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A APPENDIXPPENDIX G

MEMORANDUM FOR: REGIONAL ADMINISTRATORS

FROM: JOHN B. MILES, JR., DIRECTOR
DIRECTORATE OF COMPLIANCE PROGRAMS

SUBJECT: RESPIRATORY FIT TESTING AND FIT CHECKING PROCEDURES

This memorandum replaces the February 26 memorandum on the same subject. As you are
aware, OSHA and NIOSH during the last year have been involved in a number respirator
related issues. OSHA is in the process of issuing a final respiratory protection standard that
revises 29 CFR 1910.134,* while NIOSH issued new certification guidelines (42 CFR Part 84) last
summer for particulate respirators. The new NIOSH certification procedures directly affected
our requirements for respiratory protection for exposure to tuberculosis and particulates. The
new NIOSH certification procedures coupled with OSHA’s proposed respiratory protection
standard has generated numerous questions to the Office of Health Compliance Assistance.
Respirator related questions have centered around OSHA requirements for fit-testing, fit
checking, and reuse of the new respirators certified under 42 CFR Part 84. The most commonly
asked questions include:

1. What does OSHA expect for a fit-test?

2. What is the difference between a fit-test and user seal check?

3. What does OSHA expect for an acceptable fit-test and user seal check?

In response to these questions, this memorandum is being distributed to provide information
and guidance on current Agency respirator requirements.

Respirator Fit-Testing and User seal
checking Requirements:

The procedures and requirements for fit-test- able challenge agent (e.g., corn oil). The ad-
ing the new classes of particulate respirators equacy of the fit is determined by measuring
have not changed from those OSHA currently and establishing a ratio of the actual levels of
requires. While the respirator standard (29 the challenge agent both inside and outside of
CFR 1910.134)* does not specify what fit tests the respirator. Among QNFT methods, OSHA
and fit-testing protocols to be used, OSHA allows the use of ambient-particulate measure-
would accept either a quantitative fit test ment technology (Portacount) and the con-
(QNFT) or qualitative fit test (QLFT) as meet- trolled-negative pressure technology (Dynatech
ing the fit test requirement. Fit-Tester 3000). [Note: the controlled nega-
tive-pressure technology is only applicable to
A QNFT consists of wearing the respirator in respirators with replaceable filters. It is not
a stable test atmosphere that contains a suit- applicable to filtration facepiece respirators.]

* 29 CFR 1910.134 is now codified for protection against TB as 29 CFR 1910.139.

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