OSHA Temporary Enforcement Guidance for Respiratory Protection

On April 8, OSHA expanded enforcement guidance on N95/filtering facepiece fit testing to include all employment sectors

OSHA issued guidance to its compliance officers on March 14, 2020 to use discretion when enforcing the annual fit testing requirement for N95 and other filtering facepiece respirators in healthcare settings. Protection of workers exposed to other respiratory hazards in other industries is impacted by the filtering facepiece shortage resulting from the response to the COVID-19 pandemic. On April 8, OSHA expanded its enforcement guidance for healthcare employers to apply to other employment sectors.

What does this guidance mean for your organization?

For employers who have a developed respiratory protection program and have done initial fit testing, OSHA has issued guidance to use discretion when enforcing the annual fit testing requirement for N95 and other filtering facepiece respirators. However:

• This only applies where the employee wears the same model, size and style respirator that the worker was fit tested on. If a different respirator is substituted, you must conduct fit testing before using these respirators in the workplace, with the following caveats:

o In the absence of quantitative or qualitative fit-testing capabilities, if the respirator model used during fit testing is unavailable, consult the manufacturer to see if it recommends a different model that fits similarly to the model used previously by employees.

o During this COVID-19 pandemic, OSHA field offices have been directed to exercise enforcement discretion when an employer switches to an equivalent-fitting make/model/size/style N95 or other filtering facepiece respirator without first performing an initial quantitative or qualitative fit test.

• Fit testing must also be conducted if there have been 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).

• If fit testing supplies are limited, prioritize use of fit-testing equipment to protect employees who must use respirators for high-hazard procedures.

• Workers should also conduct a user seal check each time they don the respirator to ensure they are getting an adequate seal.

• Employers should also assess their engineering controls, work practices, and administrative controls on an ongoing basis to identify any changes they can make to decrease the need for N95s or other filtering facepiece respirators.

o When reassessing these types of controls and practices, employers should, for example, consider whether it is possible to increase the use of wet methods or portable local exhaust systems or to move operations outdoors.

o In some instances, an employer may also consider taking steps to temporarily suspend certain non-essential operations.

• Please note that appropriate respiratory protection is required for all healthcare personnel providing direct care of COVID-19 patients.

Guidance on use of out-of-date respirators

OSHA is also permitting the use of out-of-date (expired) N95s for some activities. Expired N95s generally must not be used when healthcare providers perform surgical procedures on patients infected with, or potentially infected with, SARS-CoV-2, or perform or are present for procedures expected to generate aerosols or procedures where respiratory secretions are likely to be poorly controlled (e.g., cardiopulmonary resuscitation, intubation, extubation, bronchoscopy, nebulizer therapy, sputum induction).

If available, other filtering facepiece respirators (such as P100, R99), non-disposable elastomeric respirators and PAPRs that are still within their manufacturer’s recommended shelf life should be used before using respirators that are beyond their manufacturer’s recommended shelf life. Surgical masks and eye protection may be used as an interim measure against splashes and large droplets but are not respirators, and do not provide protection against aerosol-generating procedures. Engineering and administrative controls to reduce the need for respiratory protection should be implemented to protect employees.

Fit testing for other respirator types:

As of April 9, annual fit testing requirements for other types of respirators (e.g., half face, full face) have not been waived. Employers using these types of respirators should continue to perform annual fit testing as required by 29 CFR § 1910.134. Please note that the above guidance is specifically for healthcare, NOT general industry. General industry covered by OSHA Regulations are still required to follow all applicable OSHA Rules and Regulations and are required to perform annual respirator fit testing based on their current annual requirements timeline.

