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OSHA 1915.1001AppC

Fit testing procedures

Subpart Z

22 Questions & Answers
10 Interpretations

Questions & Answers

Under 29 CFR 1915.1001 App C, when must employers perform respirator fit testing for shipyard employees?

Employers must perform fit testing before an employee uses a tight-fitting respirator in the workplace. This is required under 1915.1001 App C, which directs employers to follow the fit-testing requirements in 1910.134(f) and the protocols in Appendix A to 1910.134.

  • Perform the initial fit test prior to assignment to respirator use.
  • Use either the qualitative or quantitative protocols specified in 1910.134 App A.
  • Document and retain fit-test records as required by 1910.134(f).

Under 29 CFR 1910.134(f), how often must fit testing be repeated?

Fit testing must be repeated at least annually for each employee who uses a tight-fitting respirator. 1910.134(f) requires an annual fit test to verify the respirator continues to fit the wearer properly.

  • Repeat sooner when there are changes that could affect fit (see next question).
  • Use the same qualitative or quantitative methods in 1910.134 App A.

Under 1910.134(f), what changes require additional fit testing beyond the annual test?

Additional fit testing is required when there are changes in the employee’s physical condition or respirator that could affect fit. 1910.134(f) specifies fit testing whenever there are changes such as significant weight change, dental work, facial surgery, or wearing new styles of respirator.

  • Examples: major dental procedures, facial scarring, significant weight gain/loss, or switch to a different model/size of respirator.
  • If the employer observes or the employee reports a change that could affect the seal, perform a new fit test before continued use.

Under 29 CFR 1915.1001 App C, can employers use either qualitative or quantitative fit testing protocols?

Yes — employers may use either the qualitative or the quantitative fit-testing procedures specified in Appendix A to 1910.134. 1915.1001 App C requires compliance with the fit-testing requirements in 1910.134(f), and those protocols allow either approach depending on respirator type and employer choice.

  • Qualitative methods are allowed for appropriate negative-pressure respirators (e.g., saccharin, Bitrex, isoamyl acetate, irritant smoke).
  • Quantitative methods use instruments to measure leakage (e.g., PortaCount) and are required for certain respirators or when a quantitative measure is preferred.

Under 1910.134 App A, which respirators are not suitable for qualitative fit testing and require quantitative testing instead?

Tight-fitting half- and full-facepiece air-purifying respirators can often use qualitative tests, but certain situations or respirator types require quantitative fit testing under 1910.134 App A and 1910.134(f).

  • Quantitative testing is required when an objective numerical fit factor is necessary (for instance, for certain tight-fitting full facepieces needing specific assigned protection factors).
  • Employers should consult 1910.134 App A to match the respirator type with the approved test method.

Under 29 CFR 1915.1001 App C, who must conduct fit testing and what qualifications are required?

OSHA does not prescribe a specific professional credential for the person who conducts fit testing, but the tester must be competent to follow the selected protocol in 1910.134 App A and the requirements in 1910.134(f). The employer is responsible for ensuring the tester performs the fit test correctly and documents results.

  • The tester should be trained in the specific fit-test procedures (qualitative or quantitative) being used.
  • Employers must keep fit-test records as required in 1910.134(f)(2).

Under 1910.134(f), what records must employers keep for respirator fit testing?

Employers must retain fit-test records that show the employee’s name, the type of fit test performed, the make/model/size of the respirator, the date of the test, and the pass/fail result as required by 1910.134(f).

  • Maintain records for the duration specified by the standard or your program (check the specific recordkeeping sentences in 1910.134(f)).
  • These records support compliance and help identify when retesting is required.

Under 29 CFR 1915.1001 App C, does a fit check (user seal check) replace formal fit testing?

No — a user seal check (fit check) does not replace the formal fit test required by 1910.134(f) and 1915.1001 App C. The formal fit test verifies the respirator model, size and fit under the standardized protocol; a user seal check is a quick check that the wearer performs each time the respirator is donned.

