N95 Respirators and Respiratory Protection Programs
by Lee Slaton 10/29/2020
This blog post covers everything you need to know about N95 respirators and respiratory protection programs.
Here’s what you will learn by reading:
- Who is required to have a Respiratory Protection Program
- N95: mask or respirator?
- New infection and exposure control measures
- What to do when NIOSH-approved masks aren’t available
- Guidance on the respirator shortage
- Required aspects of the OSHA Respiratory Protection Program
- Medical evaluations
- Fit tests
If you would rather listen than read, check out our Respiratory Protection Program webinar.
First, who is required to have a mandatory Respiratory Protection Program?
Any entity that has employees who are either required to wear a respirator or who choose to wear a respirator voluntarily.
Are N95 masks classified as masks or respirators?
N95 “masks” are classified as respirators. Check out our blog to learn more about the difference between masks and respirators.
While it might sound like we’re splitting hairs, there is a huge difference in the efficiency of an N95 versus a surgical mask in protecting both the patient and staff.
An N95 respirator filters the airflow through it. A surgical mask allows most of the air breathed in and out (by the wearer) to go around it. Because, among other things, the filtering process of an N95 creates exertion to the wearer, OSHA requires a formal written Respiratory Protection Program be in place for any entity that requires the use of respirators, or even if the entities’ staff voluntarily wears them.
What are the new infection and exposure control measures?
Until the COVID-19 pandemic, N95s were a non-issue for dental practices.
But the new Texas State Board of Dental Examiners (TSBDE) Rule states, “Dental Health Care Personnel (DHCP) shall implement Transmission-Based Precautions, including N95 respirator masks, KN95 masks, or their substantial equivalent for all DHCP who will be within six (6) feet of any and all procedures likely to involve aerosols.”
This means a new level of infection and exposure control was created for dental practices to contend with. There’s a lot of fresh ground to plow here, but for today, we’ll just hit the high notes.
NIOSH-approved N95 respirators aren’t available. What now?
N95 masks, ahem, respirators, are incredibly hard to source right now. There are several agencies weighing in on the issue with regard to dental practices.
What if I can lay my hands on KN95 masks manufactured in another country, you say? Under normal conditions, OSHA requires that only NIOSH-approved N95s be utilized. However, because of the shortage of NIOSH-approved N95s, the FDA has granted a couple of Emergency Use Authorizations (EUA) during the COVID-19 pandemic that allow entities to purchase and utilize KN95s that are not NIOSH-approved.
What if my practice is still facing an N95 respirator shortage?
Well now, that opens up a whole new legal (according to the FDA) source of respirators, doesn’t it?
Even with the EUAs allowing the use of other N95 type of respirators, the supply chain is still falling woefully short in many locales.
Enter the strategies developed by the CDC for sterilizing and reusing N95 respirators—a practice that during normal times might see your license suspended. However, OSHA has issued a “Discretion in Enforcement when Considering an Employer’s Good Faith Efforts During the Coronavirus Disease 2019 (COVID-19) Pandemic” memorandum (among other things) that provides a modicum amount of cover for a practice owner.
Just be aware that the hazards surrounding re-use of personal protective equipment (PPE) haven’t disappeared. To the contrary, proper donning and doffing protocols for preventing cross-contamination are more important than ever, as this is a wildly contagious virus.
Check out our blog post for more information about OSHA guidance on the respirator shortage.
What are required components in OSHA’s Respiratory Protection Program?
“Okay, Lee, I’ve located the respirators I need. Give me the ‘CliffsNotes’ version of what I need to have for my practice to be legal and safe in the eyes of OSHA.”
Here they are:
- An OSHA Written Respiratory Program (which includes record keeping)
- An appointed Administrator of that program
- Training for all employees in the program
- Medical evaluations for all personnel who will be wearing a respirator, no matter whether they’re wearing them on a required or voluntary basis
- Fit tests for all personnel who are required to wear a respirator
Who can perform medical evaluations for employees that will wear respirators?
A licensed healthcare professional must perform the evaluations; which mean dentists can perform them. In Smart Training’s OSHA Respiratory Protection Program (dental version), we recommend a practice utilize its own dentist, which would save the cost of having an outside provider conduct the evaluations.
The medical evaluation is performed to provide assurance the wearer should be safe while using respirators. It’s accomplished by reviewing the medical evaluation questionnaire that must be completed by each respirator user. This questionnaire is found in Appendix C of the OSHA regulations that spell out the Respiratory Protection Program. Smart Training’s program provides a link where you can download the medical evaluation. The regulations governing the OSHA respiratory standard can be found in CFR 1910.134.
If the dentist conducting the medical evaluations sees no concerns, he or she simply signs off on the respective users. If the dentist notes any concerns stemming from a user’s answers, we recommend the dentist refer the user to a physician or other licensed healthcare professional with more experience in respirator issues.
Which users must have a fit test?
Any user who is required to wear a respirator. In Texas dental settings, the TSBDE rules set the standard by stating, “Dental health care personnel (DHCP) shall implement Transmission-Based Precautions, including N-95 respirator masks, KN-95 masks, or their substantial equivalent for all DHCP who will be within six (6) feet of any and all procedures likely to involve aerosols.”
For clarification’s sake, the TSBDE does not consider wearing a level-3 mask in conjunction with a face shield to be a “substantial equivalent” to an N95 respirator.
Who can perform a fit test?
Anyone who has been trained to perform a fit test. In our training module for respiratory protection program administrators, we include a 10-minute video on how to properly perform a fit test.
Where practical, we recommend practices perform fit tests in-house, as the cost savings can be substantial for larger practices. The big holdup in performing them internally stems from the lack of fit-testing kits, which are currently incredibly hard to source. That leaves the option of utilizing other firms that offer fit testing; namely occupational health clinics.
Most of those clinics offer walk-in testing. Some firms will come to your office to conduct the tests, if you have enough users to make it worth their while. Make sure to let them know you’re going to conduct the medical evaluations yourself, as this can save you $20-40 per user.
What is the difference between a fit test and a user seal check?
A fit test is something each required user of a respirator must complete before starting use of a respirator, and must complete annually thereafter. The annual requirement has been temporarily rescinded by OSHA.
A user seal check is a procedure every respirator user must conduct every time they don a respirator, to ensure it seals around their face correctly. Our training module for respiratory protection plan users includes a short video on how to properly perform a user seal check. Since conducting a user seal check requires the user place their hands against the outside of the respirator, using proper donning and doffing procedures is paramount to preventing cross-contamination.
Smart Training’s Respiratory Protection Program
If you need help writing and implementing your Respiratory Protection Program, Smart Training created a program specifically for healthcare and dental practices. Smart Training’s Platinum+ Dental Solution, Dental Essentials, and Complete Medical Compliance feature this OSHA Written Program.
The initial set up time for your respiratory protection program is about 15-20 minutes. Check out our blog to learn more about setting up your program on our learning software. These packages also feature respiratory training modules for both employees and administrators.
Request a demonstration here if you have none of the above plans and still want respiratory protection.