Since I was able to conduct my very first fit test, I was taught that the Qualitative method was ONLY permitted when the user was wearing an Air Purifying Respirator (APR) which needed a fit factor of 100 or less.  When I read 1910.134(f)(6), that is exactly how I read it today…  QLFT may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less.  So what in the heck is OSHA up to with the 2008 revisions of the CPL?

1910.134(f)(6) QLFT may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less.   Sounds pretty straight forward!  But apparently to OSHA it means something else.

I can remember working in the Physical Plant Safety Office at Murray State.  My boss asked me if I could do fit testing since I was a firefighter and lived in an SCBA.  Heck I did not even know what fit testing was.  Being a firefighter, all we wore were SCBA’s (positive-pressure) and before 1998 these types of respirators were exempt from fit testing.  So my boss begins to train me in how to do Qualitative Fit Testing (QLFT) and he was VERY CLEAR that I was ONLY to fit test certain employees with ½ mask APRs.  I inquired why, and one thing about my boss at the time he was VERY THOROUGH in explaining the “why’s” of safety rather than just saying “because that what OSHA requires”.  Jeff went into a 15 minute history of fit testing and how the QLFT method had not been validated for those users needing a fit factor over 100.  I also learned about OSHA’s compliance directives and NIOSH’s Respiratory Decision Logic book that day.

So from that day in 1991 I have always followed that rule.  I have even been told during many VPP assessments that emergency responders who are called on to enter IDLH atmospheres, in which the ONLY acceptable respirator is a SAR w/backup or an SCBA (both types must be in pressure-demand mode), must be fit tested using the Quantitative Fit Testing Method (QNFT).  A SAR/SCBA in pressure-demand mode is a positive pressure respirator that requires a fit factor of 500 or higher.  So one could logically deduct that since an emergency responder wears an SCBA/SAR requiring a fit factor of 500 or more AND it is a positive pressure respirator that 1910.134(f)(6) would eliminate the QLFT method.

Where is my logic wrong?  Anyone, please explain this to me.

If we turn to OSHA Compliance Directive for Respirators we can turn to section G – Fit Testing and they start off sounding as if they are going to support my logic.  But then things take a dramatic turn!  The CPL even states that the reason for (f)(6) is that “existing evidence only validates the QLFT protocols listed in Appendix A to identify respirators that achieve a fit factor of 100”.  Sound familiar?  It then goes on to state… “For greater concentrations, Quantitative Fit-Testing (QNFT) must be used.” I have always assumed that we could use QLFT to fit test SAR/SCBA’s when the user is wearing the respirator in non-IDLH atmospheres and where they only need a fit factor of less than 100.  But the first two sentences support (f)(6) and my training, but then OSHA states For all positive pressure, atmosphere-supplying respirators, either qualitative or quantitative fit testing may be used. Go figure!

Here is the CPL wording in full and Table 1…

Qualitative Fit-Testing (QLFT) may be used to fit test negative pressure air-purifying respirators, if they will only be used in atmospheres less than ten times the PEL, since existing evidence only validates the QLFT protocols listed in Appendix A to identify respirators that achieve a fit factor of 100. For greater concentrations, Quantitative Fit-Testing (QNFT) must be used. When quantitative fit-testing is used, all full-facepiece respirators must meet or exceed a fit factor of 500, while quarter - and half-mask respirators must meet or exceed 100. For all positive pressure, atmosphere-supplying respirators, either qualitative or quantitative fit testing may be used. While atmosphere-supplying respirators are fit-tested in the negative pressure mode, these respirators are most often used as positive pressure respirators in the workplace. Positive pressure atmosphere-supplying respirators that pass the QLFT or QNFT fit test may be used at the higher protection factors assigned these respirators. See Table 1 for a summary.

There is also a 1999 LOI that sates…

Your second concern relates to paragraph (f)(6), which states that "Qualitative Fit-Testing (QLFT) may only be used to fit test negative pressure air-purifying respirators that must achieve a fit factor of 100 or less." OSHA believes that existing evidence validates the use of qualitative fit-testing for full facepieces on negative pressure respirators as well as on SCBA's.

Click Here to read OSHA’s Fit Testing e-tool, which states…

The relative workplace exposure level determines what constitutes an acceptable fit and which fit test procedure is required. For negative pressure air purifying respirators, users may rely on either a qualitative or a quantitative fit test procedure for exposure levels less than 10 times the occupational exposure limit. Exposure levels greater than 10 times the occupational exposure limit must utilize a quantitative fit test procedure for these respirators. Fit testing of tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators shall be accomplished by performing quantitative or qualitative fit testing in the negative pressure mode.

So maybe our interpretation of what is written in (f)(6) is correct, but it is out dated and OSHA is no longer enforcing it.

So I went to NIOSH to seek the answer and this is what I found…

The QLFT method has not been validated because of one simple reason – Intraspecies Variation.  Simply put, some of us are very sensitive to the QLFT testing agents and some of us are not.  But almost everyone is sensitive at levels of 1/100^th  of the test agents; however, when we get to 1/500^th of the test agent the number of people able to respond to the test agents is very small.  This is why OSHA stated in the CPL that using the QLFT method has not been validated for a fit factor over 100.  So why would OSHA revise the standard in 1998 and include (f)(6) and state their concerns in the CPL and e-tool, and then turn around and allow QLFT for respirators needing a fit factor higher than 100?

I think the answer lies in some studies done by the CDC/NIOSH after the revision of 1910.134 in 1998.  Reading the data from these studies makes me think maybe I should get my CIH certification, but then I woke up and realized that will never happen!  But I am assuming that somewhere in these Workplace Protection Factor (WPF) studies lies the data that somehow validated QLFT above and beyond a fit factor of 100.  Although I was not able to satisfy my concerns in reviewing some of the data from these studies I am guessing I will have to have faith in those much smarter than I in respiratory protection.

But I want to close with this comment… OSHA may not be enforcing (f)(6), but it is there and it was put there for a reason.  I know how much trouble it is for OSHA to revise their standards so maybe it is just easier to not enforce (f)(6) than to remove it.  Until someone smarter than me can explain to be how the human race has improved our sensitivity to the QLFT test agents in the past 12 years, I for one will continue to push QNFT for those emergency responders I train and work with.  I know that I will never accept anything but a QNFT for me and my team and I hope I have convinced one or two of you to join me in taking our respiratory protection to the next level by not accepting anything less than QNFT for our emergency responders.