OSHA Approves New Quantitative Fit Testing Protocols
Pursuant to 29 C.F.R. § 1910.134(f) employees are required to be fit tested prior to wearing tight-fitting respirators and the fit test administered must be using an OSHA-accepted fit test protocol. Appendix A to § 1910.134 outlines the procedures employers are required to use for fit testing and apply to all OSHA-accepted fit test methods, both Qualitative fit test (QLFT) and Quantitative fit test (QNFT).
Under Appendix A, Part II for § 1910.134, interested parties are able to submit an application to OSHA for approval of a new fit test protocol. There are currently four available fit testing protocols: Generated Aerosol Quantitative Fit Testing Protocol, Ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol (PortaCount), Controlled negative pressure (CNP) quantitative fit testing protocol and Controlled negative pressure (CNP) REDON quantitative fit testing protocol.
In 2014, OSHA received an application for new fit test protocols from TSI Incorporated (TSI). TSI submitted three fit test protocols: “Fast-Full” method for elastomeric full-facepiece respirators, “Fast-Half” method for elastomeric half-mask respirators and “Fast-FFR” method for filtering facepiece respirators. The three proposed new fit test protocols were modified and abbreviated versions of the original ambient aerosol CNC protocol. In October 2016, OSHA issued a proposed notice of rulemaking to add the new protocols and invited public comments.
On September 26, 2019, OSHA issued a final rule approving the new fit testing protocols to be added to Appendix A. The first is the modified ambient aerosol condensation nuclei counter (CNC) quantitative fit testing protocol for full-facepiece and half-mask elastomeric respirators, the “Fast-Half” and “Fast-Full.” The second new protocol is the modified ambient aerosol CNC quantitative fit testing protocol for filtering facepiece respirators, “Fast-FFR.”
According to OSHA, the major differences between the proposed Fast-Full and Fast-Half methods and the OSHA-approved PortaCount protocol are that the Fast-Full includes only 3 of the 7 current test exercises (i.e. bending, head side-to-side, and head up-and-down) plus one new exercised (i.e., jogging-in-place). According to TSI, the Fast-Full method reduces each exercise duration from 60 seconds to 30 seconds, which results in a total test duration of 2.5 minutes rather than 7.2 minutes. Similarly, the Fast-FFR method includes 4 of the current test exercises and reduces total exercise time from 7.2 minutes to 2.5 minutes.
These submitted fit test methods were evaluated using ANSI standards and met the required acceptance criteria for test sensitivity, predictive value of a pass, predictive value of a fail, test specificity and kappa statistic. “OSHA determined that the new protocols met the sensitivity, specificity, predictive value, and other criteria outlined in the ANSI annex and will, therefore, provide employees with protections comparable to protections afforded to them by the reference method, which consisted of the standard OSHA exercises listed in Section 1.A. 14 of appendix A of the Respiratory Protection Standard, minus the grimace exercise, in the same order as described in the standard….These are the same test exercises, minus the grimace exercise, that are utilized for both the CNC and CNP protocols.”
These new protocols will serve as alternatives to the four existing quantitative fit testing protocols in Appendix A. OSHA believes that these new protocols will “maintain safety and health protections for workers while providing additional flexibility and reducing compliance burdens.”
The new rule went into effect on September 26, 2019.