OSHA Voluntary Respirator Use: Challenges incurred with use of N95 filtering facepiece respirators during the...

This article discusses several lessons learned in dealing with the interpretation of the Occupational Health and Safety Administration (OSHA) Voluntary Use provision of the Respiratory Health Standard at health-care facilities during the COVID-19 pandemic in the United States. This includes (but is not limited to) (a) confusion about OSHA policy and procedures when health-care workers brought outside personal protective equipment (PPE; N95 filtering facepiece respirators) into the workplace; (b) challenges in adhering to guidelines stated in Appendix D of the Respiratory Protection Standard; (c) difficulty in achieving respirator fit testing for workers; and (d) vague or inconsistent determination of "non-hazardous" environments (concerning COVID-laden droplets and aerosols). The purpose was to identify gaps in knowledge to help policy makers, enforcement personnel, safety managers, and health-care workers in the United States prepare for similar future events involving PPE shortages.