N95 Masks and Fit Testing during COVID

N95 Masks and Fit Testing during COVID

June 12, 2020
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With many businesses opening and employees returning to work we have received many questions from employers regarding use of N95 masks and fit testing during the COVID-19 pandemic.

The most commonly asked question about N95’s is “Are N95's considered respirators?” and the answer is: yes. 

Technically, an N95 is a filtering facepiece respirator because of how it creates a tight seal to the face and filters at least 95% of the airborne particles the user would otherwise breathe in. 

It is important to realize that N95's are NOT surgical masks. Surgical masks are different and do not create a tight seal, allowing small particles to leak around the edges of the respirator and into the wearer’s breathing zone.

Because of the tight seal on a respirator there are some rules in place for their use. 

  1. Staff that must use any respirator are required to undergo fit testing, medical clearance, and training.  All of these elements are required as part of the employer’s respiratory protection program. 
  2. Even if an employer allows a worker to wear an N95 voluntarily, the employer has the obligation to make sure that the respirator is not presenting a health hazard to the employee.
  3. An employee should be fit tested when they are first issued an N95 and then annually thereafter.  It is possible to require fit testing more frequently if the user’s facial features change due to extreme weight loss or gain.

During the pandemic OSHA has issued guidance to it’s compliance officers that they are permitted to exercise discretion with enforcement of fit testing as long as the employer follows the following guidelines;

  • Make a good-faith effort to comply with 29 CFR § 1910.134;
  • Use only NIOSH-certified respirators;
  • Implement CDC and OSHA strategies for optimizing the supply of N95 filtering facepiece respirators and prioritizing their use, 
  • Perform initial fit tests for each HCP with the same model, style, and size respirator that the worker will be required to wear for protection against COVID-19 (initial fit testing is essential to determine if the respirator properly fits the worker and is capable of providing the expected level of protection);
  • Inform workers that the employer is temporarily suspending the annual fit testing of N95 filtering facepiece respirators to preserve and prioritize the supply of respirators for use in situations where they are required to be worn;
  • Explain to workers the importance of performing a user seal check (i.e., a fit check) at each donning to make sure they are getting an adequate seal from their respirator, in accordance with the procedures outlined in 29 CFR § 1910.134, Appendix B-1, User Seal Check Procedures.4 See also, OSHA tutorial videos;
  • Conduct a fit test if they observe visual changes in the employee’s physical condition that could affect respirator fit (e.g., facial scarring, dental changes, cosmetic surgery, or obvious changes in body weight) and explain to workers that, if their face shape has changed since their last fit test, they may no longer be getting a good facial seal with the respirator and, thus, are not being adequately protected; and,
  • Remind workers that they should inform their supervisor or their respirator program administrator if the integrity and/or fit of their N95 filtering facepiece respirator is compromised.

Below are some links to more information on N95 masks.

https://blogs.cdc.gov/niosh-science-blog/2020/03/16/n95-preparedness/

https://www.cdc.gov/niosh/docs/2018-130/pdfs/2018-130.pdf?id=10.26616/NIOSHPUB2018130

https://www.osha.gov/memos/2020-04-08/expanded-temporary-enforcement-guidance-respiratory-protection-fit-testing-n95

https://www.osha.gov/video/respiratory_protection/voluntaryuse_transcript.html#:~:text=If%20your%20employer%20permits%20you,a%20health%20hazard%20to%20you.