  • Perform a positive and/or negative pressure user seal check every time a tight-fitting respirator is put on.
  • Still complete the formal fit test initially and at least annually per 1910.134(f).

Under 1910.134(f), how should employers handle fit testing when employees need to use different respirator models for different tasks?

Employers must fit test each employee with the make, model, and size of respirator they will actually use; if an employee will use multiple models, each must be fit tested. 1910.134(f) and 1915.1001 App C require using the specific respirator that the employee will wear on the job.

  • If an employer provides several approved respirator models, fit test the employee for each model they may be required to use.
  • Employers may keep a list of acceptable models for each worker, but the worker must be demonstrated to fit each listed model.

Under 29 CFR 1915.1001 App C, how should employers address facial hair when fit testing tight-fitting respirators?

Employees must be clean-shaven where the respirator seal contacts the face; facial hair that interferes with the seal prevents a proper fit and requires that the employee not use that type of tight-fitting respirator. 1910.134(f) and the fit-test protocols in 1910.134 App A assume an effective face seal.

  • Sideburns, mustaches, beards, or stubble in the sealing area can cause a failed fit test.
  • Consider powered air-purifying respirators (PAPRs) with loose-fitting hoods or helmets if the employee cannot shave for religious or medical reasons.

Under 1910.134(f), do employers have to provide medical evaluation before fit testing?

Employers must ensure employees are medically able to wear a respirator before fit testing or use, as required by 1910.134; this typically means completing the medical evaluation provisions in the respiratory protection standard prior to fit testing. 1910.134(f) is part of that standard’s fit-testing requirements.

  • Follow the medical questionnaire and/or medical examination procedures in 1910.134(d) before fit testing to identify conditions that could interfere with respirator use.
  • If an employee has medical restrictions, the employer must address them before assigning respirator use.

Under 29 CFR 1915.1001 App C, can employers rely on a fit test done by another employer or at another site?

Fit tests must reflect the actual respirator make, model, and size that the employee will use and must be recent; generally, employers should perform or verify fit tests for their own workers. 1910.134(f) requires documentation of the fit test for each employee, and employers must have confidence the test applies to the equipment they provide.

  • If an employee already has a valid fit test record for the exact make/model/size performed within the required timeframe, an employer may accept that record after verifying its applicability.
  • Retain fit-test documentation as required by 1910.134(f).

Under 1910.134 App A, what exercises must the wearer perform during a qualitative fit test?

During a qualitative fit test, the wearer must perform a standardized set of exercises (e.g., normal breathing, deep breathing, turning head side to side, moving head up and down, talking, grimace, bending over, and normal breathing) as specified in 1910.134 App A. These exercises check the respirator seal under typical motions.

  • The grimace exercise is included to intentionally break the seal and then allow testing of the seal on returning to normal breathing.
  • Follow the exact sequence and timing in 1910.134 App A for consistent results.

Under 29 CFR 1915.1001 App C, what should an employer do if an employee fails a fit test?

If an employee fails a fit test, the employer must try a different make, model, or size of respirator until a proper fit is achieved and documented, per 1910.134(f) and 1910.134 App A. The employee cannot use that particular tight-fitting respirator until they pass a fit test for it.

  • Record the failed attempt and the respirator models tried.
  • Consider alternate approved respirator types (e.g., different facepieces or a loose-fitting PAPR) if no tight-fitting model fits.

Under 1910.134(f), are fit testing requirements different for emergency use respirators?

Fit testing requirements generally apply to any tight-fitting respirator used in the workplace, including those for emergency use; 1910.134(f) does not exempt emergency use. Employers must ensure employees are fit-tested for the respirator models they will use in emergencies.

  • For emergency response, employers should identify which respirators responders will wear and ensure they are fit tested and medically cleared per 1910.134.
  • Keep fit-test records accessible to demonstrate readiness.

Under 29 CFR 1915.1001 App C, can powered air-purifying respirators (PAPRs) with loose-fitting hoods be fit tested using the same protocols in Appendix A?

