OSHA Voluntary Respirator Use: Challenges incurred with use of N95 filtering facepiece respirators during the COVID-19 pandemic

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.