By Brad Sant, senior vice president of safety & education, ARTBA

The Occupational Safety and Health Administration (OSHA) April 3 issued interim enforcement guidance in response to shortages of disposable N95 filtering facepiece respirators (N95 FFRs) due to the COVID-19 pandemic. This interim guidance allows for variances from the OSHA standards regarding use of such respirators after employers have made a “good faith” effort to obtain them. The guidance includes the following:

  • Employers may consider using alternative classes of NIOSH approved respirators, including elastomeric respirators or powered, air-purifying respirators;
  • If alternatives are not available or may create a greater hazard,  employers may:
    • extend the use of respirators for a longer period by the original user, or
    • reuse of N95 FFRs by the original user with training and precautions in place to prevent exposure to harmful substances when re-donning or doffing the masks, or
    • use N95 FFRs that were approved but have since passed the manufacturer’s recommended shelf life, under specified conditions.

Under all conditions regarding re-use and extended use of N95 FFRs, employers must examine the respirator to ensure it retains its functional and structural integrity and can pass a seal check.  Employees who are asked to use such masks must be trained in:

  • donning and doffing the masks to prevent contamination; and
  • inspecting the masks to ensure they retain structural and functional integrity.

This interim guidance will take effect immediately and remain in effect until further notice. This guidance is intended to be time-limited to the current public health crisis. For more detailed information, please refer to OSHA’s interim enforcement guidance.