An Outline of OSHA Guidelines for Dealing with the N95 Shortage


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Content provided by Mike Kay, Director of Resource Safety Services (RSS)
RSS is an education and training division of Safety Products Inc


Dealing with the N95 shortage.  In these unprecedented times of COVID-19, the industrial worker is finding it more difficult to access disposable N95 respirators.  Rightfully so, as we must arm our front line healthcare workers with PPE to protect them as they fight for the lives of our loved ones and friends.  However, the industrial worker thankfully is still doing just that… working.  OSHA has recognized that and has issued an enforcement memo regarding the use of the disposable N95 respirator to make it feasible and flexible for employers to still keep their workers protected during this time of shortage.

A couple of things they mention here is the ability to reuse the respirator that you currently have, and the other is using disposable respirators where the expiration date from the manufacturer has passed.  Here are a few things you must know if you’re going to enact this policy into your program:

Reusing a Disposable Respirator
For a reusable respirator you have to make sure that the physical structure of the respirator is still intact.  It cannot be contaminated.  What do we mean by that?  It cannot have excessive soiling, paint droplets, oils and potentially even blood.  If any of those exist, then you do not have the ability to reuse the respirator because its functionality is now gone.  

Expired Disposable Respirators
When it comes to using respirators that have been expired, the only thing you have to do is make sure that you still use them in accordance to the manufacturer’s recommendations.  That means proper donning and doffing of the respirator, and they would like you to also look at alternative respirators use.  Examples of this might be using an elastomer reusable half face, or a full face respirator, or potentially a PAPR system.  In addition, there are other filters such as N99, or P100 or P99, so try to get those as well first if you can.

Written Respiratory Protection Program
If your employees are using a respirator, then you must have a written respiratory protection program.  This new enforcement memo states that you must re-evaluate this program and look at new administrative and engineering controls to try and eliminate your respirator use.  Try moving your operation outdoors into the fresh air or increase ventilation.  These are some engineering options you can execute to help.  In addition, use wet tools to knock down particulates in your environment.  When you do this, you must update these policies and procedures into your written respiratory protection program.  Otherwise, you could be fined for not doing so.  

View the OSHA Enforcement Memo here!

In Summary
1.  You can now use disposable N95 respirators as long as they are physically in good condition and not soiled.

2.  Expired disposable N95 respirators can be used as long as it’s in compliance with the manufacturer’s
 recommendations with proper donning and doffing.

3.  Revise your written respiratory protection program to include any policy and procedure changes that reference reused or expired respirators or any changes in your operation from engineering or administrative controls.

Your Challenge
If you haven’t yet, go back and look at your written respiratory protection program and make the changes that you need.  Re-evaluate your workspace to see if you can engineer it out, but make sure that all of your employees that use these respirators, or reuse them, understand the limitations.  The N95 shortage may continue, even while work increases.  Let’s work together to make America safe!

View another of our popular blog posts:  5 Factors that Can Lead to Dehydration

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