Respiratory Protection Program Requirements

Posted on September 23, 2021 by Kari Everson

As COVID-19 crashed into our lives, so did the awareness of and need for respiratory protection programs in long-term care settings. Respiratory protection programs are designed to ensure all employees are protected from respiratory hazards, such as the SARS-CoV-2 pathogen.

According to 29 Code of Federal Regulations (CFR) 1910.134, employers must write and maintain individualized, written respiratory protection programs for their employees if those employees are required to use respirators in the course of their job duties. For quarantine and isolation measures relating to COVID-19, N95 masks or higher-level respirators are part of the personal protective equipment (PPE) for transmission-based precautions. Respiratory protection programs have multiple required components, including but not limited to fit testing, a medical evaluation, policy and procedure, work hazard identification, respirator selection and training, and documentation/record keeping of respiratory protection activities. 

Medical Evaluations
Medical evaluations must be completed by a physician or physician extender, such as a nurse practitioner or physician's assistant. According to the Minnesota Board of Nursing, RNs that are not nurse practitioners may not complete the medical evaluation in Minnesota. To obtain medical evaluations, employees may see their primary care providers and bring a copy of their medical evaluation form. If you have an arrangement or contract with an occupational health clinic, they may use that service. In some settings, the medical director of primary care provider service will complete medical evaluations for staff. OSHA has sample medical evaluations and other tools online, and LeadingAge Minnesota has a respiratory protection program template on our Coronavirus website under Personal Protective Equipment.

Fit Testing v. Seal Checks
In 2020, OSHA issued an emergency standard that allowed for a seal check each time a respirator was donned instead of fit testing all staff because access to respirators and fit testing equipment was extremely limited. In the past few months, OSHA has repealed that emergency standard and fit testing is again a required component of all respiratory protection programs. A seal check may be used if the organization can implement a mini-respiratory protection program, essentially meaning that if a respirator is used outside of a quarantine or isolation area in place of a source control mask, fit testing is not required to occur. However, for all other respirator uses, a fit test is required annually.

Fit testing kits are available for purchase and more readily available than last year. Nurses can learn to fit test and can train others to fit test staff. Each different brand of respirator must be fit tested individually since the sizing may differ between brands. Because the availability of fit testing in the community through hospital partners and public health partners remains difficult, obtaining a fit testing kit and training nurses to fit test is a good option for ongoing maintenance of your respiratory protection program.

What should your organization have in place?
The following are essential components to have in place for your respiratory protection program:

• A written respiratory protection program
• Medical evaluations on file for staff
• Fit testing documentation
• Policies for the use of N95 or high-er level respirators
• Documentation of training for staff and return demonstrations for donning / doffing respirators

Respirators are the standard for PPE use in isolation and quarantine use. Our settings used face-masks as replacements while supplies were critically short; however, now that they are more readily available, regulatory agencies expect to see the use of N95s and good documentation if the organization cannot obtain N95s or higher level respirators. For additional information on PPE contingency and crisis capacity information, please reference the CDC information.

If you have further questions on respiratory protection programs, please contact Kari Everson.