Written by Kirsten Romero - Certified Industrial Hygienist

See the full text of OSHA’s guidance here:

https://www.osha.gov/memos/2020-03-14/temporary-enforcement-guidance-healthcare-respiratory-protection-annual-fit

https://www.osha.gov/memos/2020-04-03/enforcement-guidance-respiratory-protection-and-n95-shortage-due-coronavirus

https://www.osha.gov/memos/2020-04-08/expanded-temporary-enforcement-guidance-respiratory-protection-fit-testing-n95

If you have questions about N95 respirators, OSHA Fit Test Standards, about fit testing or any other workplace safety questions, please don’t hesitate to contact our team @ 800-331-3218. We are here to help!

*** Disclaimer: This material has been prepared for general informational purposes only and is not intended to be relied upon for occupational health and safety reasons, legal or other professional advice. Please refer to your advisors for specific advice.

How to Properly Wear an N95 Face Mask

Wearing Your Face Mask Properly Matters…

In light of the recent Covid-19 pandemic, you may hearing all over the news or seeing for yourself at the local grocery store, the use of a specialized face mask, better known as an N95-style respirator. To avoid confusion, from here on out, we will now refer to any respirator as a mask. This article is particularly useful to our healthcare professionals or ANY workplace covered by OSHA where there is required use of respirators, especially those who are exposed to patients with suspected or confirmed coronavirus disease 2019 (COVID-19) and other sources of SARS-CoV-2 (the virus that causes COVID-19). Read our article here to learn more about what N95s are and WHO should be wearing one during this pandemic.

It is possible that wearing a mask alone may be providing some respiratory protection, however, if you are failing to properly adjust the mask to your face it is likely that you are not receiving any more protection than if you were wearing no mask at all.  Simply throwing a mask on your face, without properly adjusting it is not providing the level of protection that the mask is intended for or capable of.  Proper placement of the mask straps, correct molding of the adjustable nose bridge and placement of the mask on your face are all imperative when wearing a mask in order to provide protection. The following steps will walk you through how to properly don an N95 mask so that you are fully protected.

Things to Note Before Putting Your Mask On

Before donning you N95 mask, it is important to note that in order to properly wear an N95 or any tight-fitting mask, you must be clean shaven. Facial hair that lies along the sealing area of a respirator (beards, sideburns, or some mustaches) will interfere with respirators that rely on a tight face piece seal to achieve maximum protection. Ensuring the respirator seal is a vital part of respiratory protection practices. Any facial hair including stubble will push against the mask seal and create a “leak”, thus, preventing the mask from providing the level of protection it is intended for.

Finally, before putting on a mask, it is crucial to wash your hands with alcohol-based hand rub or soap and water prior to touching the mask to place it on your face. Remember to wash your hands thoroughly after taking the mask off, as well.

Step one: Get the strap placement right 

While holding the mask in one hand, move the elastic straps from the back of the mask to the front of the mask.  You will see a bottom and top strap. With one hand holding the mask, place the bottom of the mask on your chin and bring the top nose bridge section of the mask to your face.  The mask should be sitting flat on your face while you are holding it to your face with one hand.

The second hand will take the bottom strap and pull it over your head to the back of your neck.  You will then pull the remaining top strap onto the crown of your head. 

Having both straps properly positioned on your head ensures that pressure of the mask is evenly distributed on your face. 

Tip: Positioning the mask while looking into a mirror will allow you to properly center the mask, which is extremely important in gaining a proper seal on your mask.

Step two: Mold the nose bridge

After the mask is held to your face with the straps in their proper positions, you will now mold the nose bridge to form to your face.  With the pointer and middle fingers on both hands positioned on each corresponding side of your nose, apply pressure to the nose bridge and work your way down the nose.  This approach will apply the right amount of pressure and mold the nose bridge to your facial shape. 

Tip: Never pinch the adjustable nose piece with one hand (i.e.: pointer finger and thumb), this will -apply uneven pressure on the nosepiece and can significantly reduce the effectiveness of the seal on your mask.

Step three: Check your seal

Now that the mask is properly seated on your face, you will perform a positive and negative seal check. This is performed every time a mask is placed on your face and confirms that the mask seal is performing correctly.