Loose-fitting PAPRs that do not rely on a tight face seal do not require a fit test in the same way tight-fitting respirators do; the fit-test protocols in 1910.134 App A apply to tight-fitting facepieces. 1915.1001 App C directs employers to follow 1910.134(f) and its appendix, which distinguish loose-fitting respirators.

  • For loose-fitting PAPRs, OSHA requires that the employer ensure the device provides adequate protection and that users are trained, but a conventional facepiece fit test is not applicable.
  • If a PAPR uses a tight-fitting facepiece, then that facepiece must be fit tested per 1910.134(f).

Under 1910.134(f), are fit tests required at different altitudes or environmental conditions?

Fit testing should be performed in conditions that reasonably approximate how the respirator will be used; 1910.134(f) and 1910.134 App A expect fit tests to be valid for expected use conditions, but they do not require special fit-test methods simply because of altitude. Employers should consider environmental factors that could affect respirator functioning.

  • For example, extreme cold may stiffen materials and affect fit; if use will be in those conditions, evaluate fit accordingly.
  • If the respirator’s performance is limited by altitude (e.g., assigned protection factors), consult the respirator manufacturer and the standard.

Under 29 CFR 1915.1001 App C, does OSHA allow abbreviated fit-testing methods in certain situations?

No — fit testing must follow the full, approved qualitative or quantitative protocols in 1910.134 App A and the requirements in 1910.134(f). 1915.1001 App C mandates compliance with those procedures; abbreviated or modified tests that do not meet the protocol are not acceptable for satisfying the annual and initial fit-test requirement.

  • Do not skip or shorten required exercises or steps from the approved protocol.
  • If using a new test device or method, ensure it is compliant with the standard before relying on it.

Under 1910.134(f), how should employers handle fit testing for employees who wear glasses or hearing protection?

Employers must fit test employees while wearing any eyewear or hearing protection that they will normally wear with the respirator, because these items can affect the face seal. 1910.134(f) and the protocols in 1910.134 App A account for interactions with other PPE.

  • During fit testing, include safety glasses, goggles, or hearing protection the worker will wear while using the respirator.
  • If the eyewear prevents a proper seal, consider alternative frames or respirator types that are compatible.

Under 29 CFR 1915.1001 App C, how should employers incorporate fit-testing into their written respiratory protection program?

Employers must include fit-testing procedures and schedules in their written respiratory protection program as required by 1910.134; 1915.1001 App C requires adherence to 1910.134(f) fit-test requirements and 1910.134 App A protocols.

  • The program must state who is responsible for fit testing, the methods used, recordkeeping procedures, and the schedule for initial and annual testing.
  • Include procedures for when fit testing must be repeated (e.g., facial changes, respirator model change).

Under 29 CFR 1915.1001 App C and 1910.134, can fit testing be done for workers who will only occasionally wear respirators?

Yes — any employee who may be required to use a tight-fitting respirator on the job must be fit tested, even if the use is occasional. 1915.1001 App C directs compliance with 1910.134(f), which covers all employees assigned respirators regardless of frequency of use.

  • Fit tests ensure protection whenever the respirator is needed — do not reserve fit tests only for regular users.
  • Maintain fit-test records for occasional users just as for regular users.

Under 29 CFR 1915.1001 App C, how does OSHA’s interpretation on oxygen-deficient atmospheres affect respirator selection and fit testing?

OSHA requires employers to follow the Respiratory Protection Standard for selecting respirators and considering oxygen-deficient atmospheres; if an atmosphere is oxygen deficient, employers must use respirators appropriate for IDLH or oxygen-deficient conditions and ensure those devices are fit tested where applicable. The OSHA interpretation on oxygen-deficient atmospheres notes that civilian employees covered by OSHA are subject to 1910.134 requirements, including IDLH considerations (see interpretation).

  • For IDLH or oxygen-deficient atmospheres, employers typically must provide supplied-air respirators or SCBAs and ensure users are trained, medically cleared, and fit tested where tight-fitting facepieces are used.
  • Consult 1910.134 and the interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-07-16 for applying the standard to such environments.