Mini Respiratory Protection Program

The Mini Respiratory Protection Program applies only to respirator use that is done in accordance with 1910.502(f)(4).

• In short, 1910.504 is limited in scope and only covers respirator situations explicitly tied to the conditions set out in 1910.502(f)(4).
• Employers should check 1910.502(f)(4) to confirm whether their respirator use falls within the mini program’s allowance.

Under 1910.504(b), an elastomeric respirator is a tight-fitting respirator with a facepiece made of synthetic or rubber material that permits it to be disinfected, cleaned, and reused according to the manufacturer’s instructions, and it is equipped with replaceable cartridge(s), canister(s), or filter(s) (1910.504(b)).

• By contrast, a filtering facepiece respirator is defined as a negative-pressure particulate respirator with a non-replaceable filter as an integral part of the facepiece or with the entire facepiece composed of the non-replaceable filtering medium (1910.504(b)).
• Key practical difference: elastomerics are designed for cleaning and reuse with replaceable elements; filtering facepieces (for example, many N95s) have non-replaceable filters and are generally single-user items.

No — under 1910.504(b) face coverings, facemasks, and face shields are not respirators (1910.504(b)).

• That means they do not count as respirators for the purposes of the mini respiratory protection program and do not provide the same level of airborne contaminant protection as NIOSH-certified respirators or authorized EUA respirators.
• If a respirator is required by workplace hazards, employers must provide an appropriate respirator and follow the employer-responsibility provisions in 1910.504(d).

Under 1910.504(c), the employer must provide employees who bring and use their own respirators the specific notice that explains respirators can be effective but can also become a hazard if used improperly, and it lists precautions the employee must take (1910.504(c).

• The notice should tell employees to follow manufacturer instructions, keep their respirator clean and not share it, and be aware that improper use may create hazards.
• Employers should keep a copy of the notice available to employees who supply their own respirators as part of the mini program requirements.

Under 1910.504(c)(1), employees who provide their own respirators must read and follow all manufacturer instructions on use, maintenance, cleaning and care, and warnings about the respirator’s limitations (1910.504(c)(1).

• Practically, this means workers must follow the respirator user manual and cleaning/disinfection instructions so the respirator remains effective and safe to use.
• Employers should ensure employees understand these instructions in a language and literacy level they can comprehend as required by the training provisions in 1910.504(d)(1).

Yes — 1910.504(c)(2) requires that employees keep track of their respirator so they do not mistakenly use someone else’s respirator (1910.504(c)(2).

• This helps prevent cross-contamination and ensures each employee uses a respirator sized and maintained for them.
• Employers can help by labeling respirators with the user’s name or providing individual storage to make tracking easier.

No — 1910.504(c)(3) says employees must not wear their own respirator where other workplace hazards (for example, chemical exposures) require use of a respirator; in those cases the employer must provide a respirator used in accordance with 1910.134 (1910.504(c)(3).

• Practically, if hazards beyond COVID-19 are present that trigger the full respiratory protection standard, the employer must implement the full 29 CFR 1910.134 respiratory protection program.
• Employers should evaluate workplace hazards and provide compliant equipment and program elements under 1910.134 when required.

Under 1910.504(d)(1)(i), employers must ensure that each employee wearing a respirator receives training on how to inspect, put on and remove, and use a respirator before their first use and whenever they change respirator types (1910.504(d)(1)(i).

• Training must be in a language and literacy level the employee understands (1910.504(d)(1)).
• Employers should demonstrate inspection steps (checking straps, facepiece, valves), correct donning/doffing order, and safe handling procedures during training.

Under 1910.504(d)(1)(ii), training must explain the limitations and capabilities of the respirator, especially when the respirator has not been fit tested (1910.504(d)(1)(ii).

• Employees should be told what protection the respirator can and cannot provide, warning signs of poor protection (e.g., leaks, breathing difficulty), and situations where a respirator without fit testing may offer reduced protection.
• Employers should emphasize that an unfit-tested tight-fitting respirator may not provide full protection and explain any additional precautions or limitations.

Under 1910.504(d)(1)(iii), training must cover the procedures and schedules for storing, maintaining, and inspecting respirators (1910.504(d)(1)(iii).

• This should include where to store respirators (clean, dry areas), how often to inspect components (straps, facepiece, filters), and when to dispose of or replace damaged parts.
• For elastomeric respirators or PAPRs, training should also reference cleaning/disinfection procedures as required under 1910.504(d)(3)(ii)(B) and 1910.134 guidance.

Under 1910.504(d)(1)(iv), training must teach employees how to perform a user seal check as described in 1910.504(d)(2), and the employer must ensure each tight-fitting respirator user performs a seal check each time they put on the respirator (1910.504(d)(2)(i)).

