More on Respiratory Protection Programs

By Lee Slaton, Vice President of Healthcare; Smart Training

My last article probably generated more questions than I’ve ever received in the last three years of writing these articles. I thought this month I’d cover the most-frequently referenced subjects related to OSHA’s mandatory respiratory protection program.

Mandatory Respiratory Protection Program

Who’s required to have a mandatory respiratory protection program?

Any entity that has employees who are either required to wear a respirator or who choose to wear a respirator voluntarily.

What are required components in OSHA’s respiratory protection program?

There are five:
• An OSHA written respiratory protection program (which includes record keeping)
• Someone appointed to serve as administrator of that program
• Documented training for all employees in the program
• Medical evaluations for all personnel who will be wearing a respirator, whether they wear them on a required or voluntarily basis.
• Fit tests for all personnel required to wear a respirator

Medical Evaluations

Who can perform medical evaluations for employees that will wear respirators?

A licensed healthcare professional must perform the evaluations; which mean dentists can perform them. In Smart Training’s OSHA respiratory protection plan (dental version), we recommend a practice utilize its own dentist, which would save the cost of having an outside provider conduct the evaluations.

The medical evaluation is performed to provide assurance the wearer should be safe while using respirators. It’s accomplished by reviewing the medical evaluation questionnaire that must be completed by each respirator user. This questionnaire is found in Appendix C of the OSHA regulations that spell out the respiratory protection program. (Smart Training’s program provides a link where you can download the medical evaluation.) The regulations governing the OSHA respiratory standard can be found in CFR 1910.134. (You can Google it.)

If the dentist conducting the medical evaluations sees no concerns, he or she simply signs off on the respective users. If the dentist notes any concerns stemming from a user’s answers, we recommend the dentist refer the user to a physician or other licensed healthcare professional with more experience in respirator issues.

Fit Test

Which users must have a fit test?

Any user who is required to wear a respirator. In Texas dental settings, the TSBDE rules set the standard by stating, “DHCP shall implement Transmission-Based Precautions, including N-95 respirator masks, KN-95 masks, or their substantial equivalent for all DHCP who will be within six (6) feet of any and all procedures likely to involve aerosols.” For clarification’s sake, the TSBDE does not consider wearing a level-3 mask in conjunction with a face shield to be a “substantial equivalent” to an N-95 respirator.

Who can perform a fit test?

Anyone who has been trained to perform a fit test. In our training module for respiratory protection program administrators, we include a 10-minute video on how to properly perform a fit test.

Where practical, we recommend practices perform fit tests in-house, as the cost savings can be substantial for larger practices. The big holdup in performing them internally stems from the lack of fit-testing kits, which are currently incredibly hard to source. That leaves the option of utilizing other firms that offer fit testing; namely occupational health clinics. Most of those clinics offer walk-in testing. Some firms will come to your office to conduct the tests, if you have enough users to make it worth their while. Make sure to let them know you’re going to conduct the medical evaluations yourself, as this can save you $20-40 per user.

What is the difference between a fit test and a user seal check?

A fit test is something each required user of a respirator must complete before starting use of a respirator, and must complete annually thereafter. (The annual requirement has been temporarily rescinded by OSHA.)

A user seal check is a procedure every respirator user must conduct every time they don a respirator, to ensure it seals around their face correctly. Our training module for respiratory protection plan users includes a short video on how to properly perform a user seal check. Since conducting a user seal check requires the user place their hands against the outside of the respirator, using proper donning and doffing procedures is paramount to preventing cross-contamination.