Fit-test kits and respirators were both scarce during the early pandemic. OSHA had already given healthcare employers temporary relief on annual fit testing; this April 8, 2020 memo expanded that guidance to 'all workplaces covered by OSHA where there is required use of respirators.'
OSHA announced it would exercise enforcement discretion concerning the annual fit-testing requirements as long as employers made good-faith efforts to comply with the respiratory protection standard (29 CFR 1910.134(f)(2) and Appendix A). The agency also pushed employers to reduce respirator demand by assessing and strengthening engineering controls, work practices, and administrative controls, suggesting options like wet methods or moving operations outdoors.
If a worker's fit-tested respirator model was out of stock, OSHA said employers should consult the manufacturer to see if it recommends a different model with equivalent fit characteristics. For those equivalent-model switches, OSHA would exercise additional enforcement discretion regarding compliance with the initial fit-testing requirement specifically. The memo emphasized this guidance was time-limited to the public health crisis and directed employers to monitor www.osha.gov/coronavirus for updates.