• Training should include hands-on practice performing both positive and negative pressure checks described in 1910.504(d)(2)(i)(A) and 1910.504(d)(2)(i)(B).
• Employees must be shown how to correct leaks and adjust straps and nosepieces if the seal check fails.

Under 1910.504(d)(1)(v), training must teach employees how to recognize medical signs and symptoms that may limit or prevent effective respirator use (for example, shortness of breath, coughing, wheezing, chest pain) and what to do if they experience those signs or symptoms (1910.504(d)(1)(v).

• Training should instruct employees to stop wearing the respirator and notify a supervisor or seek medical evaluation if they develop symptoms that affect breathing or cardiovascular function while using a respirator.
• Employers must require discontinuation of respirator use when such medical signs are reported, per 1910.504(d)(4).

Under 1910.504(d)(2)(i)(A), to perform a positive pressure user seal check you should, after proper hand hygiene and donning, place your hands over the facepiece covering as much surface as possible and exhale gently; a slight positive pressure should build inside the facepiece without outward leakage (1910.504(d)(2)(i)(A).

• Evidence of leakage includes feeling air movement at the seal, fogging of glasses, or not building pressure.
• If the respirator has an exhalation valve so a positive check isn’t possible, perform the negative pressure check instead as described in 1910.504(d)(2)(i)(B).

Under 1910.504(d)(2)(i)(B), to perform a negative pressure user seal check you should, after proper hand hygiene and donning, cover the filter surface with your hands as much as possible and then inhale; the facepiece should collapse slightly on your face and you should not feel air passing between your face and the facepiece (1910.504(d)(2)(i)(B)).

• If you feel air leaking or the facepiece does not draw in, adjust the respirator and repeat the seal check.
• Employers must ensure users fix any problems discovered during the seal check as required by 1910.504(d)(2)(ii).

Under 1910.504(d)(2)(ii), the employee must correct any problems found during the user seal check; for leaks around the nose, use both hands to readjust the respirator or adjust the nosepiece, and readjust straps as needed until a proper seal is achieved (1910.504(d)(2)(ii).

• Employers must ensure employees perform these corrections every time a leak is detected.
• If a proper seal cannot be achieved because of facial hair interfering with the seal, see the note to paragraph (d)(2) about providing a different respirator type for employees who cannot trim facial hair due to religious belief (1910.504(d)(2)).

The note to 1910.504(d)(2) says employers may provide a different type of respirator to accommodate employees who cannot trim or cut facial hair because of religious belief when facial hair interferes with a seal (1910.504(d)(2) note).

• Practically, this means employers should consider alternate respirator types (for example, loose-fitting hoods or PAPRs) that do not require a tight face seal for affected employees.
• Any alternate equipment must still be appropriate for the hazard and used in compliance with the other requirements of 1910.504(d).

Under 1910.504(d)(3)(i), a filtering facepiece respirator may be reused by the same employee only when all of these conditions are met: it is not visibly soiled or damaged; it has been stored in a breathable container for at least five calendar days and kept dry; the employee visually inspects it; the employee completes a user seal check; the employee performs proper hand hygiene before use; and it has not been worn more than five days total (1910.504(d)(3)(i)(A)–(F)).

• Note that the standard discourages reuse of single-use respirators, so reuse should be an exception with careful controls (1910.504(d)(3)(i) note).
• Employers should document any reuse plan and train employees on the specific checks and storage methods required under 1910.504(d)(1).

Under 1910.504(d)(3)(i)(B), it means the filtering facepiece respirator must be stored in a breathable container (for example, a paper bag) for at least five calendar days between uses and kept away from water or moisture before being reused by the same employee (1910.504(d)(3)(i)(B).

• The five-day storage is intended to allow potential virus particles to become nonviable; the container must permit drying and avoid trapping moisture.
• Employers should instruct employees on proper labeling, rotation, and storage to prevent accidental sharing and moisture exposure, per 1910.504(d)(1)(iii).

Under 1910.504(d)(3)(i)(F), a filtering facepiece respirator may not be worn more than five days total by the same employee under the conditions that allow reuse (1910.504(d)(3)(i)(F).

• Employers should track total days worn per FFR and remove any respirator from reuse once it has been used five times or five calendar days, whichever the program defines as the limit.
• Remember the standard also cautions that reuse of single-use respirators is discouraged (1910.504(d)(3)(i) note).

Under 1910.504(d)(3)(ii), elastomeric respirators and PAPRs may be reused only when they are not damaged; they are cleaned and disinfected as often as necessary to be kept sanitary in accordance with 1910.134, Appendix B-2; and an appropriate change schedule is implemented for cartridges, canisters, or filters (1910.504(d)(3)(ii)(A)–(C)).

