OSHA Releases New Guidance on Respiratory Protection & N95/N99/N100 Mask Shortages
As requested by the federal government, many construction and industrial companies have donated their PPE to front-line medical workers to aid in the fight against COVID-19.
At the same time, construction and industrial manufacturing companies are still considered essential businesses and are operational. These businesses still have the duty to protect employees from known hazards. OSHA has released new guidance on the permitted use and reuse of disposable masks and possible alternatives for respiratory protection in the workplace.
Respiratory Protection Program
All employers required or voluntarily using respiratory protection must continue to manage their RPPS in accordance with OSHA standards. This includes updating your RPP to reflect the changes in mask usage during this shortage. Employers should try to minimize the requirements of masks by utilizing wet methods or local exhaust systems or moving operations outdoors. If respiratory protection must be used, alternative classes providing equal or greater protection compared to an N95 FFR are permissible. When these alternatives are not available, or they create additional hazards, employers may consider extended or reuse of N95s, or using N95s that are expired.
Extended use or reuse of N95s: In the event extended use or reuse of N95 FFRs becomes necessary, the same worker is permitted to extend use of or reuse the respirator, as long as the respirator maintains its structural and functional integrity and the filter material is not physically damaged, soiled, or contaminated (e.g., with blood, oil, paint). Employers must address in their written RPPs the circumstances under which a disposable respirator will be considered contaminated and not available for extended use or reuse. Extended use is preferred over reuse due to contact transmission risk associated with donning/doffing during reuse. When respirators are being re-used, employers should pay particular attention to workers’ proper storage of the FFRs in between periods of reuse.
Users should perform a user seal check each time they don a respirator and should not use a respirator on which they cannot perform a successful user seal check. See 29 CFR § 1910.134, Appendix B-1, User Seal Check Procedures.
Employers should train workers to understand that if the structural and functional integrity of any part of the respirator is compromised, it should be discarded, and that if a successful user seal check cannot be performed, another respirator should be tried to achieve a successful user seal check.
If reuse of respirators is necessary, an appropriate sequence for donning/doffing procedures should be used to prevent contamination, and training needs to address appropriate donning/doffing procedures. See www.cdc.gov/niosh/npptl/pdfs/PPE-Sequence-508.pdf.
Use of expired N95s: In the event that N95s are not available and the employer has shown a good faith effort to acquire the respirators or to use alternative options, as outlined below, CSHOs should exercise enforcement discretion for the use of N95 FFRs beyond the manufacturer’s recommended shelf life, including surgical N95s.
Employers may use only previously NIOSH-certified expired N95 FFRs found at www.cdc.gov/coronavirus/2019-ncov/release-stockpiled-N95.html. Workers should be notified that they are using expired N95s.
Purchasers and users of personal protective equipment should not co-mingle products that are past their manufacturer’s recommended shelf life (i.e., expired) with items that are within their shelf life.
Employers should visually inspect, or ensure that workers visually inspect, the N95 FFRs to determine if the structural and functional integrity of the respirator has been compromised. Over time, components such as the straps, nose bridge, and nose foam material may degrade, which can affect the quality of the fit and seal.
Where an employer has expired N95s available from their own stored cache (i.e., not from the U.S. Strategic National Stockpile), the employer should seek assistance from the respirator manufacturer or independent lab regarding testing of those stored respirators prior to use.
Healthcare employers only:
Expired N95s generally must not be used when HCP:
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).
In accordance with CDC guidance for optimizing the supply of respirators, employers should prioritize the use of N95 respirators by activity type. When HCP perform or are present for aerosol-generating procedures or procedures where respiratory secretions are likely to be poorly controlled, use respirators (including N95 FFRs; other FFRs; non-disposable, elastomeric respirators; and PAPRs) that are still within their manufacturer’s recommended shelf life, if available, before using respirators that are beyond their manufacturer’s recommended shelf life. See www.cdc.gov/coronavirus/2019-ncov/hcp/respirators-strategy/contingency-capacity-strategies.html. The CDC guidance also addresses scenarios in which other crisis standards of care may need to be considered, but this enforcement guidance is not intended to cover those scenarios.
Please contact us with any questions on how to update your Respiratory Protection Program, or if you need assistance procuring alternative respiratory protection.