Infection Control Today - 03/2004: OSHA Applies General

OSHA Applies General Respiratory Protection Standards toHealthcare Setting

By Kelly M. Pyrek

In a dance of one step forward, two steps back, theOccupational Health and Safety Administration (OSHA) backed off from a proposedtuberculosis (TB) standard but announced in January it will apply its generalrespiratory protection standards to the healthcare environment. This seeming contradiction and the accompanying mandate ofannual fit-testing of respirators has caught the infection control communityoff guard, with clinicians scrambling to gather pertinent details. OSHA hasannounced a six-month grace period for implementing the new requirements; facilities are expected to be in compliance by July 1, 2004.

Jeff Weed, product manager for the PortaCount Universal FitTest System from TSI, says the fit-testing of respirators is justified. OSHA does have legitimate reasons to require fit testingand to require that it be done annually, he says. He points to the preamble to the OSHA respiratoryprotection standard 29CFR1910.134 published in the Jan. 8, 1998 Federal Register(63 FR 1223) that explains OSHAs reasoning:

Physiological changes that affect facepiece fit can occurgradually over time and are easily overlooked by observers, and by the usersthemselves. Individuals with poorly fitting respirators were oftendetected only through fit testing, and not by other methods such as observationof changes in facepiece fit, failure to pass a user seal check, or an employeereporting problems with the fit of the respirator. Retesting facepiece fitsolely on the basis of physical changes in individual respirator users would notbe a reliable substitute for fit testing on an annual basis.

Weed says, Examination of that document reveals that all ofthe arguments against annual fit testing that are currently being made wereraised and fully considered by OSHA back then. In fact, the annual fit testing requirement was specificallychallenged in court and upheld in 1999.

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