Respiratory protection requirements

Employers must provide respirators when engineering and work-practice controls cannot keep employee exposures below the permissible exposure limit (or when controls are infeasible), or when employees must enter IDLH or oxygen-deficient atmospheres. See Respiratory protection - 1926.103 which states the construction requirements are identical to 29 CFR 1910.134.

• IDLH or oxygen-deficient atmospheres require the highest-level respiratory protection; see OSHA's respiratory standard at 29 CFR 1910.134 and the OSHA letter clarifying that oxygen-deficient atmospheres are those below 19.5% oxygen and must be treated as immediately dangerous to life and health (IDLH) for civilian employees covered by OSHA: Oxygen-deficient atmospheres in HVAC.

Yes — employers must establish and maintain a written respiratory protection program when respirators are required. The construction rule at 1926.103 adopts the requirements of 29 CFR 1910.134, which requires a written program that covers respirator selection, medical evaluations, fit testing, training, maintenance, and recordkeeping.

• The written program must be appropriate to the workplace and implemented by a designated program administrator; see 29 CFR 1910.134.

The written program must include respirator selection, medical evaluation procedures, fit testing, proper use, maintenance and care, cleaning and storage, inspection and repair, training and information, and program evaluation. This follows the employer duties set out in 29 CFR 1910.134, which 1926.103 says also applies to construction.

Key items to document:

• How respirators are selected for specific hazards
• Medical evaluation process before fit testing or use
• Fit testing method and frequency
• Training content and frequency
• Cleaning, maintenance, and storage procedures
• Recordkeeping and program evaluation schedule

(See 29 CFR 1910.134 for these program element details.)

Yes — employers must fit test employees for tight-fitting respirators before initial use, whenever a different model or size is used, and at least annually thereafter. The construction rule points employers to 29 CFR 1910.134 for these fit-testing requirements.

• Both qualitative fit tests (QLFT) and quantitative fit tests (QNFT) are acceptable methods where authorized; follow the procedures and pass/fail criteria in 29 CFR 1910.134.
• Refit or additional tests are required whenever facial condition or equipment changes may affect the seal (e.g., dental work, significant weight change, or new facial hair).

An employee must receive a medical evaluation before fit testing or using a respirator to ensure they can safely wear one. 29 CFR 1910.134 (adopted by 1926.103) requires the medical evaluation and describes acceptable procedures (e.g., questionnaires or examinations) and follow-up when indicated.

• The evaluation determines whether the employee can tolerate the respirator’s physical burden (breathing resistance, heat, etc.).
• Employers must provide medical surveillance and retain medical records in accordance with the medical-record provisions of 29 CFR 1910.134.

No — workers whose facial hair interferes with the respirator facepiece seal or valve function must not wear tight-fitting respirators. 29 CFR 1910.134, which applies under 1926.103, requires that facial hair not interfere with the facepiece-to-face seal.

• Alternatives like loose-fitting powered air-purifying respirators (PAPRs) with hoods or helmets may be used when facial hair prevents a tight seal; follow selection and medical guidance in 29 CFR 1910.134.

If an employee voluntarily uses a respirator when not required, the employer must provide the employee with the information in Appendix D of 29 CFR 1910.134 and must ensure the respirator is clean, sanitary, and in good working order. The construction rule at 1926.103 points to 29 CFR 1910.134 for voluntary-use guidance.

• If the employer permits voluntary use of tight-fitting respirators, the employer generally must still provide a medical evaluation to ensure safe use; see 29 CFR 1910.134 for specifics.
• Document the voluntary-use policy and provide the Appendix D notice to the employee.

Employers must choose cartridges and filters that are certified for the specific contaminants and must implement a change-out schedule based on the cartridge or filter service life or other objective data to ensure protection. The respirator-selection and maintenance requirements are in 29 CFR 1910.134, which applies under 1926.103.

• Use manufacturer service-life data, end-of-service-life indicators (ESLIs), or conservative change-out schedules based on workplace conditions.
• For unknown or IDLH atmospheres, do not use air-purifying respirators — use atmosphere-supplying respirators such as SCBA; see 29 CFR 1910.134.

Yes — filtering facepiece respirators such as N95s can be used in construction when they are appropriate for the hazard, are NIOSH-certified, and are used within a complete respiratory protection program that includes fit testing, training, and medical evaluation when required. The construction rule at 1926.103 refers employers to 29 CFR 1910.134 for program requirements.

• For certain contaminants or high exposures an N95 may not provide adequate protection; select respirators using assigned protection factors and exposure data in 29 CFR 1910.134.

Employers must provide initial and annual training that covers why the respirator is necessary, limitations and capabilities, proper donning and doffing, seal checks, maintenance, storage, and emergency use. These training obligations come from 29 CFR 1910.134, which 1926.103 adopts for construction.

• Training must be understandable to the employee and include hands-on practice with the specific respirator model.
• Retrain when changes in the workplace, respirator type, or when employee performance indicates a need.

Employers must keep medical evaluation records and fit-testing records as required by 29 CFR 1910.134, which applies through 1926.103.