First you will perform a positive seal check by cupping your hands together and covering the mask without overly applying pressure directly to it.  Take a deep inhalation breath and you should feel the mask lightly sucking to your face.

Next you will perform a negative seal check.  Cup your hands together and cover the mask without overly applying pressure directly to it, just as you did in the positive seal check.  Now you will exhale into the mask and should feel air slightly escaping through the nose bridge but nowhere else.

Performing this step every time you put the mask on is a way to ensure it is properly fitted to your face and providing the intended protection.

Additional considerations if your profession requires you to wear a mask 

If your profession requires you to wear a mask, two additional steps are required by the Occupational Safety and Health Administration (OSHA) in order to properly determine if you are physically capable of wearing a mask and that the mask fits your face properly.  The first step is to complete a Respirator Medical Evaluation Questionnaire. The second step is to participate in an annual Qualitative or Quantitative respirator fit test.

Under OSHA 1910.132, employees that are required to wear a mask in order to perform on-the-job duties will complete a respirator medical evaluation. The respirator medical evaluation is designed to identify general medical conditions that could place a worker at risk of serious medical consequences when a mask is used. This is an OSHA document that will be filled out and reviewed by a physician or other licensed health care professional. 

After receiving approval on a respirator medical evaluation, a respirator fit test is required annually to ensure the manufacturer, model, size and style respirator properly fits.  Not every person or facial shape is the same, so finding a proper fitting mask is pivotal in ensuring that it provides an adequate level of protection. A respirator fit test can be performed Qualitatively or Quantitatively. Once a fit test is passed, you will wear that specific type of mask you were fit tested on (same manufacturer, model #, size and style) for the year, until your next annual fit test. Following the steps to properly don a face mask coupled with wearing only the type of mask you were approved to wear during fit testing will ensure proper respiratory protection each time the mask is worn.

Due to the recent COVID19 pandemic, masks and fit testing kits/equipment are facing a severe shortage. Due to this shortage, owning a properly fitting mask and being fit tested may not be possible. By taking the appropriate donning steps summarized above you will greatly improve the fit and efficiency of the mask you are wearing, especially in the event of extended use or reuse of N95s as per OSHA’s temporary enforcement guidance for respiratory protection.

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If you have questions about N95 respirators, OSHA Fit Test Standards, respirator fit testing or any other workplace safety questions, please don’t hesitate to contact our team @ 800-331-3218. We are here to help!

*** Disclaimer: This material has been prepared for general informational purposes only and is not intended to be relied upon for occupational health and safety reasons, legal or other professional advice. Please refer to your advisors for specific advice.

Effectiveness of homemade masks in a pandemic

Fashionable, yes. Effective? Not so much.

If you spend any time on social media these days, you’re bound to see a parade of posts picturing brightly colored homemade cloth masks being donated to healthcare workers. Similarly, a quick search of “N95 Respirators” on Amazon or Google yields a vast array of “reusable” or “washable” cloth and fabric “N95s”. These are not National Institute for Occupational Safety and Health (NIOSH) approved N95 respirators and have not been tested for performance. Even in my small town on the Oregon coast, our local hospital is conducting a hand-sewn face mask drive. The Centers for Disease Control (CDC) has issued guidance suggesting that homemade masks may be used; however, this guidance emphasizes homemade alternatives should be used ONLY as a last resort. Furthermore, the CDC statement includes the caveat that these homemade alternatives should not be considered personal protective equipment (PPE).

