RECORD ID D99-01-011 Precedented

STANDARD NUMBER

INFORMATION DATE 02-01-1999

SUBJECT Respirator Fit Testing Procedure Requirements

QUESTION

In reference to the test exercises given in Appendix A, "Fit Testing Procedures" of 29 CFR 1910.134, paragraph(A)(14)(a) calls for the following: "(A)(14)(a)(3) Turning head side to side. Standing in place, the subject shall slowly turn his/her head from side to side between the extreme positions on each side. The head shall be held at each extreme momentarily so the subject can inhale at each side." "(A)(14)(a)(4) Moving head up and down. Standing in place, the subject shall slowly move his/her head up and down. The subject shall be instructed to inhale in the up position (i.e., when looking toward the ceiling)." What is the definition of EXTREME as it is referred to in this Appendix? What if a subject has limited movement on the "side to side" exercise and the "up and down" exercise? Does this preclude him from mask fitting after 15 years of respirator use?

REGULATORY REVIEW

A definition of the word "extreme" is not given in the text nor in the appendices of the OSHA Respiratory Protection Standard found at 29 CFR 1910.134. Therefore, the definition of "extreme" can be taken from a dictionary of the English language. The phrase found in Appendix A under Paragraph (A)(14)(a)(3), "…the subject shall slowly turn his/her head from side to side between the extreme positions on each side," is most accurately interpreted to mean that the head should be turned to the limit of the range-of-motion in each direction by the person undergoing the fit test. OSHA does not explicitly prohibit respirator use by an employee who may have a limited range of head motion in either the side-to-side or up-and-down directions. However, the underlying reason for the limitation in range of head motion must be assessed by a physician or other licensed health care professional (PLHCP), as required in the Standard as part of the mandatory medical evaluation procedure in Paragraph (e)(2): "(e)(2)(i) The employer shall identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire." "(e)(2)(ii) The medical evaluation shall obtain the information requested by the questionnaire in Sections 1 and 2, Part A of Appendix C of this section." Appendix C of 1910.134 is mandatory, and contains questions which are designed to reveal potential medical limitations that need to be considered by the PLHCP when arriving at a recommendation regarding an employee’s ability to wear a respirator. Questions 15e and 15f in Part A, Section 2 of Appendix C pertain specifically to an employee’s ability to move their head: "15. Do you currently have any of the following musculoskeletal problems?" "…e. Difficulty fully moving your head up or down: Yes/No f. Difficulty fully moving your head side to side: Yes/No…" However, these particular questions are part of a series of questions that must be answered only if the employee has been selected to use either a full-facepiece respirator or a self-contained breathing apparatus (SCBA). For employees who use other types of respirators, these questions are voluntary; most likely because a head range-of-motion limitation is not a condition considered to be medically disqualifying for these other types of respirators.