Question: My organization is experiencing a supply shortage of N95 filtering facepiece respirators. What alternatives are available if N95s are required to protect my employees?

Answer:

In light of a Presidential Memorandum on making general-use respirators available for healthcare workers during the COVID-19 pandemic, OSHA has issued temporary enforcement guidance for the Respiratory Protection standard (29 CFR 1910.134) for:

• Required annual fit-testing.
• Supply shortages of disposable N95 filtering facepiece respirators.
• Use of respiratory protection equipment certified under standards of other countries.
• Decontamination of filtering facepiece respirators in healthcare.

OSHA enforcement guidance describes additional measures employers can take to ensure workers have appropriate respiratory protection during the COVID-19 pandemic.

Although OSHA's enforcement guidance describes equipment prioritization that includes surgical masks as potential considerations in some circumstances when respirators are not available, employers must still comply with the provisions of any standards that apply to the types of exposures their workers may face. For example, the permissible exposure limits of all substance-specific standards, such as asbestos and silica, remain in place, and surgical masks are not an acceptable means of protection when respirators would otherwise be required (e.g., when engineering, administrative, and work practice controls do not sufficiently control exposures).

If respirators are needed but not available (including as described in the OSHA enforcement guidance noted above), and hazards cannot otherwise be adequately controlled through other elements of the hierarchy of controls (i.e., elimination, substitution, engineering controls, administrative controls, and/or safe work practices), avoid worker exposure to the hazard. Whenever a hazard presents an imminent danger, and in additional situations whenever feasible, the task should be delayed until feasible control measures are available to prevent exposures or reduce them to acceptable levels (i.e., at or below applicable OSHA permissible exposure limits).

The CDC/National Institute for Occupational Safety and Health, National Personal Protective Technology Laboratory (NPPTL), provides additional information on SARS-CoV-2, the virus that causes COVID-19, and PPE.