• Medical records must be retained per the timelines specified in 29 CFR 1910.134.
• Maintain fit test records showing employee name, respirator model, type of fit test, pass/fail, and date.
• Also keep training records and program evaluation documentation to demonstrate compliance.

In IDLH or oxygen-deficient atmospheres, employers must use an atmosphere-supplying respirator such as a self-contained breathing apparatus (SCBA) or a combination system providing equivalent protection; air-purifying respirators are not allowed. This requirement is in 29 CFR 1910.134, which 1926.103 adopts for construction.

• OSHA has clarified that oxygen-deficient atmospheres are those below 19.5% oxygen and that such atmospheres must be considered IDLH for covered civilian employees; see OSHA’s interpretation Oxygen-deficient atmospheres in HVAC.
• For emergency rescues in IDLH conditions, use properly trained personnel and SCBA or equivalent systems per 29 CFR 1910.134.

A user seal check is a quick check performed by the respirator wearer at each donning to verify the respirator is seated properly and the facepiece seals to the face; employees must perform a seal check every time they put on a tight-fitting respirator. The requirement to ensure proper fit and use comes from 29 CFR 1910.134, which 1926.103 adopts.

• Common seal checks include negative-pressure and positive-pressure checks using the respirator’s valves or coverable openings; follow the respirator manufacturer’s instructions and training provided under 29 CFR 1910.134.

Respirators can be shared only if they are properly cleaned, disinfected, and inspected between uses or issued in a way that avoids cross-contamination; employers must follow the cleaning and maintenance rules in 29 CFR 1910.134, which 1926.103 adopts.

• For filtering facepieces used voluntarily, sharing is discouraged; issued respirators should be assigned to one person when practicable.
• Document cleaning procedures and ensure replacement parts meet manufacturer specifications.

If there is a sudden release that creates an IDLH or unknown atmosphere, the employer must immediately implement emergency procedures and ensure affected workers use appropriate atmosphere-supplying respirators (for example, SCBA) and follow rescue and evacuation plans per 29 CFR 1910.134, which applies under 1926.103.

• Emergency response must include trained personnel, proper respirators, and measures to prevent reentry until the area is safe.
• Document the incident, medical evaluations, and any program changes as required by 29 CFR 1910.134.

Yes — PAPRs are allowed when they provide adequate protection for the hazard, are compatible with the task and environment, and the wearer has completed required medical evaluation, fit testing (if tight-fitting PAPR), and training as required by 29 CFR 1910.134, which 1926.103 adopts.

• Loose-fitting PAPRs do not require a tight face seal and may be an option for workers with facial hair that prevents a good seal with tight-fitting respirators; check the assigned protection factor (APF) to ensure adequate coverage.
• Ensure battery maintenance, filters, and manufacturer instructions are followed consistent with 29 CFR 1910.134.

Employers should use either a qualitative fit test (QLFT) or a quantitative fit test (QNFT) depending on the respirator type and program needs; both are acceptable when performed according to the procedures in 29 CFR 1910.134, adopted by 1926.103.

• QLFT is appropriate for many negative-pressure, half-facepiece respirators if the employee can detect the test agent.
• QNFT provides numeric fit-factor data and is required when an objective numeric result is needed or when an employer chooses that method; follow the fit-test protocols in 29 CFR 1910.134.

No — the respiratory protection requirements for construction under 1926.103 are identical to those in 29 CFR 1910.134. The construction standard explicitly notes the requirements are the same as the general industry rule.

• Employers in construction should follow the procedures, program elements, and recordkeeping requirements set out in 29 CFR 1910.134.

The employer must designate a qualified program administrator to implement the respiratory protection program and must regularly evaluate the program’s effectiveness, at least annually and whenever workplace changes suggest the program may be inadequate. These duties are specified in 29 CFR 1910.134, which applies under 1926.103.

• Program evaluation includes observing employees using respirators, checking training and fit-test records, and updating procedures when problems are found.

Employers must select respirators that provide adequate protection by comparing workplace airborne concentrations to the respirator’s assigned protection factor (APF); choose a respirator whose APF reduces exposure to a safe level. See 29 CFR 1910.134, which 1926.103 adopts.

• Use the APFs and assigned exposure limits to calculate whether a respirator provides sufficient protection for the specific contaminant and exposure scenario.
• When exposures are unknown, IDLH, or exceed the control capability, select atmosphere-supplying respirators as required by 29 CFR 1910.134.

Yes — escape-only respirators (for emergency escape) are permitted when provided for emergency use only, and employers must ensure they are NIOSH-certified, inspected, stored and maintained per 29 CFR 1910.134, adopted by 1926.103.

• Use escape-only respirators only for escape from hazardous atmospheres, not for regular work activities.
• Employees provided escape respirators must receive training on their use and limitations as required in 29 CFR 1910.134.

Respirators must be cleaned, disinfected, inspected, and stored to protect them from damage, contamination, and deformation; employers must follow the maintenance and storage procedures in 29 CFR 1910.134, which apply under 1926.103.

• Store respirators in sealed containers or cleanable lockers away from contaminated areas, direct sunlight, and extreme temperatures.
• Replace parts only with manufacturer-approved components and keep inspection records as part of the written program.