OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

Aug 27, 1999

Frank G. Duncan, Jr.
108 Randall Dr.
Slidell, LA 70458-1327

Dear Mr. Duncan;

Thank you for your letter of July 1, 1999 regarding the requirements for fit testing respirators under the revised Respiratory Protection Standard, 29 CFR 1910.134. You asked several questions about Appendix A of the standard.

Question 1: Is the use of a device that allows the quick determination of the correct size respirator precluded by the mandates of Appendix A? You add that other sizes and makes are available if the first, as determined by the device, is uncomfortable to the wearer.

Answer: The object of the respirator selection paragraph is the selection of a respirator that fits comfortably and will pass a fit test. The use of any device that aids in this process is permitted.

Question 2: Regarding the Saccharin Solution Aerosol Protocol, are fewer than ten squeezes allowable for Step 7, if the test subject can taste the saccharin sooner?

Answer: Step 7 determines the concentration at which the fit-test subject tastes the saccharin. The procedures in Steps 7 through 9 are meant to generate an even concentration within the test enclosure. If fewer than ten squeezes elicits a response, then no more squeezes are required (but are recorded as ten). However, contrary to your suggestion, the nebulizer must not be directed toward the nose and mouth; this defeats the purpose of these paragraphs, and a sensitivity concentration would not be determined. The nozzle must be directed away from the nose and mouth as directed in Step 4. This same precaution also must be observed during the fit testing procedure.

Question 3: Would OSHA consider an employer to be in violation of the standard if the nebulizer were directed toward the nose and mouth during this procedure?

Answer: Yes, OSHA would consider this modification of the procedure to be a violation.

Question 4: Does this fit test section require the written documentation of the number of squeezes required for the sensitivity test?

Answer: Step 10 of the Taste Threshold Screening requires the fit test operator to take note of the number of squeezes required to elicit a response. The operator must know and remember this number in order to complete the actual fit test portion of the appendix. Step 7 of the fit test procedure requires administering the same number of squeezes of fit test solution and Step 9 requires replenishing every 30 seconds with half the number of squeezes. The recordkeeping requirements for fit testing records are detailed in paragraph (m)(2)(i) of the respiratory protection standard. Subparagraph (E) under this paragraph requires the Pass/Fail results for Qualitative Fit Tests to be included in the record. The standard does not require you to record the actual number of squeezes on the fit test record, however this number may be helpful for the fit test operator when performing fit testing in following years.

Thank you for your interest in employee safety and health. We hope this provides the clarification you were seeking. If you have any further questions, you may wish to consult our website at http://www.osha.gov. Also, please feel free to contact the Office of Health Compliance Assistance at 202-693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs