Clarification on Voluntary Use of N95 Respirators

During last week’s virtual town hall a question was asked regarding the requirement for fit testing for N95 respirators. If an employer makes a filtering facepiece respirator, e.g. N95, available to employees on a voluntary basis, initial fit testing is not required as long as use of the respirator does not create a hazard:

  • Due to misuse of the respirator such as wearing a dirty respirator which leads to dermatitis.
  • Due to hazards or conditions in the workplace.
  • Hazard to the individual employee based on medical conditions such as asthma.

Additionally, the employer must also provide the respirator users with the information contained in Appendix D of the standard ("Information for Employees Using Respirators When Not Required Under the Standard".)

If an employer makes the filtering facepiece respirator mandatory, for example for all employees working in retail area, fit testing on the N95 respirator would be required to those employees. In addition to the fit testing, the employer would also fall under the full respiratory protection standard. An excellent resource would be the OSHA Small Entity Compliance Guide for the Respiratory Protection Standard.  See pages 14 & 15 for details on voluntary use.

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