OSHA Instruction CPL 2-2.29 October 27, 1980 Office of Compliance Programming

Subject: 29 CFR 1910.134(e)(5)--Respirator Fit-Testing

A. Purpose. This instruction provides guidance regarding enforcement policy for the respirator fit-testing requirement under by 29 CFR 1910.134(e)(5).

B. Scope. This instruction applies OSHA-wide.

C. Action. OSHA Regional Administrators and Area Directors shall assure that violations resulting from use of improper fit-testing procedures are cited as set forth in F. of this instruction.

D. Federal Program Change. This instruction describes a Federal program change which affects State programs. Each Regional Administrator shall:

1. Ensure that this change is forwarded to each State designee.

2. Explain the technical content of the change to the State designee as requested.

3. Ensure that State designees are asked to acknowledge receipt of this Federal program change in writing, within 30 days of notification, to the Regional Administrator. This acknowledgment should include a description either of the State's plan to implement the change or the reasons why the change should not apply to that State.

4. Review policies, instructions and guidelines issued by the State to determine that this change has been communicated to State program personnel. Routine monitoring activities (accompanied inspections and case file reviews) shall also be used to determine if this change has been implemented in actual performance.

E. Background.

1. 29 CFR 1910.34(e)(5) states, in part: "Training shall provide the men an opportunity to handle the respirator, have it fitted properly, test its face-piece-to-face seal, wear it in normal air for a long familiarity period, and, finally, to wear it in a test atmosphere."

2. Because of a request for compliance procedures for this provision, litigation activities, and other considerations, it is necessary to clearly establish enforcement policy on the respirator fit-testing issue.

F. Enforcement Policy. When issuing citations for violations of 29 CFR 1910.134(e)(5), use the following guidelines:

1. Respirators must be fit-tested.

2. A "test atmosphere" must be applied to assess the quality of fit.

3. The fit-test must be applied to each and every employee required to wear a respirator.

4. The fit-testing requirement applies to all negative pressure respirators including SINGLE-USE RESPIRATORS.

5. The "test atmosphere" must be applied using recognized qualitative fit-testing procedures utilizing iso-amyl acetate, irritant smoke, etc.; or quantitative fit testing using DOP, NaCl, etc.

6. Items F.1.-5. above shall be part of the training required in 29 CFR 1910.134(b)(3), "The user shall be instructed and trained in the proper use of respirators and their limitations."

7. Cite "serious" when F.1.-5. above, is not implemented, if the toxic substance is classified as "serious" in the Industrial Hygiene Field Operations Manual (IHFOM), Chapter II.

G. Inquiries. Inquiries concerning this instruction may be addressed to the U.S. Department of Labor, Occupational Safety and Health Administration, Division of Occupational Health Programming, Washington, D.C. 20210, Telephone: 202-523-8033.

Bruce Hillenbrand Acting Director, Federal Compliance and State Programs

DISTRIBUTION: National, Regional and Area Offices All Compliance Officers State Designees NIOSH Regional Program Directors