October 18, 2004

Mr. Kevin Cassidy
Entergy
17265 River Rd.
Mail Unit W-EEC-650
Killona, LA 70066-2093

Dear Mr. Cassidy:

Thank you for your March 23, 2004 letter to the Occupational Safety and Health Administration (OSHA) regarding the requirements of the Respiratory Protection standard, 29 CFR 1910.134. Specifically, you ask about the requirements for fit testing employees before fire brigade training exercises. 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.

In your letter you state that your facility provides annual refresher training for fire brigade members to practice their skills and fire fighting techniques. For training purposes, they are provided SCBAs to wear during the exercises. Frequently, the SCBAs used are not the same as those on which the trainees had been fit-tested. In your letter, you ask if these trainees need to be fit-tested with the facility's SCBAs.

It would be the responsibility of the trainees' employers to ensure their employees are protected from any hazardous atmospheres. This includes fit-testing with any respirator being used to enter any hazardous atmosphere. The trainee's employers are not relieved of their responsibility when the trainees are working at a remote training facility. However, in our telephone conversation, you clarified that the SCBAs are being worn solely for training purposes and that during the training, the trainees are never actually exposed to a hazardous atmosphere. Indeed, the instructors who observe the exercises do not wear any respiratory protection at all. In the situation you describe, there appears to be no hazardous atmosphere from which the trainees need to be protected. Therefore, fit-testing would not be required for these respirators in these particular circumstances.

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 http://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