Are you or your company currently using qualitative respirator fit testing (e.g., the procedure that relies on the ability of the test subject to sense saccharine exposure)? If so, how can you be 100% positive your respirators are properly fitted and therefore effective at protecting you and your co-workers?
Current regulations allow qualitative fit testing methods for half-face respirators including disposable facepieces. However, the test itself depends wholly on the test subject’s widely-varying sensitivity to the challenge agent (typically saccharine) and worse, his or her veracity. There are absolutely no defensible metrics developed during a qualitative fit test.
In contrast, a quantitative fit test measures a metric which is not influenced by the test subject, or in other words, is completely objective. Any record of a qualitative fit test contains only a subjective response regardless of how closely the process follows the protocol outlined in 29 CFR 1910.134.
To place this in a different context, let’s imagine it as a court case. Since it’s apparent we live in an increasingly litigious society, civil erroneous behavior or actual wrongdoing (or as we understand the legalese, a tort) is frequently addressed in lawsuits.
Can you imagine a scenario in which a worker who has suffered some sort of respiratory insult might bring suit against an employer claiming that he or she was inadequately protected under the employer’s Respiratory Protection Program (RPP)?
If the employer were using a Qualitative Fit Test, the plaintiff testimony might be similar to this:
Plaintiff’s lawyer: “Do you have a formal Respiratory Protection Program?”
Person responsible for RPP: “Yes, we do.”
PL: “Does it include a requirement to perform fit testing of the respirators you provide?”
RPP person: “Yes, it does, in accordance with OSHA guidelines as stated in 29 CFR 1910.134”
PL: “What sort of fit testing do you provide?”
RPP person: “We use a Qualitative Fit Test Protocol.”
PL: “Could you describe the protocol?”
RPP person: “Well, briefly, it consists of placing a hood over the test subject’s head and squirting saccharine into the hood to see if the test subject can taste it while he is performing a series of exercises…”
PL: “And what sort of data does this test provide?”
RPP person: “Well, it tells us whether or not a test subject can taste the saccharine…”
PL: “And if he or she can taste it, what does that mean?”
RPP person: “That means that they have failed the fit test”
PL: “And if they can’t taste it or if they tell you that they can’t taste it, what does that mean?”
RPP person: “It means they passed.”
PL: “So all you have is a subjective answer based on the ability of the test subject to taste a challenge agent, and what’s worse, the truthfulness of that answer?”
Defense Lawyer: “Objection! Your Honor, the plaintiff’s lawyer is leading the witness.”
PL: “I’ll re-phrase my question. Do you have any proof, any actual metric that demonstrates exactly how well the respirator fit my client?”
RPP person: “Well, we keep records of who was tested, when it was done, and what the result was.”
PL: “So you don’t actually know how well the respirator fits my client?”
Defense lawyer: “Objection!”
Now, if you were a juror in this trial, how would you feel given that explanation? Would you have doubts about the legitimacy and accuracy of the qualitative fit test? There’s a good chance most of us would be skeptical of this form of fit testing.
If, on the other hand the employer were using a Quantitative Fit Test, the plaintiff testimony might go as follows:
Defense lawyer: “Do you have a formal Respiratory Protection Program?”
Person responsible for RPP: “Yes, we do.”
DL: “Does it include a requirement to actually measure how well a respirator actually fits the user?”
RPP person: “Yes, it does, in accordance with OSHA guidelines as stated in 29 CFR 1910.134. We refer to this measurement as a ‘Fit Test’.”
DL: “What sort of ‘Fit Test’ do you provide?”
RPP person: “We use a Quantitative Fit Test Protocol.”
DL: “Could you describe the protocol?”
RPP person: “Certainly! The test uses an instrument that is capable of measuring the concentration of ultrafine particulates in the ambient atmosphere and dividing that number by the concentration of ultrafine particulates in the test subject’s breathing zone while the test subject is performing a series of exercises designed to stress the respirator/face seal.” The instrument makes these measurements and computes a “Fit Factor” which is mathematically related to the actual “Protection Factor”
DL: “How do you know the instrument is working properly?”
RPP person: “We have the instrument calibrated yearly according to the manufacturer’s recommendations, and we perform a validation check prior to and after each series of fit tests. The validation check ensures that there are a sufficient number of particles, that the detector is working properly, that there are no leaks in the system, and that the switching valve between ambient and in-mask sample is functioning properly.”
DL: “And do you have records to support this?”
RPP person: “Of course. All of the test data including the validation test data are automatically written to our database.”
DL: “So you can produce actual, objective, defensible metrics that describe the condition of the instrument used in these measurements and the fit of the respirator?”
RPP person: “Of course.”
As that same juror, how does this testimony differ from the first? Feeling more certain about the effectiveness of a quantitative fit test? It’s likely we all would.
Now, given the choice, which method would you want your company to utilize?
Obviously, this is not a real court transcript (yet) and we’re not lawyers, however, the point we’re trying to make is clear. There is a huge risk in attempting to defend qualitative fit testing which generates absolutely zero defensible, objective metrics.
Quantitative Respirator Fit Testing not only saves lives, it can save companies thousands of dollars in capital costs for potential lawsuits, should employee respirators not fit correctly.
There is an old saying from Britain that goes like this: “He hath spoil’t the barrel for a ha’penth of tar!”
Want to learn more about Quantitative Respirator Fit Testing?