Archive for: Respiratory Protection

Two new protocols for respirator fit testing from OSHA

By: October 9th, 2019 Email This Post Print This Post

By Guy Burdick, EHS Daily Advisor

On September 26, OSHA added two new protocols for ensuring employees’ respirators fit properly. When employers are required under personal protective equipment regulations to provide respiratory protection, they also are required to ensure the respirators properly fit each employee.

The new protocols are variations of an existing OSHA-approved method, the ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol, often referred to as the “PortaCount® protocol.” The new protocols are:

  • The modified ambient aerosol CNC quantitative fit testing protocol for full-face piece and half-mask elastomeric respirators; and
  • Modified ambient aerosol CNC quantitative fit testing protocol for filtering face piece respirators.

The new protocols have fewer test exercises, shorter exercise duration, and a more streamlined sampling sequence than the existing ambient aerosol CNC quantitative fit testing protocol.

The protocols provide employers with alternatives to the four quantitative fit testing protocols already listed in the respiratory protection standard. The new protocols apply to employers in general industry, shipyard employment, and the construction industry.

Original, Modified Protocols

The original ambient aerosol CNC protocol uses a sample device installed on the respirator to quantitatively test the respirator’s fit. The probed respirator is used only for the fit test.

The PortaCount protocol employs a series of eight test exercises, performed in the following order: normal breathing, deep breathing, turning head side to side, moving head up and down, talking, grimacing, bending over, and then normal breathing again.

The modified ambient aerosol CNC protocol for full-face piece and half-mask elastomeric respirators differs from the original protocol as follows:

  • It includes only three of the eight original test exercises (bending over, head side to side, and head up and down).
  • It adds jogging in place as a new exercise.
  • It reduces the total test duration from 7.2 to 2.5 minutes.

The modified ambient aerosol CNC protocol for filtering face piece respirators differs from the original protocol as follows:

  • It includes only four of the eight original test exercises (bending over, talking, head side to side, and head up and down).
  • It reduces the total test duration from 7.2 to 2.5 minutes.

Employers, States, Consensus Standard

Although employers are not required to use the new protocols, the agency believes having alternative fit testing methods gives employers greater flexibility and can reduce the burdens of complying with the respiratory protection standard.

Because the protocols are part of an appendix to the respiratory protection standard, states administering their own workplace safety and health programs are not required to adopt them. However, OSHA strongly encouraged states to adopt the new protocols to provide employers additional compliance options.

The agency also said the new protocols are consistent with the industry consensus standard developed by the American National Standards Institute (ANSI) and American Industrial Hygiene Association (AIHA)—ANSI/AIHA Z88.10-2010, “Respirator Fit Testing Methods.” OSHA concluded the new protocols meet the evaluation criteria outlined in the consensus standard.

The final rule amending the respiratory protection standards is effective immediately.

Guy Burdick is a writer with EHS Daily Advisor, a BLR publication.

Is OSHA being sneaky?

By: June 4th, 2015 Email This Post Print This Post

Hi folks –

Boy, it’s fun to watch how sneaky OSHA can be. If you’ve been paying attention, you know that the agency has quietly passed changes to a few pretty important rules in the healthcare industry.

First, there was an upgrade to the Workplace Violence Prevention rule (3148), which basically is a rule that requires employers to have a plan in place. There was also a very well-done manual that went with it to help you out.

Then, in May, OSHA and NIOSH teamed up to provide a Respiratory Protection Toolkit for employers, which essentially is a warning that if you don’t already use respirators to help protect your workers against infections, you better start. And here’s the handy toolkit published to help you out:

I don’t doubt that these are great things. We all want a safer work environment. But what’s going on here? Well, in the opinion of one lawyer who I read in an online blog:

“The bottom line is that OSHA is coming. Accordingly, employers in the health care industry should act now to ensure that their employees are working in the safest possible conditions and that, when OSHA appears at their door, they can demonstrate their commitment to employee health and safety.”

Interestingly, the Joint Commission is taking note of these changes, and has issued their own recommendations right about the same time that OSHA is doing so.

I’d like to know what you think. Is OSHA about to get tough on the healthcare industry? Good luck getting them to say so.

The feeling out there is that OSHA doesn’t have enough inspectors, so they probably won’t inspect. Will that change? And will you do anything different in your job because of it?

Please drop me a line and let me know your opinions.


John Palmer

Take a lesson about chemicals from janitor’s death

By: July 9th, 2014 Email This Post Print This Post

We hear it every day like a broken record – wear your PPE and know what you are doing when you are working with hazardous chemicals in the workplace. Unfortunately, too many people don’t listen and they end up paying the ultimate price.

I’m reminded of this today as I read more about the janitor in an elementary school in Plymouth, Massachusetts who was apparently overcome and died from exposure from an as-yet unknown chemical on Monday morning.

