Who needs OSHA respiratory protection training?

Every employee who is required to use a respirator at work, by the standard or by the employer. Employees who use one voluntarily must be given the basic information in Appendix D.

How often is respirator training required?

Before the employee is required to use a respirator, then annually. Retraining is also required when changes in the workplace or respirator make earlier training obsolete, or when the employee's knowledge or use shows gaps.

Can respirator training and fit testing be done online?

Knowledge content can be delivered online, but it does not replace fit testing or a hands-on demonstration. Fit testing is a separate test that must be done before first use and at least annually.

OSHA respiratory protection training requirements

Who needs the training

Paragraph (k) applies to employees who are required to use a respirator, by the standard or by the employer. The standard covers general industry, shipyards, marine terminals, longshoring and construction. It applies where a respirator is necessary to protect the health of the employee, for example in healthcare, painting and coating, abatement, agriculture, laboratories and manufacturing.

Training is provided at no cost to the employee, as are the respirator and the medical evaluation, under (c)(4).

Employees who wear a respirator when it is not required are voluntary users. Under (k)(6) they must be given the basic advisory information in Appendix D, in any written or oral format. Voluntary users of anything other than filtering facepieces (dust masks) also fall under the written program elements for medical ability to use the respirator and for cleaning, storage and maintenance, per (c)(2)(ii).

What the training must cover

Paragraph (k)(1) says the employer must ensure each employee can demonstrate knowledge of at least these seven items. The training must be comprehensive, understandable and recur annually, and more often if necessary.

Why the respirator is necessary, and how improper fit, usage or maintenance can compromise its protection
The limitations and capabilities of the respirator
How to use the respirator effectively in emergencies, including when it malfunctions
How to inspect, put on and remove, use, and check the seals of the respirator
The procedures for maintenance and storage
How to recognise medical signs and symptoms that may limit or prevent effective use
The general requirements of the standard

Under (g)(1)(iii), employees must perform a user seal check each time they put on a tight-fitting respirator. Under (g)(1)(i), the employer must not let anyone wear a tight-fitting facepiece if facial hair comes between the sealing surface and the face, or interferes with valve function.

How often

Training must be given before the employee is required to use a respirator in the workplace, (k)(3). A new employee who can be shown to have received training covering (k)(1)(i) to (vii) within the last 12 months does not have to repeat it, but must still be able to demonstrate knowledge of those items. That earlier training must be repeated no later than 12 months after it was given, (k)(4).

Retraining is required every year, and also when:

Changes in the workplace or the type of respirator make earlier training obsolete
Gaps in the employee's knowledge or use of the respirator show they have not kept the understanding or skill
Any other situation arises where retraining appears necessary for safe use

Training is not the whole requirement

Two other steps sit alongside training, and a course does not replace either.

Medical evaluation under (e): the employer must provide a medical evaluation to determine the employee's ability to use a respirator before the employee is fit tested or required to use it. A physician or other licensed health care professional performs it.
Fit testing under (f): an employee using a tight-fitting facepiece respirator must pass a qualitative or quantitative fit test before first use, whenever a different facepiece (size, style, model or make) is used, and at least annually. An additional test is needed when changes to the employee's physical condition could affect fit, such as facial scarring, dental changes, cosmetic surgery or an obvious change in body weight.

Can it be done online?

Part of it, yes. The standard does not name a delivery method. It requires training that is comprehensive and understandable, with each employee able to demonstrate knowledge of the (k)(1) items. Employees cannot show they can inspect, put on, use and seal check a respirator by clicking through a screen.

Online training does not replace fit testing or a hands-on demonstration. Fit testing under (f) is a separate hands-on test using an OSHA-accepted protocol, and Appendix A states that the instruction given during fit testing is only a review and may not count as the employee's formal training. A practical approach is online knowledge content, followed by a supervised demonstration of inspection, donning, user seal check and removal, with a person available to answer questions.

Who can deliver it

The standard sets no trainer certification. It does require a program administrator who is qualified by training or experience that matches the complexity of the program, under (c)(3). That person oversees the program and the evaluation of how well it works. Whoever delivers the training should know your written respiratory protection program, the respirators you actually issue and the hazards on your sites.

What records to keep

Paragraph (m) requires three kinds of written information. Fit test records must show the employee, the type of test, the make, model, style and size of respirator, the date, and the pass or fail result or fit factor. They are kept until the next fit test. Medical evaluation records follow 29 CFR 1910.1020. A written copy of the current respirator program must also be kept.

Paragraph (m) does not list training records, but the written program must cover training under (c)(1)(vii) and (viii). Keeping a record of who was trained and when is a sensible way to show that.