November 16, 1998

Dr. Charles E. Truthan, D.O.
Diplomate of the American Osteopathic Board
of Family Physicians
4075 Rum Run Avenue, S.E.
Grand Rapids, MI 49546

Dear Dr. Truthan:

This is in response to your letter received July 22, addressed to the Lansing Area Office of the Occupational Safety and Health Administration (OSHA). You requested clarification of the fit testing and storage requirements of the new Respiratory Protection Standard, 29 CFR 1910.134. We apologize for the long delay of this response.

In your letter you ask for a statement of clarification regarding when to use either quantitative and qualitative fit testing. Qualitative Fit-Testing (QLFT) may be used to fit test negative pressure air-purifying respirators, if they will only be used in atmospheres less than ten times the PEL, since existing evidence only validates the QLFT protocols listed in Appendix A to identify respirators that achieve a fit factor of 100. For greater concentrations, quantitative fit-testing (QNFT) must be used. When quantitative fit-testing is used, all full-facepiece respirators must meet or exceed a fit factor of 500, while quarter- and half-mask respirators must meet or exceed 100. For all positive pressure, atmosphere-supplying respirators, either qualitative or quantitative fit testing may be used. While atmosphere-supplying respirators are fit-tested in the negative pressure mode, these respirators are most often used as positive pressure respirators in the workplace. Positive pressure atmosphere-supplying respirators that pass the QLFT or QNFT fit test may be used at the higher protection factors assigned these respirators. OSHA's policies and procedures for compliance with the Respiratory Protection Standard is published in the compliance instruction, Inspection Procedures for the Respiratory Protection Standard, CPL 2-0.120. This OSHA Instruction is available on the Internet at the OSHA Home Page at http://www.osha.gov. In addition, on August 3, 1998, OSHA published Questions and Answers on the Respiratory Protection Standard. This 79 page document contains guidance regarding the Respiratory Protection Std. This can be found on the Internet at the OSHA Home Page as well.

The specially designed seat backs that you have described in your letter would be acceptable to store and protect SCBA's on the firetruck. As you have described it, the SCBA is enclosed in a storage compartment that would prevent any damage to the equipment. Your letter requested an exemption for providing a covering for SCBAs on fire trucks as long as there is a water and dust proof cap over the regulator opening. OSHA believes that an exemption from the required cover cannot be permitted because it does not provide adequate protection for the entire SCBA. It is important that the entire SCBA be covered particularly in a fire truck. Debris, soot, dust, salt, or water must not be allowed to enter the facepiece of the respirator. Should material get into the facepiece, the material could be blown into the employee's eyes, mouth, or nose. Further, debris could affect the seal of the respirator. This material could also cause corrosion of the harness, straps, and hoses. You mentioned your concern for trip hazards which could be caused by the cover. This hazard would be eliminated if the cover were affixed to the fire truck. If designed well, the removal of a cover before boarding the fire truck would result in a negligible time delay.

The Michigan Department of Consumer and Industry Services is operating its own occupational safety and health program under a plan approved and closely monitored by Federal OSHA. The program is primarily responsible for enforcement of the OSHA Respiratory Protection Standard in Michigan. The State of Michigan must adopt standards at least as strict as federal OSHA. The state enforces these standards for the private sector and city, county, and state employees. If you wish to pursue this matter further with the State of Michigan, you may contact:

Should you require any additional information on this matter, please, feel free to contact OSHA's Office of Health Compliance Assistance at (202) 693-2190.

Sincerely,

Richard E. Fairfax
Acting Director
Directorate of Compliance Programs