I have been working closely with healthcare organizations requiring fit testing and training on N95 respirators since long before the virus causing COVID-19 first made headlines. The shortage of available N95s is dire. As a Certified Industrial Hygienist my job is to protect employees' health in the workplace by implementing programs, policies and procedures to measure and reduce their exposure to physical, chemical, biological and ergonomic stress factors. My years of experience coupled with research evidence leads me to have serious doubts about the effectiveness of homemade masks as a form of protection for healthcare workers. After all, companies like 3M, Honeywell and Moldex have worked for years to engineer N95s that meet NIOSH criteria (click here and view the “What is an N95” section find out the 3 mains ways an n95 is specially engineered to keep particles from entering). While I admire the volunteers’ mask-making efforts during a time of crisis, is there evidence that homemade masks are effective? Or are we simply providing healthcare workers with a false sense of security?

A quick search of PubMed yielded answers. Researchers in Vietnam compared infection rates in healthcare workers wearing homemade cloth masks to surgical masks and found that rates of clinical respiratory illness (CRI), influenza-like illness (ILI) and laboratory-confirmed respiratory virus infection were significantly higher in the cloth mask group. These results caution against the use of homemade cloth masks for protection from respiratory pathogens.

Homemade masks could be of value when placed on symptomatic patients if surgical mask supplies have been exhausted.

If homemade masks are not effective as Personal Protective Equipment (PPE), do they have any value? To answer this, we turn to another study, this one published in Disaster Medicine and Public Health Preparedness. Masks made of various materials were tested for their efficacy in reducing droplet and particle transmission when worn by a coughing individual. Two layers of cotton t-shirt material or pillowcases reduced transmission, but not as effectively as surgical masks. This suggests that homemade masks could be of value when placed on symptomatic patients if surgical mask supplies have been exhausted.

What should healthcare workers do, then, if N95 respirator stocks are limited? First, remember that PPE is the bottom rung in the ladder of controls. Wherever possible, engineering and administrative controls should be implemented first, as these controls separate workers from the hazard area. Examples of engineering controls include the use of isolation rooms and properly maintained ventilation systems. Administrative controls such as telemedicine and postponing non-urgent procedures are being implemented in hospitals around the country. The CDC lists these and other strategies for optimizing the use of N95s at various stages of capacity.

When direct patient care is necessary, if N95 stock is limited, healthcare providers should first turn to elastomeric respirators and powered air-purifying respirators (PAPR) as alternatives. These give a higher level of protection and are intended to be reusable. Proper disinfection methods should be utilized to avoid contamination.

If these alternatives cannot be obtained, industrial filtering facepiece respirators and medical N95s past their use-by date but still in their original packaging and in unused condition may be used. Call upon manufacturing and construction businesses in your local area to donate excess supplies. They may also have rubber gloves, disposable coveralls, face shields and goggles they can spare, especially if their workers are sheltering at home.

Wearing a non-medical or homemade mask to go out in public may be a good idea.

At the crisis stage, when hospitals are overrun with patients and protective equipment is scarce, extended use or reuse of N95s may be necessary. Prioritize tasks with higher risk of exposure when determining when to wear respirators. Use strategies such as wearing a face shield over your respirator to minimize splash or spray risk, and mask patients with surgical masks whenever possible. Homemade masks are not recommended over top of N95s, as this could lead to a buildup of moisture inside the respirator and significantly reduce air flow. The public can assist by creating improvised face shields. These work as a barrier to protect the N95 from aerosol spray from the patient and do not need a special fit or design.

In summary, improvised masks do not provide the protection healthcare providers need to when in close contact with patients with a suspected viral disease and may cause the health care provider to in fact spread disease, as has been seen with the spread of some COVID-19 cases in Italy. However, this does not mean homemade masks are worthless. When surgical masks are in short supply, cloth masks are a viable alternative for use by the general population to reduce transmission of the coronavirus while out in public. In a healthcare setting they may be useful (as a last resort) for masking coughing patients or for use by staff who will not have direct or close patient contact.

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*** Disclaimer: This material has been prepared for general informational purposes only and is not intended to be relied upon for occupational health and safety reasons, legal or other professional advice. Please refer to your advisors for specific advice.

Written by Kirsten Romero - Certified Industrial Hygienist with Mobile Health Diagnostics