If you’re just learning about this, 53-year-old Chester Flattery, the head custodian at Manomet Elementary School, was found dead by the school secretary at about 8 a.m.  That employee and 12 other people – many of them police officers, firefighters and other first responders who were exposed – had to also be taken to the hospital for treatment.

The investigation is still ongoing, but reports say Flattery had been at work for an hour before anyone else and that he may have been applying a floor sealant at the time of his death. School is not in session and there is a lot of maintenance work that goes into getting the building ready for next year.

Now, we all in workplace safety world know he was supposed to be wearing a respirator, eye protection, and other protective equipment. I have been a teacher in an elementary school, and I have seen these guys hard at work getting the school ready, even as I was getting my own classroom ready for students.

Most of the time, they are in regular street clothes as they go about their duties and I am willing to bet Flattery was no exception. As someone who had been working there since 2007, he was probably just doing what he always did – this time the fumes were too much for him and no one was there to help him until it was too late.

It almost happened to me. Back in college, I worked as a pool director at a country club in Connecticut, responsible for maintaining the proper chemical levels. One morning, I went into the supply closet looking for chlorine pellets, not knowing that one of my lifeguards hadn’t tightened the cover of the bucket properly the night before, allowing rain water to seep in. When I took the cover off, I got hit with a cloud of chlorine gas that knocked me off my feet and burned my throat. Happily, I was able to get to fresh air quickly and was fine. But no one was around and I was not wearing any kind of protection. I was lucky, and I never made the same mistake twice.

In the healthcare field, you can take a lesson from this tragedy. Don’t assume that just because you have done a job for a long time, you can ignore the rules. OSHA has bloodborne pathogens and hazardous chemical standards for a reason. If you are working with patients, wear your gloves, use your safety sharps, and lift safely.

If you are in a lab and work with chemicals, make sure you know the hazards of what you are working with and how to handle it properly, as well as any first aid information – it’s why OSHA says you must have SDS safety sheets on site. And always be sure someone is around, because it may save your life.

Checking podiatry clinics for bioaerosol exposures

By: February 29th, 2012 Email This Post Print This Post

Yes, there are occupational hazards for caregivers working on feet.

A study done by Irish researchers and appearing in the January 23 issue  Annals of Occupational Hygiene surveyed 250 podiatrist clinics to assess personal exposure knowledge and conducted tests in 15 podiatry clinics for concentrations of airborne bacteria, fungi, yeasts, and molds.

“Workplace Exposure to Bioaerosols in Podiatry Clinics” reports that 32% of care providers surveyed had a respiratory condition. Asthma was the most common condition reported.

Gloves (73.3%) and respiratory protective equipment (34.6%) were the most common personal protective equipment used during patient treatments.

“Refresher health and safety training focusing on health and safety hazards inherent in podiatry work and practical control measures is warranted,” the study concluded.

OSHA adds free online respiratory protection videos

By: February 2nd, 2012 Email This Post Print This Post

OSHA announced its new respiratory protection video web page, January 31.

The OSHA Respiratory Protection Videos web page includes nine short videos that cover key compliance points for the Respiratory Protection Standard, 1910.134. Topics include:

  1. Respiratory Protection in General Industry
  2. Respiratory Protection in Construction
  3. Respirator Types
  4. Respirator Fit Testing
  5. Maintenance and Care of Respirators
  6. Medical Evaluations for Workers Who Use Respirators
  7. Respiratory Protection Training Requirements
  8. Voluntary Use of Respirators
  9. Counterfeit and Altered Respirators: The Importance of NIOSH Certification

The free videos, while not specific to healthcare settings, allow safety officers and trainers to access sections of the  standard that apply to general industry, including healthcare.

Spanish language videos are also available on the same page.

If you don’t need to access only a certain section of the standard for compliance, try the OSHA video that is specific for healthcare workers that the agency posted a year ago. It is 33 minutes in length and does a good a job in covering all the elements of the standard listed above.

TB screening, OSHA, and applicable chapter and verse

By: January 19th, 2012 Email This Post Print This Post

Steve MacArthur, safety consultant for The Greeley Company, is taking on all comers lately, especially  OSHA compliance. And as Father Lonergan from The Quiet Man would say: “What do you expect?”

Last week MacArthur tackled emergency eyewash stations with the seductive headline: “In your eyes – the light, the heat … the chemicals?” This week: The intricacies of TB screening for contract staff and OSHA compliance.

Here is the post, courtesy of Mac’s Safety Space:

From the muddy banks of compliance

Let’s break from form a little bit and start with a question:

How often are you (and by you, I mean your organization) screening contracted staff, including physicians, physician assistants, nurse practitioners, etc.?

