What dentists need to know about OSHA’s respiratory protection program

October 10, 2020

As more of dentists are ‘getting back to work’, more questions arise regarding guidance on OSHA’s respiratory protection program. Specifically, what is required now — fit test, medical evaluation and proper training — to ensure offices are deemed compliant.

During these unprecedented times, OSHA recommends all employers make a ‘good-faith’ effort to provide and ensure workers use the most appropriate respiratory protection available for the hazards against which workers need to be protected. This should be accomplished through implementing the hierarchy of controls in an effort first to eliminate or substitute out workplace hazards, then using engineering controls, administrative controls, and safe work practices to prevent worker exposures to respiratory hazards.

OSHA classifies NIOSH-approved (National Institute for Occupational Safety and Health) N95 masks as filtering facepiece respirators (FFRs). If a N95 respirator is required for use in a dental setting, then the OSHA Respiratory Protection Standard (29 CFR 1910.134) would apply.

OSHA’s Respiratory Protection Standard requires that each employer has a written program which includes:

• Medical Surveillance/Evaluation to determine if the employee is fit to wear a respirator.

• Training in the proper use (donning and removing), limitations, and storage of the respirator selected for use.

• Fit-Test to determine that the respirator selected for use fits properly.

When is a Medical Evaluation required?

Prior to wearing a respirator, re-evaluation needed if:

• Medical signs or symptoms develop which affect one’s ability to wear a respirator.

• A change in workplace conditions creates a substantial increase in the physiological burden of the respirator user.

• Recommended by health care professional, supervisor or program administrator.

When are a Fit Test and Training required?

· Fit testing is required prior to wearing a respirator and annually thereafter.

• Fit testing is also required if changes in workplace/activities or type of respirator affect fit (Facial/dental changes or body weight change of more than 10-20 pounds).

• Initial and annual training is required. In addition, training is to be repeated if user does not demonstrate required understanding or skill to wear a respirator.
• Additional fit testing would be required if a new model and/or size were being used. Only the model and size of respirator fit tested with should be worn.

More about respirator Fit-Test process

• Fit test participants cannot have facial hair or stubble. If they normally have facial hair, they will need to be clean shaven on the day of the fit test and anytime they wear a respirator.

• Fit test participants should refrain from eating, drinking, chewing gum or smoking 15 minutes prior to the fit testing session. Doing these things can affect the fit test process.

Note: OSHA has relaxed the annual (not initial) fit testing requirements during the pandemic.

Fit-testing with alternative filtering facepiece respirators (FFRs) produced in other countries (i.e. KN95 respirators)

OSHA has provided guidance on the use of FFRs produced in other countries (OSHA April 3, 2020 News Release) during the pandemic.

Fit Testing Required:

• Before initial use of alternative FFRs.

• Alternative FFR must be tightfitting with elastic head band(ear loop masks do not qualify as tight fitting).

Fit Testing Not Required:

• If the alternative FFR has earloops or is not tight fitting.

Documentation and Record Keeping.

• A written copy of a respiratory protection plan shall be kept in the Program Administrator’s office and made available to all employees who wish to review it.

• The respiratory protection plan is required to include worksite-specific procedures and elements for required respirator use.

• Records pertaining to training, fit-testing and medical surveillance/evaluation shall be maintained by the Program Administrator.


Examples of sample respiratory plans are below:

https://multimedia.3m.com/mws/media/567574O/3m-administrative-respiratory-protection-program.pdf https://www.health.state.mn.us/facilities/patientsafety/infectioncontrol/rpp/clintemplate/index.html

Additional resources: