As fit-testing supplies ran short during COVID-19, OSHA issued temporary enforcement guidance on October 2, 2020 for tight-fitting powered air-purifying respirators (PAPRs) under the Respiratory Protection standard (29 CFR 1910.134 and 1910.134(f)(2)). The memo is archived historical content and explicitly states it 'does not have the force and effect of law.'
The scope was tight. The discretion applied only to NIOSH-approved tight-fitting PAPRs, only for workers with high or very high SARS-CoV-2 exposure risk, only where fit testing was infeasible due to supply shortages, and only as a contingency capacity strategy. It did not apply to PAPRs not approved by NIOSH, workers at low or medium exposure risk, protection against non-COVID hazards, or loose-fitting hooded PAPRs (which do not require fit testing in the first place).
To qualify, employers had to provide NIOSH-approved tight-fitting PAPRs with a high efficiency (HE) particulate cartridge to protect against SARS-CoV-2, monitor fit-testing supplies and make good-faith procurement efforts, implement feasible engineering, work practice, and administrative controls, and maintain full respiratory protection program compliance except fit-testing, including medical evaluations, battery and filter maintenance, and required training. Employees also had to 'maintain neatly trimmed facial hair that does not compromise the seal of the respirator,' with accommodation notes for religious exercise. OSHA warned that citations could still issue under the respiratory protection provisions if employers failed on medical evaluation, maintenance, care, or training requirements beyond fit testing.