Unmasking OSHA’s top respiratory protection violations

If you’re not able to eliminate or reduce atmospheric hazards and employees must wear respirators, you’re covered by OSHA’s respiratory protection standard at 1910.134. Are you meeting OSHA’s requirements?

Most frequently cited violations of 1910.134

The top three violations in fiscal year 2024 were failure to provide medical evaluations, establish a written respiratory program, and ensure employees are fit tested.

Paragraph (e)(1). Provide medical evaluation, 557 violations. Before employees are fit tested or required to use a respirator in the workplace, the employer must provide a medical evaluation to determine employees’ ability to use a respirator.

The employer must identify a physician or other licensed healthcare professional to perform medical evaluations using the medical questionnaire found in Appendix C to 1910.134 or an initial medical examination that obtains the same information as the medical questionnaire. The medical evaluation must obtain the information requested by the questionnaire in Sections 1 and 2, part A of Appendix C of 1910.134.

The medical questionnaire and examinations must be administered confidentially during the employee’s normal working hours or at a time and place convenient to the employee. The medical questionnaire must be administered in a manner that ensures that the employee understands its content. Employees must have an opportunity to discuss the questionnaire and examination results with the healthcare provider.

Paragraph (c)(1). Establish written program, 374 violations. Where respirators are necessary to protect the health of the employee or whenever respirators are required by the employer, the employer must establish and implement a written respiratory protection program with worksite-specific procedures. The program must be updated as necessary to reflect changes in workplace conditions that affect respirator use. The program must include the following elements, as applicable:

• Procedures for selecting respirators for use in the workplace;
• Medical evaluations of employees required to use respirators;
• Fit testing procedures for tight-fitting respirators;
• Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations;
• Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators;
• Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators;
• Training of employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations;
• Training of employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance; and
• Procedures for regularly evaluating the effectiveness of the program.

Paragraph(f)(2). Ensure employees are fit tested, 339 violations. Employees using a tight-fitting facepiece respirator must be fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model, or make) is used, and at least annually after that. Paragraph (f) specifies the kinds of fit tests allowed, the procedures for conducting them, and how the results of the fit tests must be used.