Standard Interpretations - Table of Contents
• Standard Number: 1910.134(f)(2); 1910.134(e)(1); 1910.134(g)(1)(iii)

June 12, 2002

Mr. Ray Piantanida,
Avon Risk Services, Inc.
1901 Main Street., Suite 300
Irvine, California 92614

Dear Mr. Piantanida:

Thank you for your April 22 letter to the Occupational Safety and Health Administration (OSHA). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. You requested clarification on several respiratory protection issues.

Question 1: What are the fit testing requirements for filtering facepieces?

Response: The respiratory protection standard, 29 CFR 1910.134, under paragraph (f)(2), requires fit testing for all employees using tight fitting respirators including filtering facepiece respirator. The fit test must be performed before the respirator is used in the workplace and must be repeated at least annually and whenever a different respirator facepiece is used or a change in the employee's physical condition could affect the respirator fit.

The user seal check is a separate requirement under paragraph (g)(1)(iii) and must be performed each time the employee dons the respirator. Employers must adhere to the recommendations of the respirator's manufacturer; different manufacturers recommend different procedures. Also, as you may know, if an employer requires employees to use filtering facepiece respirators, the employer must establish and implement a written respiratory protection program with worksite-specific procedures.

Question 2: With the lower level of breathing restrictions of a filtering facepiece and nuisance dust environment below the TLV, what are the initial and/or annual medical monitoring requirements for employees using the filtering facepieces?

Response: Before an employer may fit test any employee, paragraph (e)(1) requires a medical evaluation to determine whether each