• Employers must establish cleaning/disinfection procedures (see 1910.134) and a filter/cartridge replacement schedule appropriate to the workplace exposures.
• Keep maintenance records and train employees on cleaning, inspection, and replacement procedures as required by 1910.504(d)(1).

Under 1910.504(d)(3)(ii)(B), employers must clean and disinfect elastomeric respirators or PAPRs as often as necessary to be maintained in a sanitary condition in accordance with 1910.134, Appendix B-2 and 1910.504(d)(3)(ii) requires employers to enforce that practice (1910.504(d)(3)(ii)(B).

• Employers should consult 1910.134 Appendix B-2 for step-by-step cleaning and disinfecting guidance and adapt that guidance to the respirator manufacturer’s instructions.
• Ensure cleaning agents are compatible with respirator materials and that components are fully dry before reuse.

Under 1910.504(d)(4), employers must require employees to discontinue respirator use when either the employee or a supervisor reports medical signs or symptoms (for example, shortness of breath, coughing, wheezing, chest pain) that are related to the ability to use a respirator (1910.504(d)(4).

• Employers must remove the employee from respirator use and arrange any necessary medical evaluation or follow-up.
• Additionally, any employee previously medically determined unfit to wear a respirator must not be provided one under this standard unless re-evaluated and medically cleared (1910.504(d)(4)).

No — 1910.504(d)(4) states that any employee previously found not medically fit to wear a respirator must not be provided one under this standard unless they are re-evaluated and medically cleared to use a respirator (1910.504(d)(4).

• Employers must follow medical evaluation procedures and obtain clearance before resuming respirator use for such employees.
• This requirement ensures that respirator use is safe for the employee’s health condition and is consistent with the program’s medical safeguards.

The Mini Respiratory Protection Program became effective on June 21, 2021, as stated in 1910.504(e) (1910.504(e).

• Employers implementing the mini program should be aware that the standard’s requirements have applied since that effective date.
• Subsequent guidance or enforcement actions (for example, on related recordkeeping) may affect other parts of COVID-19 rules — see OSHA’s memorandum on enforcement of certain COVID-19 recordkeeping requirements at https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05 for recent enforcement context.

Under 1910.504(b), a Powered Air-Purifying Respirator (PAPR) is defined as an air-purifying respirator that uses a blower to force ambient air through air-purifying elements to the inlet covering (1910.504(b).

• PAPRs can be tight-fitting or loose-fitting depending on the model; loose-fitting PAPRs do not require a tight face seal and can be an alternative for employees with facial hair that interferes with a tight-fitting respirator (see the note to 1910.504(d)(2)).
• Employers must ensure PAPRs are cleaned, disinfected, and maintained per 1910.504(d)(3)(ii) and applicable manufacturer instructions.

Under 1910.504(d)(3)(i) the standard says reuse of single-use respirators (for example, filtering facepiece respirators) is discouraged, and it sets strict conditions if reuse by the same employee is allowed (1910.504(d)(3)(i) note).

• If reuse is used as an exception, employers must ensure all the conditions in 1910.504(d)(3)(i)(A)–(F) are met (no visible soil/damage, five-day breathable storage, visual inspection, user seal check, hand hygiene, and not more than five days worn).
• Employers should prefer reusable respirators (elastomerics or PAPRs) when ongoing protection and sanitation controls are needed, following 1910.504(d)(3)(ii).

Under 1910.504(d)(1), employers must provide respirator training in a language and at a literacy level that the employee understands (1910.504(d)(1).

• This ensures employees can comprehend inspection, donning, seal check, maintenance, and medical-symptom guidance.
• Employers should document training content and confirm employee understanding (for example, through return demonstrations or quizzes) as part of the mini program compliance.

The mini program under 1910.504 does not replace the full respiratory protection standard; 1910.504(c)(3) and other provisions require employers to follow 1910.134 when workplace hazards necessitate the full standard (for example, chemical exposures or other respirator-required hazards) (1910.504(c)(3)).

• In practice, use the mini program only where it is applicable under 1910.502(f)(4) and where hazards do not trigger the full 1910.134 requirements.
• If chemical or other hazards are present that require 1910.134, employers must implement the full program elements in 1910.134, not the mini program.

No — the OSHA memorandum dated February 5, 2025, announces a temporary enforcement stay for certain COVID-19 recordkeeping and reporting requirements under 1910.502, but it does not change the respirator requirements in 1910.504 themselves (https://www.osha.gov/laws-regs/standardinterpretations/2025-02-05).

• Employers should still comply with the substantive respirator training, seal-check, reuse, cleaning, and medical provisions in 1910.504 even though recordkeeping/reporting enforcement for certain COVID-19 logs and reports was stayed.
• Recordkeeping under other OSHA rules (for example, 29 CFR part 1904) may still apply.