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OSHA 1910.134AppB1

User seal check procedures

Subpart I

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.134AppendixB-1, what is a "user seal check" for a tight-fitting respirator?

A user seal check is a quick self-check the respirator wearer performs each time they put on a tight-fitting respirator to confirm an adequate face seal. Appendix B-1 to 1910.134 requires the individual who uses a tight-fitting respirator to perform a user seal check each time the respirator is donned. The appendix also clarifies that user seal checks are not substitutes for formal qualitative or quantitative fit tests.

Under 1910.134AppendixB-1, are user seal checks mandatory?

Yes. Appendix B-1 to 1910.134 is mandatory and requires that the individual who uses a tight-fitting respirator perform a user seal check each time the respirator is put on. The appendix heading itself states "(Mandatory)" and the text directs the wearer to perform the check for adequate sealing.

Under 1910.134AppendixB-1, when must a user perform a seal check?

A user must perform a seal check each time the tight-fitting respirator is put on. Appendix B-1 to 1910.134 explicitly says the individual who uses a tight-fitting respirator is to perform a user seal check to ensure an adequate seal each time the respirator is put on.

Under 1910.134AppendixB-1, can user seal checks replace qualitative or quantitative fit tests?

No. User seal checks cannot replace fit tests. Appendix B-1 to 1910.134 explicitly states that user seal checks are not substitutes for qualitative or quantitative fit tests required by the standard.

Under 1910.134AppendixB-1, how do you perform the positive pressure user seal check?

For a positive pressure check you gently exhale while blocking the exhalation valve and look for outward leakage. Appendix B-1 to 1910.134 instructs the wearer to close off the exhalation valve and exhale gently into the facepiece; the fit is satisfactory if a slight positive pressure is built up inside the facepiece without any evidence of outward leakage at the seal. The appendix also notes that for most respirators the wearer may need to remove the exhalation valve cover before closing the valve and then carefully replace it after the test.

Under 1910.134AppendixB-1, how do you perform the negative pressure user seal check?

For a negative pressure check you block the filter or inlet, inhale gently, and hold your breath for ten seconds to check for inward leakage. Appendix B-1 to 1910.134 instructs you to close off the inlet opening of the canister or cartridge(s) (for example with the palm or a filter seal), inhale gently so the facepiece collapses slightly, and hold the breath for ten seconds; if the facepiece remains slightly collapsed with no inward leakage the tightness is satisfactory.

Under 1910.134AppendixB-1, may an employer allow the respirator manufacturer's user seal check procedure instead of the positive/negative checks?

Yes, if the employer demonstrates the manufacturer's method is equally effective. Appendix B-1 to 1910.134 allows the respirator manufacturer's recommended user seal check procedures to be used instead of the positive and/or negative pressure checks, provided the employer demonstrates that the manufacturer's procedures are equally effective.

Under 1910.134AppendixB-1, what should you do if the cartridge inlet cannot be covered with the palm during a negative pressure check?

Cover the cartridge inlet with a thin latex or nitrile glove (or similar) when the palm cannot effectively seal the inlet. Appendix B-1 to 1910.134 explains that if the design of the inlet opening cannot be effectively covered with the palm, the test can be performed by covering the inlet opening of the cartridge with a thin latex or nitrile glove.

Under 1910.134AppendixB-1, who is responsible for performing the user seal check?

The respirator user performs the seal check themself. Appendix B-1 to 1910.134 states that "the individual who uses a tight-fitting respirator is to perform a user seal check" to ensure a proper seal each time the respirator is donned.

Under 1910.134AppendixB-1, do the user seal check procedures apply to all tight-fitting facepieces (half-mask and full-face)?

Yes. Appendix B-1 applies to the individual using a tight-fitting respirator, which includes tight-fitting half-mask and full-facepiece respirators. Appendix B-1 to 1910.134 directs the wearer of a tight-fitting respirator to perform a user seal check each time it is put on.

Under 1910.134AppendixB-1, are user seal checks required for loose-fitting hoods or helmets?

No. Appendix B-1 specifically requires a user seal check for tight-fitting respirators, so loose-fitting hoods and helmets (which are not tight-fitting) are not covered by these user seal check procedures. See Appendix B-1 to 1910.134 which begins by specifying the individual who uses a tight-fitting respirator must perform the check.

Under 1910.134AppendixB-1, how long must you hold your breath during the negative pressure check?

You must hold your breath for ten seconds during the negative pressure check. Appendix B-1 to 1910.134 instructs the wearer to inhale gently so that the facepiece collapses slightly and then hold the breath for ten seconds to verify no inward leakage.

Under 1910.134AppendixB-1, what indicates a satisfactory positive pressure check?

A satisfactory positive pressure check is indicated by a slight positive pressure inside the facepiece with no evidence of outward leakage at the seal. Appendix B-1 to 1910.134 explains that after closing off the exhalation valve and exhaling gently, the face fit is satisfactory if a slight positive pressure can be built up without outward leakage at the seal.

Under 1910.134AppendixB-1, what indicates a satisfactory negative pressure check?

A satisfactory negative pressure check is indicated when the facepiece remains slightly collapsed after inhaling and holding the breath, and no inward leakage is detected. Appendix B-1 to 1910.134 states that if the facepiece remains in its slightly collapsed condition and no inward leakage of air is detected, the tightness is considered satisfactory.

Under 1910.134AppendixB-1, does the appendix require both positive and negative checks every time, or can you use one method?

You can use either the positive and/or negative pressure checks listed in the appendix or the respirator manufacturer's recommended user seal check method. Appendix B-1 to 1910.134 states that either the positive and negative pressure checks in the appendix, or the manufacturer's recommended method, shall be used; it does not mandate both checks every time.

Under 1910.134AppendixB-1, who must show that a manufacturer's user seal check method is equally effective?

The employer must demonstrate that the manufacturer's user seal check procedure is equally effective. Appendix B-1 to 1910.134 allows the manufacturer's recommended method to be used only "provided that the employer demonstrates that the manufacturer's procedures are equally effective."

Under 1910.134AppendixB-1, does the appendix apply to powered air-purifying respirators (PAPRs) that have tight-fitting facepieces?

Yes—if the PAPR uses a tight-fitting facepiece, the wearer must perform a user seal check when donning it. Appendix B-1 to 1910.134 applies to "tight-fitting respirators," which includes tight-fitting PAPR facepieces, and requires the individual user to perform a seal check each time the respirator is put on.

Under 1910.134AppendixB-1, does the appendix set pass/fail criteria for the two checks?

Yes. Appendix B-1 to 1910.134 describes clear pass criteria: for the positive pressure check, a slight positive pressure must be built without outward leakage at the seal; for the negative pressure check, the facepiece must remain slightly collapsed with no inward leakage detected during a ten-second breath hold.