OSHA Allows Extended Use and Reuse of Respirators During COVID-19 Crisis
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OSHA compliance officers may use their discretion to permit the extended use and reuse of respirators during the COVID-19 pandemic, according to interim guidance issued on April 3. The guidance, a response to respirator shortages stemming from the pandemic, applies immediately to all industries and will remain in effect until further notice, OSHA states. CDC defines extended use as wearing the same respirator for repeated close contact with people, without removing it. Reuse involves using the same respirator for multiple encounters but removing it after each. OSHA’s interim guidance states that extended use is preferred over reuse due to the possibility that handling the respirator may facilitate transmission of SARS-CoV-2, the virus that causes COVID-19. The agency instructs compliance officers that extended use or reuse may be permitted as long as the respirator “maintains its structural and functional integrity and the filter material is not physically damaged, soiled, or contaminated.”

The guidance refers to the Food and Drug Administration’s March 28 action permitting the use in healthcare settings of NIOSH-approved respirators that have passed their manufacturer-recommended shelf life. OSHA acknowledges that during a respirator shortage, extended use and reuse of NIOSH-approved respirators is preferable and more protective than surgical masks or homemade mouth-and-nose coverings.

NIOSH testing of a sample of expired N95 filtering facepiece respirators has indicated that they remain protective beyond their shelf life. The agency recommends that workplaces follow guidelines for extended respirator use in CDC’s “Strategies for Optimizing the Supply of N95 Respirators.”
For healthcare employers, OSHA’s guidance specifies that expired N95 FFRs must not be used during surgery on patients infected with or suspected of being infected with SARS-CoV-2, or during procedures expected to generate aerosols or where respiratory secretions may be poorly controlled. The guidance also states that other respirators whose shelf life has not been exceeded should be used before expired N95 FFRs. All employers whose workers are required or permitted to use respiratory protection must continue to manage their respiratory protection programs according to OSHA’s standard for respiratory protection. OSHA encourages employers in industries other than healthcare to consider ways to reduce use of N95 FFRs in order to preserve supplies for healthcare workers.  “All employers should reassess their engineering controls, work practices, and administrative controls to identify any changes they can make to decrease the need for N95 respirators,” the guidance reads. Possible approaches to limiting N95 FFR use include using wet methods or local exhaust systems, moving operations indoors, or suspending non-essential operations. In cases where respiratory protection is necessary, employers may consider respirators other than N95 FFRs as long as they provide equal or greater protection, OSHA says.  OSHA’s temporary guidance on extended use and reuse of N95 FFRs is on the agency's website. FDA’s letter about the shelf life of respirators can be accessed on its website as a PDF. Read CDC’s “Strategies for Optimizing the Supply of N95 Respirators” online. Additional guidance for extended use and reuse of N95 FFRs is on the CDC website.

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Extended use or reuse may be permitted as long as the respirator “maintains its structural and functional integrity and the filter material is not physically damaged, soiled, or contaminated.”