A recent TJC survey resulted in a finding under the HR standards because the process was being administered on a biannual cycle. The finding vaguely referenced OSHA guidelines in identifying this deficiency, but the specific regulatory reference point was not provided (though apparently a call to Chicago validated that this was the case). Now, anyone who’s worked with me in real time knows that I have an exhaustive (and, at times, exhausting) curiosity about such matters. The deficiency “concepts” are usually sourced back to a “they;” as in, “they told me I had to do this” “they told me I had to that.” I am always, always, always curious as to who this “they” might be and whether “they” were good enough to provide the applicable chapter and verse. The answer, more often than not, is “no.” Perhaps someday we’ll discuss the whimsical nature of the” Authority Having Jurisdiction” (AHJ) concept, but we’ll save that for another day.

At any rate, I did a little bit of digging around to try and locate a regulatory source on this and in this instance, the source exists; however, the standard is not quite as mandatory as one might first presume (If you’re thinking that this is going to somehow wrap around another risk assessment conversation, you are not far from wrong). So, a wee bit of history:

Back in 1994, the CDC issued their Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Facilities, ( which, among other things, advises a risk-based approach to screening (Appendix C speaks to the screening requirements for all healthcare workers, regardless of who they work for. The guidance would be to include contract folks. The risk level is determined via a risk assessment (Appendix B of the Guidelines is a good start for that). So, for a medium exposure risk environment, CDC recommends annual screening, but for a low exposure risk environment, they recommend screening at time of hire, with no further screening required (unless your exposure risk increases, which should be part of the annual infection control risk assessment).

But, in 1996, OSHA issued a directive that indicates annual screening as the minimum requirement , even for low-risk exposure risks, and even while referencing the CDC guidance: ( with medium risk folks having semi-annual screening and high-risk folks being screened on a quarterly basis. So, friends, how are you managing folks in your environment, particularly the aforementioned contracted staff? Do you own them or is it the responsibility of their contracted employer? Does this stuff give you a headache when you think about it too much? It sure gives me one…occupational hazard, I guess. At any rate, it’s certainly worth checking to see whether a risk assessment for TB exposure has been conducted. The OSHA guidance document clearly indicates that if you haven’t, it’s the responsibility of the surveyor to conduct one for you, and I don’t know that I’d be really keen on having that happen.

I especially liked the they references. Do you encounter the vague but seemingly ominpotent and omniscient they reference? If so, or for other observations, post a comment below.

OSHA posts resource for respirator use in small businesses

By: October 20th, 2011 Email This Post Print This Post

A new publication will help small businesses to better understand respiratory protection regulation, according to an October 17 OSHA announcement.

Small Entity Compliance Guide for Respiratory Protection Standard provides a comprehensive step-by-step guide, complete with checklists and commonly asked questions, that will aid both employers and workers in small businesses, including small healthcare facilities such as medical and dental practices

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Weekly poll: Healthcare workers and the “Contagion” buzz

By: September 19th, 2011 Email This Post Print This Post

“Contagion,” the film about a new virus that sweeps over the world infecting and killing people in just days, has attracted the attention of both moviegoers (number 1 and 2 in box office sales the first two weeks of release) and the CDC and its infectious disease experts, who are the heroes of the film. The CDC’s website devotes a number of pages to responding to “Contagion,” distilling fact from fiction in the film, and even providing Twitter chat opportunities to connect with the type of CDC experts portrayed in the film.

Does the “Contagion” Hollywood buzz help or hinder the role of healthcare workers in responding to a future pandemic threat? Take our OSHA Healthcare Advisor Weekly Poll and let us know.

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Ask the expert: N95s and beards

By: September 15th, 2011 Email This Post Print This Post

Q: Must a worker be clean shaven to wear an N95 respirator?

A: Yes, the OSHA respiratory protection standard, 1910.134, requires workers to be clean shaven when wearing a tight-fitting, face piece–type respirator such as the N95.

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Ask the expert: Who pays when a TB skin test isn’t possible

By: July 21st, 2011 Email This Post Print This Post

Q: What is the responsibility for a company to pay for a chest x-ray in place of a PPD for TB screening? A new hire cannot have a PPD, and  with our low risk level, an x-ray is much more expensive than a skin test.

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Ask the expert: Frequency of TB skin tests

By: July 11th, 2011 Email This Post Print This Post

Q: How often should employees in healthcare settings have a PPD after the baseline when they come into our employment ranks?

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Using duct tape as an isolation precaution tool

By: June 28th, 2011 Email This Post Print This Post

Don’t ever underestimate the utility of duct tape—the stuff that literally holds the word together for the do-it-yourself types.

Now it seems that duct tape—the red color variety—can play a role in maintaining infection control policies, facilitate better communication between care providers and patients, and save nursing staff time.

Here are the details from HCPro’s HealthLeaders Media group, by Cheryl Clark, June 27:

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