The State of Respirator Fit Testing for Employee Health

In the U.S., the government requires employers to provide employees with protective respiratory equipment in industries where they may be exposed to contaminants, including infectious diseases.¹

Ensuring these facial respirators fit is an integral part of the Occupational Safety and Health Administration’s (OSHA) guidance on protecting employee health, so formal tests are conducted on individual employees to verify that their respirators provide adequate protection.² However, healthcare facilities had the option to postpone fit tests at the height of the COVID-19 pandemic due to shortages of N95 respirators and other personal protective equipment (PPE).³

Below, we’ll look at the current state of fit testing in light of the ongoing pandemic and the challenges faced by Employee Health (EH) departments reinstituting fit tests.  

What Is Respirator Fit Testing?  

In the healthcare industry, particulate filtering facepiece respirators (FFRs, or Surgical N95 Respirators) are chosen by each employee from a list of approved equipment provided by the National Personal Protective Technology Laboratory (NPPTL) in the National Institute for Occupational Safety and Health (NIOSH), which is part of the Centers for Disease Control and Prevention (CDC).⁴

Respirators must form a tight seal around the nose and mouth to be adequately protective. As a result, OSHA (29 CFR 1910.134) requires healthcare workers to undergo a “fit test”: 

• At the time of hiring and before employees are provided with their preliminary protective respirators
• Annually, to ensure the equipment still fits and forms a proper seal
• Any time their face shape changes, for example, after weight fluctuations, dental work, cosmetic surgery, scarring, or when facial hair changes and affects the fit of the facepiece (This can be reported by the employee or observed by one of the following: a) a physician or other licensed healthcare professional (PLHCP), b) a supervisor, or c) a program administrator.)
• When an employee or employer decides to switch to a different type of respirator

How Does a Respirator Fit Test Work?

Before a fit test is performed, a nurse practitioner or physician may perform a physical test on the employee to ensure they do not have breathing issues or respiratory problems that are worsened by wearing a tight-fitting respirator. Next, the employee is given a choice of respirators based on preference and comfort. 

Employers can choose to perform either a qualitative or a quantitative fit test.⁵ The qualitative fit test (QLFT) depends on an employee’s perceived sense of taste or smell when exposed to an irritant while wearing the respirator. The quantitative fit test (QNFT) uses an instrument to measure leakage around the respirator’s seal.⁶

Who Performs Respirator Fit Tests?

 OSHA does not require that the appointed “respiratory program administrator” be specially licensed. The only requirements are that program administrators must: 

• Be “suitably trained” in performing the test and maintaining the equipment
• Understand the complexity of OSHA requirements
• Be capable of recognizing and controlling workplace hazards specific to the facility that hired them and hazards that can be reasonably expected to occur
• Be familiar with every type of respirator used by their employer’s staff

There can only be one respirator fit test administrator per worksite to ensure continuous and consistent program oversight. However, other employees can assist in the fit tests and medical evaluations.⁷ 

Why Did Respirator Fit Testing Stop?

Because some N95 respirators are single-use or contain a single-use filter, fit testing during the pandemic meant destroying valuable resources that were in short supply.  Therefore, on March 14, 2020, OSHA issued temporary guidance allowing facilities to put the tests on hold as long as they were making good-faith efforts to comply with OSHA 29 C.F.R. § 1910.134 and using NIOSH-approved masks.⁸ 

What Challenges Do Employee Health Departments Face When It Comes To Respirator Fit Testing?

As the world adjusts to pandemic life, facilities that had paused their respirator fit testing are now reviving their programs. As a result, Employee Health departments will have extra challenges, including:

• Finding the time required to administer the tests to all employees (the tests take roughly 5 – 10 minutes) 
• The need for special equipment to administer the tests (new quantitative testing machines can cost as much as $12,000 per machine)⁹
• A lack of space to accommodate machines or conduct tests on-site, particularly at smaller facilities 
• Finding qualified fit test administrators or convenient external test providers 
• The urgency of performing fit testing in light of increasingly dangerous infectious diseases, such as COVID-19
• Scheduling fit tests for new employees during a time of rapid turnover 
• Monitoring employees for signs that their masks no longer fit due to changes in facial structure or facial hair (OSHA will not permit employees to undergo initial fit testing if there is any hair growing between the skin and the respirator seal, and recommends being clean-shaven.) ¹⁰

Changing facial features pose an especially tough challenge to EH employees. Weight gain or loss, cosmetic surgery, dental headgear, and facial hair worn for aesthetic or religious purposes can all interfere with a proper respirator fit.¹¹ But asking an employee to get a new fit test as a result may require delicate conversations and even legal guidance in some cases as employees may feel embarrassed or discriminated against. 

Employee Health departments already track multiple safety metrics, including occupational health data and vaccine compliance. It’s easy to see how testing and tracking continued N95 respirator fit would disrupt an already hectic schedule. 

Staying Compliant With Respirator Fit Testing

Managing a respirator fit test program is a complex task, but there is software that can simplify some of the process. Employee Health software solutions can help EH departments rebuild or scale up their respirator fit testing programs by making it easier to schedule tests, send reminders to employees, and record all of the relevant fit test data. Turning to an employee portal can also help empower workers to track their own compliance and take care of tasks in a timely manner without prodding from overburdened EH departments. By making information gathering easier, healthcare facilities can stay compliant with software solutions that provide the most up-to-date testing and reporting requirements. 

If you’d like to learn more about how Net Health can make respirator fit testing easier on your EH department, click here to schedule a demo.

Note: Net Health makes no representations as to accuracy, completeness, correctness, suitability, or validity of any of the information presented herein. All information is provided on an as-is basis. It is the viewer’s responsibility to verify any and all information presented herein.

References:

¹ Occupational Safety and Health Administration (OSHA), “Respiratory Protection,” May 2, 2022.  
² Occupational Safety and Health Administration (OSHA), “Fit Testing Procedures (Mandatory),” August 4, 2004.
³ Occupational Safety and Health Administration (OSHA), “Temporary Enforcement Guidance – Healthcare Respiratory Protection Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak,” March 14, 2020.
⁴ Centers for Disease Control (CDC), “NIOSH-Approved Particulate Filtering Facepiece Respirators,” September 15, 2021.
⁵ 3M Center for Respiratory Protection, “Overview of the Fit Testing Processes,” Accessed May 1, 2022.
⁶ 3M Center for Respiratory Protection, “Quantitative Fit Testing of Respirators,” June 2021.
⁷ Occupational Safety and Health Administration (OSHA), “Small Entity Compliance Guide for the Respiratory Protection Standard,” 2011.
⁸ Occupational Safety and Health Administration (OSHA), “Temporary Enforcement Guidance – Healthcare Respiratory Protection Annual Fit-Testing for N95 Filtering Facepieces During the COVID-19 Outbreak,” March 14, 2020.
⁹ Occupational Safety and Health Administration (OSHA), “Additional Ambient Aerosol CNC Quantitative Fit Testing Protocols: Respiratory Protection Standard,” September 26, 2019.
¹⁰ Centers for Disease Control (CDC), “To Beard Or Not To Beard? That’s a Good Question!,” November 2, 2017.
¹¹ Journal of Occupational and Environmental Hygiene, “Temporal Changes In Filtering-Facepiece Respirator Fit,” 2016.