Respirator Requirements


Hi, it’s the Spanish OSHA Guy! In my previous blog post on Health Effects on Firefighters of 9/11, I promised to write more information on Respirator Requirements. In my OSHA 10 hour and OSHA 30 hour trainings in both General Industry and Construction, many people ask about what is required before an employee wears a respirator. Oftentimes painting contractors, marble and granite fabricators and other clients who deal with dusts, silica, particulates, lead and other contaminates tell me that they tested contaminate levels and chose the proper respirator for their employees. But they missed 2 important and indispensable steps:

  1. Fit Test
  2. Medical Exam

The Fit Test is a training. It covers how to properly wear the respirator, why you need to wear it, how to verify you have a proper seal, that men must have a clean shave every morning, how to change the filters/cartridges, when to change the cartridges, how to store it and how to maintain it among other items. Men must have a clean shave each day because if they have 1, 2, 3 days or more of a beard growing then they are fooling themselves thinking they are protected, but truly they are not. A respirator is designed to provide 100% protection against inhaling toxic gases or cancer-causing particulates that you cannot see with the naked eye. If you have even one day of beard growth, you are ruining the seal that is so critical for your protection and thus inhaling the contaminates. This is why OSHA and safety professionals strongly recommend and teach to first try to control or minimize the contaminates before jumping to a respirator. Oftentimes you still need a respirator, but first you should always seek to minimize the hazard as much as possible through means such as ventilation, air scrubbers, wetting the area down among other controls.

The Medical Exam is critical because studies have shown the wearing a respirator makes the heart work about 30% more than normal. Thus, a physician or other licensed health care professional must A physician or other licensed health care professional must perform the medical evaluation using the medical questionnaire contained in Appendix C of 29 CFR 1910.134 or an initial medical examination that obtains the same information. The beauty if OSHA is they actually provide the very questionnaire that the doctor must complete. This is often the case with OSHA, they will provide an appendix to help companies fulfill the requirements of the OSHA standards. Here’s the thing, some companies want to avoid respirators at all costs because of this medical exam requirement. Some people have said to me, “Once you do a medical exam, you own the employee.” People say this because the law states that you must keep medical records on your employees for 30 years after they leave the company! This is fine as long as the company successfully reduces the contaminates below safe limits. But if they cannot achieve this then the company must provide respirators. And to those companies who still try to avoid respirators when they must provide them, I have to say this:  They need to get over doing the bare minimum and being to see their employees as a valuable resource and engine of their company and not some expendable resource whose health can be toyed with!

OSHA’s Respiratory Protection Standard is found in 29 CPR 1910.134 and applies to all industries including Construction as well as Manufacturing. The following link to the OSHA website provides a fantastic summary of the respirator standard and includes FAQ’s, a Summary of the Major Requirements of the Standard and a Small Entity Compliance Guide among other links.

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Leave A Reply (2 comments so far)

  1. david
    3 years ago

    Is it required by osha to be clean shaved for resporater fitting

    • spanishOSHAguy
      3 years ago

      Dear David,
      Yes, it is required to be clean-shaven for respirator fitting. In order to wear a tight-fitting respirator that creates a seal with your skin, men must have a fresh shave each morning. Otherwise, they are fooling themselves thinking that they are protected, but really they are not afforded the full protection that the respirator is designed to give them. Thanks for the question!

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