Comment from Clements, Barry M.; PCM Construction

Our concern is with regards to the way the standards are written for the Respiratory Protection Program (1910.134(c)). The type of work that we perform only requires that we use a Filtering Facepiece, specifically we use an N-95 respirator. This is a filtering facepiece using two straps and an adjustable nose-piece securing the respirator to the users face. 1910.134(c)(1)(iii) states that a fit testing procedure is required. Our company called several agencies who perform fit tests and were told that the test could not be done for the N-95. This is due to the fact that a tight seal is not attainable such as with the higher end air supplying respirators. If a tight fit was attained, the oxygen level inside the mask would be at a deadly, or serious, level. A question has also been proposed within our company regarding whether an employee needs to be medically evaluated for the use of an N-95. It appears that the current requirements under 1910.134(c) were primarily written for the air-supplying type of respirators and perhaps this standard needs to be adjusted to reflect those sectors of industry that only use the N-95 respirators. Thank you for your time. Barry M Clements, PCM Construction