Frequently Asked Questions About Respiratory Protection

Written Program

I got a different template from L&I but I don’t know how to fill it out, do I have the right template?

Here is the link to the WA L&I website where you can find their safety program templates: https://www.lni.wa.gov/safety-health/preventing-injuries-illnesses/create-a-safety-program/sample-safety-programs-plans

Once on this website, scroll down to the “Respiratory Protection” section and click on “Respirator Program Template for COVID-19 Prevention using Filtering Facepiece Respirators”.

Do not click on the link labeled “For employees required to wear respirators”, this template is designed for other industries and includes topics that do not apply to long-term care facilities.

How often do I need to review and update my written program?

It is recommended you review your written program at least every year like any other policy document. To keep up to date with changes that are happening in WA or the nation, subscribe to WA L&I notification system to get the latest changes.

Who should update the written program?

Updating the written program should be done by the Respirator Program Administrator.

Medical Evaluation

Who are the so called licensed medical professionals or licensed health care professionals?

Health professionals with a license in healthcare such as physician, physician assistants, nurse practitioners, registered nurses, etc.

Can LPN and RN provide medical evaluation? Only an MD? or can licensed nurses?

The WAC does not define the type of licensure that can review the medical evaluation. The person reviewing the medical evaluation should be working within their scope of practice. An MD, PA, ARPN are licensed providers who has a broader scope of practice that can make the determination to clear someone to use the N95. Whereas an RN or LPN will need to work within medical guidelines to make the determination for someone to use the N95 to stay within their scope of practice.

Not sure how we get medical clearance for staff members...not all have doctors/insurance.

The employer is required to provide access and pay for the medical evaluation for their workers. There are two issues with sending the person to their own doctor: 1) The person’s medical insurance will be billed, and potentially the balance of the charge will be paid by the worker. 2) The worker’s doctor may not be familiar with respirator use.

You can 1) Hire or contract with an occupational health clinic that does respirator medical evaluations. 2) If possible, use an in-house licensed health care professional or employee health personnel to provide the medical evaluations. 3) Find an online system to provide this service and designate a clinic to provide in person evaluations if it is necessary.

I would like to inquire how a new facility might get established with a licensed health care professional (LHCP)?

It's best to find a LHCP who has a background in safety/industrial exams, they will be familiar with the respirator medical evaluations. You could contract with a local clinic that does industrial exams, this would include the medical evaluation and if needed, a medical exam. There are online services that will review the medical evaluation and will let the employer know if the person needs to be seen in person.

If an employee is exempt from being fit tested based on the physician's recommendation, what do they do if they work in healthcare and the facility requires they wear an N95 the entire shift at all times?

If the employee is not cleared or approved to use the N95, they cannot be fit tested. In this situation, the employer can make an accommodation such as not assigning the employee to care for COVID-19 positive residents or if they are qualified to do another job that does not require the use of the N95, they can perform that job temporarily. If in this situation, the N95 is to be always worn when entering the building, the person will not be able to work because they are not able to be fit tested.

On the 3M letter of recommendation form, it says recertify in 5 years for some of our employees. But we were told they must be redone yearly. Is that state law? Or if their form says 5 years, do they not need to do it again for 5 years unless health or work conditions change?

You do not have to do medical evaluations yearly unless the Licensed Health Care Provider (LHCP) recommends it to be repeated in a year. If the LHCP clears a worker for 5-years, you can re-do it in 5-years unless the worker has health changes, a supervisor/RPA indicates a re-evaluation is needed, the worker experiences medical signs/symptoms while wearing a respirator, or there are changes in the work conditions.

What if the worker has asthma?

The medical evaluation asks questions that will screen for people with health conditions that would require further evaluation. If the person with asthma has been cleared to use the N95 and has problems when using the N95, such as difficulty breathing, they should re-take the medical evaluation. Or they should be seen in person to discuss with a licensed health care professional how the N95 is affecting their breathing.

What information needs to be on the medical evaluation letter of recommendation?

The worker’s name, the date the evaluation was done, whether or not the worker is medically able to use the respirator, any limitations the worker may have while using the N95, when the next medical evaluation will need to be done, and a statement that the worker has been given a copy of the recommendation.

What is job accommodation?

A job accommodation provides the worker with the opportunity to continue working but doing tasks that are not in their usual job duties if the person is qualified to do the alternative tasks. An example is if the person cannot be fit tested to the N95 and their job is to provide assistance to residents/patients, if reasonable, they can be assigned to care for residents/patients that are not in isolation or quarantine.

Fit Testing

Am I doing a valid fit test?

Remember, it is the facility’s responsibility to be sure the fit testers are performing a valid fit test. You can use the checklist to evaluate fit testers. Send completed checklists to the facility’s Respiratory Program Administrator.

Can I fit test more than one person at a time?

DOH recommends fit testing no more than 2 people at a time for LTC facilities. It is possible to fit test more than one person at a time, but it takes time and practice to do this and still provide a valid fit test to all that is being fit tested.

How long does it take to fit test someone?

Allow 15-30 minutes per fit test. If the worker being fit tested is new to using the N95, or they are being fit tested due to a physical change, expect that it may take longer to complete a valid fit test.

What do I need to have in place before fit testing?

