New Respirator Fit-Testing Protocol Proposed

The Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rulemaking (NPRM) for a new Abbreviated Bitrex Qualitative Fit-Testing


The Occupational Safety and Health Administration (OSHA) published a Notice of Proposed Rulemaking (NPRM) for a new Abbreviated Bitrex Qualitative Fit-Testing (ABQLFT) protocol. Applicable to both construction and general industry regulations, this proposal would make fit-testing procedures easier and faster. The only concrete producers to be affected are those employing personnel subject to respirator use and, therefore, in need of fit testing.

The proposed rule would add ABQLFT as an alternative to four existing OSHA-approved qualitative fit-test protocols, providing a new fit-test method of shorter exercise duration than that currently in use. ABQLFT listed in the Respiratory Protection standard’s existing OSHA-approved Bitrex fit-test protocol would reduce the duration for each of the seven fit-test exercises from one minute to 15 seconds.

The agency is accepting public comments until Feb. 25, 2008. Interested parties may submit comments at; by sending three copies to the OSHA Docket Office, Room N-2625, U.S. Department of Labor, 200 Constitution Ave., N.W., Washington, D.C. 20210, tel.: 202/693-2350; or, if the written submission is 10 pages or less, fax: to 202/693-1648. All comments must reference the docket number (OSHA 2007-0006).


After years of delay, OSHA announced a final rule on employer-paid personal protective equipment (PPE), applicable to both general industry and construction. Under the rule, all new and replacement PPE, with a few exceptions, will be provided at no cost to the employee. The rule becomes effective on Feb. 13, 2008, and must be implemented by May 15, 2008.

Exceptions to employer-paid PPE include the following:

  1. Safety-toe protective footwear and nonspecialty prescription safety eyewear: Employers are not required to pay for ordinary safety-toe footwear and ordinary prescription safety eyewear, as long as the employer allows the employee to wear these items off the job site.

  2. Metatarsal protection: An employer is not required to pay for shoes with integrated metatarsal protection, as long as the employer provides and pays for metatarsal guards that attach to the shoes.

  3. Everyday clothing: The employer is exempted from paying for everyday clothing. Similarly, employers are not required to pay for ordinary clothing used solely for protection from weather, such as winter coats, jackets, gloves, and parkas. In the rare case that ordinary weather gear is not sufficient to protect the employee, and special equipment or extraordinary clothing is needed to protect the employee from unusually severe weather conditions, the employer is required to pay for such protection.

Exemptions list:

  • Nonspecialty safety-toe protective footwear (e.g., steel-toe shoes/boots)
  • Nonspecialty prescription safety eyewear
  • Sunglasses/sunscreen
  • Sturdy work shoes
  • Ordinary cold weather gear (coats, parkas, cold weather gloves, winter boots)
  • Ordinary rain gear
  • Back belts
  • Long sleeve shirts
  • Long pants
  • Dust mask/respirators used under the voluntary use provisions in Sec. 1910.134

The final rule requires that the employer pay for replacement of PPE used to comply with OSHA standards. However, in circumstances where an employee has lost or intentionally damaged PPE issued to him or her, an employer is not required to pay for its replacement and may require the employee to cover such costs. The rule acknowledges that employees may elect to use PPE they own; and, if the employer allows them to do so, reimbursement for the PPE is not required.


Personal Fall Arrest Equipment (PFE) comprises harnesses; lanyards; deceleration devices, such as a retractable lanyard commonly known in construction circles as a YoYo; lifelines; and, related equipment, such as hooks, snaps, buckles, connectors, and swivels. PFE differs from fall protection equipment, such as guardrails, and other physical barrier equipment, which is the preferred, engineered solution to fall hazards. Relative to the latter engineered solutions, PFE is considered the second-best solution for hazard mitigation.

OSHA General Industry and Construction standards are similar regarding PFE inspection requirements. Both require the following:

I. Personal fall arrest systems shall be inspected prior to each use for mildew, wear, damage and other deterioration; and, defective components shall be removed from service if their strength or function may be adversely affected. These inspections can be conducted either by the Competent Person or the PFE user, potentially the same individual provided the user’s training and qualifications meet Competent Person requirements.

