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A QLFT involves the introduction of an aero- worker well enough to satisfy the respira-
sol challenge agent into the area around the tory protection standard.
face of the respirator wearer. OSHA require-
ments for fit-testing of respiratory protection In the 1994 CDC Tuberculosis Guidelines
are spelled out under the third sentence of 29 where respiratory protection for occupational
CFR 1910.134(e)(5):* exposure to Tuberculosis is addressed, the
CDC spelled out standard performance crite-
“Training shall provide... an opportunity ria for half mask respirators. One point un-
to handle the respirator, have it fitted der the criteria stated the following:
properly, test its face-piece-to-face seal,
wear it in normal air for a long familiarity “The ability to be qualitatively or quanti-
period, and, finally, to wear it in a test tatively fit tested in a reliable way to ob-
atmosphere.” tain a face-seal leakage of < 10%.”
Protection Factors and QNFT/QLFT: This statement apparently has been misinter-
preted by some to imply that the new classes
Half-mask respirators (including disposable of half mask respirators must only meet an in-
or filtering facepiece and replaceable filters) dividual FF of 10 rather than a FF of 100.
have typically received an assigned protection Until assigned protection factors are deter-
factor (APF) of 10 by ANSI and NIOSH. For mined for these respirators, for those facilities
a QNFT, one uses the APF plus an assigned conducting QNFT, OSHA continues to re-
minimum safety factor of 10 to establish the quire minimum fit factors of 100 to be ob-
“fit factor (FF).” The FF is what the wearer of tained.
that respirator is assigned for the respirator
with which he/she was tested. For a dispos- Qualitative Fit-Testing Procedures:
able respirator or half-mask respirator, based
upon the APF times the safety factor, one For facilities electing to conduct QLFTs, a de-
must achieve a minimum FF of 100 in a termination of adequate fit is based upon
QNFT. [Note: the safety factor of 10 was cho- whether or not the individual can smell, taste
sen based upon standard practice to help en- or detect the challenge agent. OSHA will ac-
sure adequate protection during field use; cept those tests using the following challenge
ANSI Z88.2-1992 also recommends a safety agents currently available: irritant fume, sac-
factor of 10]. OSHA has not formally as- charin or Bitrex™ aerosol. When an indi-
signed an APF to the Type 95, 99, or 100 res- vidual passes a QLFT, a minimum FF of 100
pirators certified under 42 CFR Part 84. As will be assumed to have been achieved.
you know, OSHA issued a proposed respira-
tory protection standard in the Federal Regis- A number of queries to OSHA have involved
ter on November 15th, 1994 (Vol. 59, No. concerns regarding the use of irritant smoke
219). When the final respiratory protection or saccharin aerosol QLFT protocols. Re-
standard is issued, the Agency will take a for- cently, a peer reviewed article discussed the
mal position on the APFs. In the interim, validation of an alternative qualitative fit test-
when the Type 95, 99, or 100 respirators are ing media. That test media used is a sub-
quantitatively fit tested, OSHA will continue stance called Bitrex (denatonium benzoate).
TM
to require a minimum FF of 100 in order for This test and the testing protocols are de-
the employer to conclude that they fit the scribed in:
* 29 CFR 1910.134 is now codified for protection against TB as 29 CFR 1910.139.
94