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 employee required to wear a respirator is physically able to wear a respirator and perform the work. This evaluation can be a medical examination or an evaluation of employee responses to the OSHA Respirator Medical Evaluation Questionnaire located in Appendix C of the Respiratory Protection Standard. Either method must be performed by a physician or other licensed healthcare professional.

A medical examination may be necessary whenever the employee gives a positive response to any of questions 1 through 8 in Appendix C, Part A, Section 2. If an employer chooses to provide a medical examination, the use of the Respiratory Medical Evaluation Questionnaire is optional. There are no annual medical monitoring requirements.

Please note that on August 3, 1998, OSHA published Questions and Answers on the Respiratory Protection Standard; the document is available on our website at www.osha.gov. You may find the section on fit testing and medial evaluations to be particularly helpful.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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 www.osha.gov. If you have any further questions, please feel free to contact the [Office of Health Enforcement] at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
[Directorate of Enforcement Programs]