Facility written respirator program – your policy or procedure for respirator use
Employee N95 user Training – to train your staff on respirator use
Space
- A room large enough to hold the trainers and the staff comfortably, and away from distractions.
- Tables and chairs
- Trash cans
- Water, cups, and napkins for the staff
- A sink in the room or a bathroom nearby
Paperwork
- Medical evaluation letter of recommendation for each person being fit tested. These need to be current and must indicate the person has clearance to wear a respirator.
- Blank fit test record forms
- If the person has been fit tested in the past, it may be helpful to have their previous fit test record on hand.
Printed handouts that may be helpful:
- DOH – Reminder sheet
- List of exercises
- Rainbow passage
- CDC – Acceptable facial hair

Facial Hair

Not for a tight-fitting respirator. You may want to consider a loose-fitting respirator such as a powered air-purifying respirator (PAPR) or a controlled air-purifying respirator (CAPR).

Worker Training

What kind of training do I need to do?

For the staff that needs to use the N95, they need to be trained on obligations and responsibilities for both the employer and the worker, why it is necessary to use the N95, how to use the N95, how it works (what it can and cannot do), storage of the N95, what to do in case of an emergency, and medical signs and symptoms that can change the effectiveness of the N95 to protect the worker.

For the person learning how to do a fit test, they will need to have a general understanding of their respirator program, have solid knowledge of the training the staff needs to have for N95 use, and train in how to do a valid fit test according to WA L&I.

How do I get a certificate to show I know how to do a fit test?

Currently, there is no certification that is required to conduct your own fit testing on your staff. The employer is required to be sure the person doing the fit testing is doing it correctly. An employer can do this by using the DOH Evaluating the Fit Tester checklist to be sure all aspects of doing a valid fit test is being done.

Record Keeping

What documents do we need to keep?

The current fit test record. It will need to be renewed yearly.
The current training record. It will need to be renewed yearly.
The current medical evaluation letter of recommendation. It will need to be renewed as indicated by the LHCP.
Updated written respirator program.

Program Evaluation

What do I need to do to evaluate my respirator program?

Talk with employees who wear respirators to get their feedback about their respirators – how they fit, do they feel they are adequately protecting them, do they notice any difficulties in breathing while wearing them, etc.
Periodically check employee job duties for changes that may require respirators other than a disposable filtering facepiece respirator.
Have staff who supervise respirator users do daily checks to ensure proper use, storage, and replacement.

Detecting the Solution

What if someone has lost their sense of smell or taste and they cannot taste the spray?

If they do not taste the solution at 30 sprays, you can try a different solution, for example: if they did not taste sweet solution, try using the bitter solution. If they do not taste either the bitter or the sweet solutions, you could wait a week and try it again. If the person still does not taste the solution, you would need to try one of the following: 1) Quantitative fit test method, 2) Powered air-purifying respirator (PAPR, CAPR), or 3) Consider a job accommodation (such that staff are not assigned to residents in isolation/quarantine for COVID-19).

What if you have a worker that had COVID and they can barely taste the solution, can you still fit test them?

If they can taste the solution (at or before 30 sprays of the sensitivity test solution), you can proceed with the fit test. See the answer above.

What do you do if the person says they feel it or taste it in the back of their throat?

If they feel or taste it in their throat, they are probably breathing through their nose and the seal was not adequate to keep the fit test solution out of their breathing space. You will need to stop the fit testing and have the person try another N95. Throughout the fit test, frequently remind them to breathe through their mouth so they will be able to taste the solution if the respirator seal breaks.

What is the purpose of having the user wear the N95 for 5 minutes prior to starting the fit test?

The purpose of the 5-minute wear time is to:

Be sure the respirator is comfortable for the wearer and that the person can tolerate it being on their face. It needs to be comfortable for the wearer to use it when it is necessary.
Let the N95 'seat' on the person’s face and adjust it if it does not fit well. This period will allow the wearer to get adjusted to how it sits on their face and the effort of breathing.

The 5-minute wait time applies to every new N95 the person is getting fit tested to.

Does the person need to have the N95 on and be in the hood for 5 minutes?

No, the hood should not be on during the 5-minute waiting period. The 5-minute waiting period is to see if the N95 is comfortable on the person's face.

What if someone has to have a head covering?

It is recommended the straps be under the head coverings. But there are situations where that is very inconvenient or not feasible. In these cases, it is recommended that the fit testing is done the way the N95 would be worn. If the person uses a hair covering for surgery, they will need to be fit tested with the hair covering on. The exercises required to be done during the fit testing are to simulate activities of work. If the N95 slips and breaks the seal, it would be best to catch it during the fit testing.

What happens if someone fails a fit test?

If the person can taste the solution during the fit test, remove the hood, have them doff the respirator, rinse their mouth if they want to, and wipe their lips. Have the person choose another N95 to get fit tested to.

What happens if someone doesn’t find a mask that fits them?

If the N95s you carry do not fit the employee, you have a few choices:

Provide an accommodation, for example, change their assignment to care for residents who are not in isolation/quarantine precautions for COVID-19.
Obtain a different type of N95 in a minimum quantity. If you have the round type of N95 such as the BYD or 3M 1680, you could try a duckbill type.
Provide a powered air purifying respirator or PAPR. This type of respirator does not require fit testing.

N95

Where can we get more N95s?: Purchase respirators from reputable distributors by checking or verifying with the manufacturer for an authorized distributor. Be sure to purchase respirators approved by the National Institute for Occupational Safety and Health (NIOSH). Respirator filters must bear the NIOSH stamp and approval number. (Link: https://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/default.html )
Can we use the N95 beyond the expiration date?: Some N95 manufacturers have extended their expiration date. Please check with the manufacturer of the N95 you are using to see if they extended the expiration date.
Do we throw away the N95s with the TC number containing “PH” that were manufactured during the pandemic?: You can use those for source control. They are no longer approved to be used in an isolation or quarantine room.