OSHA Announces Temporary PAPR Guidelines

OSHA Announces Temporary PAPR Guidelines

Due to the impact of increased demand for N95 filtering facepiece respirators (FFRs) coupled with limited global availability, OSHA recommends the reassessment of engineering and administrative controls by employers to accommodate the shortage of N95 FFRs. 

OSHA has released temporary guidelines for healthcare personnel and workers in high to very high-exposure-risk professions. These guidelines are regarding the Respiratory Protection standard for Powered Air Purifying Respirators (PAPRs) and apply only to the fit-testing of National Institute for Occupational Safety and Health (NIOSH) approved PAPRs.

N95 FFRs should now only be used under contingency and in crisis-capacity methods for example: respirator decontamination, extended use, and reuse. This involves taking steps to temporarily suspend non-essential duties and consider the feasibility of increasing the use of wet methods or portable local exhaust systems for dust-generating activities or move operations outdoors, thereby eliminating the need for N95 FFRs. 

OSHA states that “if respiratory protection must be used, employers may consider the use of alternative classes of respirators that provide equal or greater protection compared to an N95 filtering facepiece respirator, such as N99, N100, R95, R99, R100, P95, P99, and P100 respirators and NIOSH-approved, non-disposable elastomeric respirators or powered air-purifying respirators, either loose-fitting or tight-fitting”. The new policy allows the use of tight-fitting PAPRs approved by NIOSH for protection against exposure risk to SARS-CoV-2 when initial and/or annual fit testing is unworkable due to fit-testing and respirator supply shortages.

These guidelines are not applicable to all PAPRs. PAPRs that are excluded from these guidelines are:

• Those that have not been approved by NIOSH;
• Have been used by workers with low or medium exposure risk to the coronavirus; 
• Have been used or for protection against airborne hazards other than SARS-CoV-2, such as chemical hazards; and
• That is loose-fitting and/or hooded and that do not require fit testing.

The agency has permitted CSHOs to exercise discretion in enforcement when considering issuing citations for fit-testing requirements. That being said, employers should note that OSHA’s Enforcement Guidance does not suspend or reduce any obligation of businesses to protect employees from potential airborne biological hazards. Discretion is warranted when the employer/business has:

• Provided PAPRs using a high efficiency (HE) particulate cartridge or filter to protect personnel from exposure to SARS-CoV-2
• Monitored fit-testing supplies and made good-faith efforts to obtain fit-testing supplies;
• Implemented engineering controls, work practices, or administrative controls that reduce the need for respiratory protection, such as using partitions, restricting access, and cohorting patients; and
• Maintained all elements of a fully compliant respiratory protection other than fit-testing requirements. By ensuring that all personnel receive required medical evaluations, are informed of new policies, trained on new procedures, ensuring batteries and filters for PAPRs are well maintained to provide positive pressure throughout the duration of the employee’s shift or procedure, and ensuring employees wearing tight-fitting PAPRs maintain facial hair that does not compromise the seal of the respirator or interfere with valve function.