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
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
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.
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
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
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,
Bruce Hillenbrand Acting Director, Federal Compliance and State Programs
DISTRIBUTION: National, Regional and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors