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Respirator Seal Check Requirements Confirmed
By Jeffery C. Camplin, CSP, CPEA
OSHA offers clarification on contradiction in OSHA standard and guidance document.
The October 2005 edition of Compliance Magazine contained the article “Respirator Use, Finding the Right Fit” on page 17. One reader responded to a statement in the article that said user seal checks require the performance of both negative and positive seal check.
The Question
The reader stated that it was his understanding along with an OSHA official that either a negative or positive seal check is required by the agency's respiratory protection standard.
A review of the mandatory Appendix B to the OSHA respiratory protection standard, 29 CFR Part 1910.134, reveals the following:
The individual who uses a tight-fitting respirator is to perform a user seal check to ensure that an adequate seal is achieved each time the respirator is put on. Either the positive and negative pressure checks listed in this appendix, or the respirator manufacturer's recommended user seal check method shall be used. User seal checks are not substitutes for qualitative or quantitative fit tests.
It is clear from the wording of this mandatory section that both “positive and negative pressure checks” are required. However, the OSHA document “Small Entity Compliance Guide for the Respiratory Protection Standard” stated on page g-3 that “to conduct a user seal check, the worker performs a negative or positive pressure fit check.” This appears to contradict the mandatory Appendix B language found in OSHA's respiratory protection standard. Compliance Magazine editorial staff contacted OSHA for a clarification on whether one or both user seal check methods are required for compliance with OSHA's respiratory protection standard.
OSHA's Clarification
The following response from OSHA clarifies the agency's requirements:
With most respirators, it is possible to block off both the inhalation and exhalation valves, allowing both negative pressure and positive pressure user seal checks to be performed. However, some elastomeric respirators have been designed with plastic covers over their exhalation valves that prevent the valves from being blocked off during a user seal check. The user can block the inhalation valves by blocking off the filter, allowing the performance of a negative pressure user seal check; but it is not practical for the user to block the exhalation valve to allow a positive pressure user seal check.
In this case, only one type of user seal check could be performed. Where it is practical for the user to do both a negative and a positive user seal check, the standard expects both to be performed. When it is practical only to do one type of user seal check, then the wearer must do the one user seal check that can be performed.
CM
OSHA Categorizes Disposable Dust Masks as APRs
OSHA considers NIOSH-certified single-use disposable dust masks to be air-purifying respirators (APRs). The Respiratory Protection Standard's definition at 29 CFR Part 1910.134(b) refers to these dust masks as “filtering face pieces” and defines them as negative pressure particulate respirators with a filter that is an integral part of the face piece or with the entire face piece composed of the filter medium. An example would be a NIOSH-approved N95 dust mask.
In the requirements for a respiratory protection program stated in 1910.134(c)(2)(ii), OSHA states that employers are not required to include in a written respiratory protection program “those employees whose only use of respirators involves the voluntary use of filtering face pieces (dust masks).”
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