RECORD ID D00-02-002

STANDARD NUMBER

INFORMATION DATE 02-09-2000

SUBJECT Clarification Of 29cfr1910.134 Requirement For Annual Fit-testing

QUESTION

The caller's query concerned 29CFR1910.134, Annual Requirement for Fit Testing. How should the term "annual" be interpreted? Is a worker due to be fit tested no later than 365 days after the initial fit test, or can the worker be tested within the month their original fit test expires?

REGULATORY REVIEW

The revised respirator standard, 29 CFR 1910.134(k)(5) states, "Retraining shall be administered annually." This wording is identical to the wording found in other OSHA standards that have been interpreted to mean within one month of the anniversary date. Such standards include 1910.120(e)(8), "shall receive eight hours of refresher training annually" and 1910.95(k)(2), "The training program shall be repeated annually for each employee included in the hearing conservation program." Therefore, it is appropriate to interpret the annual respirator refresher training requirement to mean within one month of the anniversary date. For example, retraining may take place up to a year and a month of the previous training.