercise enforcement discretion concerning the annual fit testing requirement, 29 CFR § 1910.134(f)(2), as long as employers:
◾ Make a good-faith effort to comply with 29 CFR § 1910.134;
◾ Use only NIOSH-certified respirators;
◾ Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use, as discussed above;
◾ Perform initial fit tests for each HCP with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19 (initial fit testing is essential to determine if the respirator properly fits the worker and is capable of providing the expected level of protection);
◾ Inform workers that the employer is temporarily suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators for use in situations where they are required to be worn;
◾ Explain to workers the importance of performing a user seal check (i.e., a fit check) at each donning to make sure they are getting an adequate seal from their respirator, in accordance with the procedures outlined in 29 CFR § 1910.134
◾ Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or obvious changes in body weight) and explain to workers that, if their face shape has changed since their last fit test, they may no longer be getting a good facial seal withthe respirator and, thus, are not being adequately protected;
and,
◾ Remind workers that they should inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.
Source: OSHA Memo 3-14-2020
There are other changes highlighted in this articles by Safety and Health Magazine: OSHA allowing all employers to suspend annual respirator fit testing