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The Case Against Qualitative Fit Testing

Not all companies that use qualitative fit testing as a means to test the fit of respirators may know that the results are not necessarily 100% accurate. Since this is the case, it might be time to look for ways to conduct foolproof respirator fit testing which ensure that the results are reliable and verifiable.

Common use of qualitative fit testing in the workplace

Employers in different industries that require the use of respiratory protection are mandated to follow OSHA’s fit testing procedures (29 CFR 1910.134). Obviously, the preferred scenario would be to mitigate, remove, or remediate the environmental insult, but this is frequently impossible.

Your Respiratory Protection Program currently allows the use of qualitative fit-test (QLFT) methods when the Assigned Protection Factor (APF) of the respirators used to protect the workers does not need to be greater than 10, which can be met by a half-face respirator. It is important to be aware of the fact that if an Assigned Protection Factor (APF) greater than 10 is required for worker protection, qualitative fit test methods may not be used, and Quantitative Fit Testing (QNFT) is required.

Qualitative testing vs quantitative fit testing

When conducting a fit test, there are currently two ways to perform the test:

  • Qualitative Fit Testing which is highly dependent on the test subject’s sense of taste or smell using specific respirator fit testing agents. This, of course, means that the results are completely subjective and can be manipulated.
  • Quantitative fit testing is a more accurate and completely data-driven approach that uses defensible physical metrics to gauge the fit of the respirator.

Both testing methods can be legally used with:

  • Half-face masks
  • N-95 filtering face masks

Full-Face respirators (which have an APF of 50) must be fit-tested using QNFT.

Difference between the two methods of respirator fit testing

Here’s a quick rundown of the comparisons between the two types of respirator fit testing.

Quantitative Fit Testing

Qualitative Fit Testing

Objective, uses metrics

Subjective, results depend on test subject’s responses

Has no room for cheating

Can be manipulated based on inaccurate response

Quick and can be done in less than 3 minutes

OSHA-compliant test runs about 23 minutes

No potential toxic challenge agents are used

Test subjects may or may not have allergies to the challenge agents used

Verification check is available

No reliable means of verification check

A defensible fit test when legal issues against the employer arise

Can be labeled as circumstantial evidence and can be unfavorable for the employer when legal issues arise

Based on the comparisons shown in the above table, quantitative fit testing proves to be more accurate and efficient than qualitative fit testing.

What happens exactly during qualitative fit testing

Qualitative fit testing has two stages. In both stages, testing agents are used and prepared as solutions. 

Testing solutions

Among the OSHA-approved qualitative fit testing challenge agents are saccharin sodium, Bitrex™ (denatonium benzoate), and isoamyl acetate. In a few cases, irritant smoke may be used, so an involuntary cough can be used as a measure of sensitivity. However, the National Institute for Occupational Safety and Health (NIOSH) does not recommend using this test.

Taste sensitivity test

First, the test subject or participant takes a sensitivity test to check their sense of smell and taste. Once the taste sensitivity level has been identified, the participant is asked to wear a respirator so the seal check can be done.

Smell sensitivity test

After completing the seal check, a testing solution will be sprayed in a hood, and sometimes a nebulizer is used. Next, the participant will be asked to follow a series of exercises to check the efficacy of the respirator seal. Only if the participant is unable to taste the sprayed solution will they pass the test.

Real case of an employer with OSHA safety violations

Fit testing shouldn’t be taken lightly. A hospital in New York learned this the hard way when it was under fire in 2021. Its nurses protested against poor and unsafe working conditions amidst the pandemic.

OSHA did an inspection in May of the same year. As any company might fear, there were violations listed in the inspection report. Three of these were labeled as serious, and they are as follows:

  • The hospital failed to conduct respirator fit testing for all employees who were required to wear respirators, not even for those who were assigned to the progressive and intensive care units.
  • There were no available records of qualitative and quantitative fit testing conducted for employees who were required to wear aspirators.
  • One violation revealed that the nurses wore N-95 respirators without being provided a medical evaluation. The evaluation should have been done to gauge if they are able to use a respirator. All these happened at the time when the nurses were assigned to care for patients who were either suspected or confirmed COVID-19 cases.

This court case is just one of many where an employer didn’t make sure their workers had a safe place to work. Before this, two medical facilities in New Jersey were accused of not following safety rules for respiratory protection.

How qualitative testing can fail employers in legal cases

If you are an employer, the accuracy of test results (and good record-keeping) are crucial things that help you comply with safety regulations. Obviously, the most important consideration is that it also protects your employees against workplace hazards. Things could go wrong if issues or legal cases arise against an employer in the future as a result of improper testing or poor record-keeping. When you fail to present a defensible fit test, the court may not hold a judgment in your favor.

For any company, your records of an accurate fit test are your last line of defense. There is no way to prove that you complied with the regulations in good faith if you fail to show the courts that the fit testing measures you used were reliable. Qualitative fit testing may fail you, and here are the reasons why:

  • These tests heavily rely on the wearer’s or test subject’s honesty.
  • No one knows if the participant’s responses are reliable.
  • No metrics can quantify the data that you need.
  • The records you have on hand may be deemed circumstantial evidence.

Any employer must remember that OSHA regulations and labor code laws are made to protect the welfare of employees. Most of the time, companies are legally responsible when they are accused of breaking safety and labor laws. Any company can avoid fines by staying out of civil cases and having a good records of results that can be checked and verified.

How quantitative testing can help companies pass any safety inspection

In March 2022, OSHA sent out a memo that explained how it planned to go about inspecting medical facilities that treat COVID-19 patients. The inspection plan was only three months long, but it was very thorough. This was to make sure that medical facilities took the right steps to protect their employees from the dangers of the coronavirus.

It is possible another set of inspections will be carried out in the future. As a safety measure, companies can avoid being charged with safety violations if they do fit testing correctly. The best way to make a defensible fit test is to choose a method with better documentation. This way, results can be checked. With better documentation comes better compliance.

Also, quantitative fit testing solutions such as those offered by Accutec can solve many problems that employers face. Here are some examples:

  • When performing a qualitative fit test, it is not uncommon for the test administrator to omit some tests/exercises in the standard testing procedures in order to save time. There is no way to prove that this did not occur. When using the AccuFIT 9000 this is impossible.
  • Because of the adoption of the Fast OSHA protocol, manpower for qualified fit test administrators is no longer an issue, and scheduling employees to test respirators when there is a critical staffing shortage less of an issue.
  • Respirator fit testing in small facilities with limited space is no longer troublesome.
  • Urgent fit testing can be done amidst work settings where COVID-cases are rampant
  • Fit testing may be done often, even in circumstances where facial structure changed or when there is the presence of facial hair
  • Closer monitoring of all employees is achieved to maintain a higher level of safety and protection.
  • The AccuFIT 9000 generates a defensible metric and automatically creates and stores a virtually unimpeachable record

Finally, should a case against an employer arise, the quantifiable, verifiable, and defensible data derived from a quantitative fit test protocol holds up as solid evidence of OSHA compliance.

What companies need to know about fit testing

Carrying out fit test methods that are time-consuming and have a high margin of error takes a lot of employee productivity time. Moreover, when things go awry, the way you do things may prove to be fallible.

Employers need to understand that proper respirator fit testing is essential to saving lives. This is why not only safety but also the accuracy of testing methods should be one of any company’s top priorities.

Make sure you are doing everything you can to both protect your employees and protect your company by using only the best quantitative respirator fit test machines available.

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