How OSHA Inspectors Think: Respirator Fit Testing

How OSHA Inspectors Think: Respirator Fit Testing

Jill James

Jill James

Chief Safety Officer

Jill James brings an unrivaled perspective on risk, regulation and liability. With 14 years of experience as a Senior OSHA Safety Investigator with the State of Minnesota, and nearly a decade in the private sector as a safety program manager, Jill is a passionate advocate for training ROI.

Respirator Fit Testing

Have employees been medically evaluated to ensure they are physiologically able to wear a respirator? 1910.134(e)(1)

Commonly called “fit testing”—it’s a compliance obligation with serious implications for your workforce.

Pro Tip: Ensure the initial evaluation conducted by a PLHCP (Physician or other Licensed Health Care Provider) includes the questions outlined in mandatory Appendix C of 1910.134, titled: OSHA Respirator Medical Evaluation Questionnaire. 

The questionnaire along with any examinations must be administered confidentially & during the employee's normal working hours.

Medical evaluation criteria & frequency is found in 1910.134(e)(1)-(7)(iv)

Permissible Exposure Limits

Are your employees subject to noise over the permissible exposure limit (PEL)? Do you know the permissible exposure limit? And do you have a paper trail showing you’ve done noise monitoring and addressed administrative or engineering controls if over the limit?

As an investigator, those are the questions I’d ask to start. If the answers were “no”, and after I’d done my own noise monitoring, I’d begin by citing 1910.95(b)(1).

Permissible exposure limits are set and defined by OSHA and other occupational safety and health partner agencies and apply to chemicals, materials, noxious substances, gases, and noise.

For a complete list of PELs.

Browse the tables to find the limits for substances that present an exposure risk in your working environments.

Pro Tip: If you are standing arm’s length away from someone and must raise your voice in order to be heard, you are likely around the 90-decibel/8-HR action level. That’s not scientific, but an old, tested, rule of thumb. 

Fatality Reporting

Report all deaths which happen at work to OSHA within the required 8-hour window: 1904.39(a)-(b)(11)

There’s an exception for deaths resulting from motor vehicle incidents, 1904.39(b)(3)-(4). 

However, you must report deaths even when you are nearly certain they aren’t work-related; for example, a heart attack or death by suicide.

Years after my work with OSHA, I was in a new position and meeting a location manager for the first time. He and I worked in different states. “Did you hear about the death…employee died of a heart attack while on break, sitting in our vehicle, at a job site?’ 

I hadn’t heard of it and it wasn’t reported to OSHA. I knew we were in violation; it had been months.

But I reported it. We were inspected, fined, and I negotiated a settlement. I’ve also coached employers through reporting apparent death-by-suicide occurring at work. 

Pro-Tip: Workplace deaths, regardless of cause, are traumatic for employees, responders, and you. Engage professional services to care for the hearts and minds of all survivors.

Cable Damage

Arc welding and cutting...have you ever seen cuts in welding cables? Me too. So many times, I couldn’t hazard a guess as to how many. 

Here’s what I cited: 1910.254(d)(9)(iii)

Pro Tip: When you are doing audits, examine the entire length of welding cables; look for cuts in the outer insulation and look for tape. Electrical tape or duct tape is often used to cover cuts in the insulation; unwrap the tape and look for cuts. Electrical tape, duct tape, and other tapes cannot be used as a repair as they do not offer the same insulative qualities as the original insulation.