On September 26, 2019, the Occupational Safety and Health Administration issued a final rule providing employers with two new fit testing protocols (for quantitative fit testing) to ensure employees’ respirators fit properly.  The new protocols are:

  • The modified ambient aerosol condensation nuclei counter (CNC) qualitative fit testing for full-face piece and half-mask elastomeric respirators (EHFRs); and
  • Modified ambient aerosol CNC qualitative fit testing for filtering face piece respirators (i.e. N-95).

These tests are variations of the original OSHA-approved ambient aerosol CNC protocol.  Both require fewer and shorter test exercises, as well as a streamlined sampling sequence.  While it adds two new protocols, the rule does not require employers in general industries, shipyards, and construction to update or replace current fit testing methods.

In addition, Cal/OSHAis not obligated to adopt the additional fit testing protocols.  Further, it is unknown at this time whether or not Cal/OSHA will amend its current respirator requirements found in 8CCR5144 to include these new test protocols.  Nevertheless, Fed OSHA strongly encourages the adoption of the new protocols to provide employers with additional compliance options.  If you have any questions about compliance with OSHA regulations, including fit test requirements, feel free to contact The Cohen Group.

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