II. PFE must be regularly inspected by a Competent Person, i.e., a person capable of identifying hazardous or dangerous conditions in the personal fall arrest system or any component thereof, as well as in their application and use with related equipment. Accordingly, the producer should decide whether to train a user to the Competent Person level, or otherwise document regular equipment inspections by a Competent Person.

III. Training to include proper and safe employment of the system is required prior to its use. Guidance should include application limits; proper anchoring and tie-off techniques; estimation of free fall distance, including determination of deceleration distance and total fall distance to prevent striking a lower level; and, methods of system use, cleaning, inspection, and storage.

IV. Inspection considerations include any component with a significant defect, such as cuts, tears, abrasions, mold, or undue stretching; alterations or additions that might affect its efficiency; damage due to deterioration; contact with fire, acids, or other corrosives; distorted hooks or faulty hook springs; tongues unfitted to the shoulder of buckles; loose or damaged mountings; nonfunctioning parts; and/or, wearing or internal deterioration in the ropes. Equipment exhibiting any such defects must be withdrawn from service immediately and tagged as unusable or destroyed.

V. Most harness damage occurs by daily use leading to normal abrasion wear. A second, major damage-causing component is exposure to the sun; therefore, harnesses should be hung up and stored out of the sun when not in use. Harnesses used by welders also occasionally suffer damage by dripping welding slag.

VI. PFE has a limited service life established by the manufacturer within ANSI guidelines. ANSI A10.32-2004, for example, sets a limit of five years Û unless otherwise specified by the manufacturer Û for the service life of fall protection equipment constructed of synthetic fiber. The guideline applies only to harnesses exhibiting no visual damage and those not exposed to chemicals, abnormal heat, or excessive ultra-violet light. While equipment may last longer, depending on care and use, it should be removed from service if a manufacturing date cannot be found on the harness and disposed of in a manner that prevents inadvertent reuse.

VII. Maintenance of inspection records is not specifically addressed in the standard, although producers are well advised to document inspections, especially in the Competent Person records. Also recommended are precautions taken by the producer to ensure that employees inspect their PFE before each use and acknowledge this requirement when queried by the OSHA inspector about inspection protocol. Defining Îregular inspectionÌ may depend on use, application, and wear; however, some state safety agencies such as Cal-OSHA require regular inspections by a Competent Person at least every six months. These inspections should be documented both for internal EHS audits and for OSHA review. Additionally, many harnesses bear an inspection tag allowing the user to mark the date and initial the tag each time the harness is used, though the tags are never large enough for numerous entries.


Featured at International Powered Access Federation Safety Zone [Las Vegas Convention Center Booth SZ1000, West Blue Lot] within the 2008 ConExpo-Con/Agg show, March 11-15, will be a dynamic demonstration of the dangers of not wearing a harness on boom-type platforms. The 15-minute show will run at regular intervals throughout the day, offering practical advice on correct harness use. Additionally, the nearly 8,000-sq.-ft. Safety Zone will display a range of aerial equipment supplied by IPAF members exhibiting at the show.

Says Tim Whiteman, IPAF managing director and president of Aerial Work Platform Training (AWPT), IPAF’s North American subsidiary, It’s frustrating that people are unnecessarily killed or injured while using boom-type platforms because they don’t wear harnesses. The demonstration will show vividly the dangers of being thrown or catapulted from the platform, if it is hit by another piece of equipment or is affected by ground subsidence.

The live demonstration is part of AWPT’s Click It! safety campaign that calls on boom-type platform users to wear a full-body harness with a short lanyard attached to a suitable anchor point. That recommendation is outlined in Technical Guidance Note AWPT H1 (available at, which explains when and how to wear harnesses and lanyards on different types of aerial platforms.

The Click It! initiative has generated thousands of stickers printed in six languages for distribution. Reminding and encouraging workers to wear a harness, the stickers can be placed on boom-type platforms where visible to all occupants. The program is endorsed by the Scaffold Industry Association, as well as by aerial equipment manufacturers and rental companies worldwide.

Safety and the correct use of harnesses and lanyards also will be a discussion topic at several technical meetings to be held at the IPAF booth during ConExpo. These will include the AWPT instructors’ meeting (March 11, 1:30), the AWPT Advisory Council meeting (March 11, 2:30) and the IPAF Manufacturers’ Technical Committee meeting (March 12, 2:00). Û,