New OSHA (and Cal/OSHA) Guidance on use (and re-use) of N-95 “Filtering Facepiece Respirators”

N-95 dust masks are considered “filtering facepiece respirators” (FFRs) by OSHA and use of FFRs at work (as well other types of respirators) is regulated by the OSHA respiratory protection standard (29 CFR 1910.134).  This standard, along with associated enforcement guidance and interpretations, limits the service life and re-use of FFRs and requires that all FFRs used for worker protection have current NIOSH certification.  Recent guidance from OSHA (https://www.osha.gov/memos/2020-04-03/enforcement-guidance-respiratory-protection-and-n95-shortage-due-coronavirus) temporarily relaxes some of those requirements as healthcare providers and others struggle with limited supplies.  This is in addition to emergency actions from the FDA to increase access to respirators (https://www.fda.gov/media/136403/download), including allowing use of some respirators certified outside the U.S. and authorizing use certain industrial respirators to be used in healthcare settings. Remember - members of the general public are encouraged (and in some cases required) to wear face coverings when in public.  These face coverings are intended to prevent the wearer from inadvertently spreading contamination, they are not intended as personal protective equipment.  In order to preserve as many respirators as possible for healthcare providers and others who need them, FFRs should not be used as face coverings.  If respiratory protection needed for worker protection (not social distancing) outside of healthcare, employers should use non-disposable respirators wherever possible, consistent with applicable OSHA standards. Fed OSHA Guidance on Extended Use and Re-Use The recent OSHA guidance suggests that employers maximize use of engineering and administrative controls as well as re-usable types of respirators.  If these are not sufficient, OSHA will allow extended use and/or re-use of an FFR by the same worker if the respirator is physically intact, structurally sound and not excessively soiled or contaminated.

• Employers should develop procedures for storage and for donning/doffing potentially contaminated FFRs if they are being re-used
• Workers should be instructed that if seal checks cannot be performed successfully, the respirator should no longer be used
• Employers who need to extend use or re-use should update their written respiratory protection plan (RPP) as needed to address these issues and to describe circumstances under which a disposable respirator will be considered contaminated and not available for extended use or reuse

If other options are not available, the OSHA guidance also allows use of certain respirators that have passed the manufacturer shelf life, as long as they pass a visual inspection and as long as they are not used for certain high-risk surgical procedures (see list of respirators at https://www.cdc.gov/coronavirus/2019-ncov/hcp/release-stockpiled-N95.html). Cal/OSHA Guidance on Extended Use and Re-Use The situation is similar in California.  The Cal/OSHA respiratory protection standard (8 CCR 5144) is similar to the fed OSHA standard (including restrictions on extended use and re-use of disposable respirators), however healthcare facilities in California also have to comply with the provisions of the aerosol transmissible disease (ATD) standard (8 CCR 5199).  Recent Cal/OSHA guidance (https://www.dir.ca.gov/dosh/coronavirus/Cal-OSHA-Guidance-for-respirator-shortages.pdf) allows similar flexibility for extended use or re-use of FFRs in order to conserve respirator supplies, as long as the details are captured in an updated RPP.  In addition, for healthcare facilities regulated under the ATD standard, Cal/OSHA allows surgical masks to be used instead of respirators under limited circumstances and for lower hazard medical tasks if FFRs or other types of respiratory protection are not available. Do you have any questions about respiratory protection and Covid?  Or about respirator use in general?  Or any other workplace safety or environmental compliance issues? Contact [email protected]

James Kapin, MPH, CIH, CSP Director of EM Services, ACTenviro