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Is Respirator Fit Testing a Legal Requirement? The Answer May Surprise You.

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Is respirator fit testing a legal requirement? We get asked this question a lot.

The answer may surprise you.

In this article we'll review:

First, let's start with what fit testing is and what it entails.

What is Fit Testing?

Put simply, a mask fit test ensures there is an adequate seal between the facepiece of a respirator and the wearer's face. Fit testing is essential to ensure that respirators are providing their expected level of protection against airborne hazards.

If a mask leaks because it doesn't fit properly, then submicron particles, such as dust and viruses, can enter into the breathing zone putting the wearer at risk.

For many, fit testing may seem like a new concept or requirement. It's not!

The requirement for tight-fitting respirators to be fit-tested has been around for decades as part of a comprehensive respiratory protection program under the AS/NZS 1715:2009. But in Australia, fit testing hasn't always been enforced. The emergence of COVID-19 and an emphasis on reducing exposure to silica dust has changed that.

There are two methods for conducting respirator fit testing: quantitative fit testing and qualitative fit testing.

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Quantitative Fit Testing

Quantitative fit testing uses a machine (usually a PortaCount or Accufit) to measure the actual leakage of a respirator's seal, providing numerical data as to how well the respirator fits (this is called the fit factor). This test is done by challenging the seal of the respirator with naturally occurring, ultrafine particulates from the surrounding environment.

Quantitative fit testing is an objective measure of the seal so the results are inherently more accurate than qualitative testing.

There's also the CNP method of fit testing which is less common.

Qualitative Fit Testing

Qualitative fit testing assesses the adequacy of the respirator seal and fit based on the wearer's sensory perceptions.

During qualitative fit testing, the person wears a respirator mask and is exposed to a test agent, most often saccharin or Bitrex. The wearer performs a series of movements and activities while wearing the mask, such as normal breathing, talking, and head movement. If the wearer detects the taste or irritation of the test agent inside the respirator, it indicates a potential leak, suggesting that the mask does not provide an effective seal.

The major downside of qualitative fit testing is the subjectivity of the test. Some people have trouble determining if they can actually taste the solution or not.

Qualitative testing can only be used on disposable and half-face reusable respirators. Full-face respirators must be tested using a quantitative method.

When to Fit Test

Fit testing must be undertaken when folks are initially issued their respirator and annually thereafter. If there are any significant facial changes due to weight loss/gain, surgeries, trauma, or dental work, they need to be retested.

It's important to note that you must wear the exact brand/model/size respirator you're fit tested on. If you change brands, models or sizes, you need to get another fit test on the new mask.

Work Health and Safety Regulations: Do What is Reasonably Practicable

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Don't get too hung up on the word "mandatory" as it relates to fit testing (or any health and safety measure for that matter).

Even if you don't see the word "mandatory" or "required," there is an overarching requirement under all Work Health and Safety Acts and Regulations: "Employers must provide and maintain a working environment that is safe and free of risks to health, so far as is reasonably practicable."

What does this mean, exactly?

It means that what can be done should be done unless it is reasonable in the circumstances for the duty-holder to do something less. Read Safe Work Australia's formal definition here.

When it comes to fit testing, there is nothing less that can be done other than to test the mask to make sure it fits the wearer. If someone is wearing an ill-fitting respirator, then microscopic, harmful substances, such as silica dust or viruses, can enter the facepiece putting the wearer at risk.

As a side note, during the COVID pandemic, some employers were substituting 'seal checks' (aka fit checks) for fit testing. This would be an example of doing "something less" than fit testing.

The problem is this. Seal checks are woefully unreliable when it comes to predicting how well a mask fits. Studies have shown that seal checks are unable to serve as an effective alternative to fit testing because of their low sensitivity, poor accuracy, and dismal predictive value. Leakage between the face and the respirator - even gross leakage - is not easily detected by the wearer through a seal check.

In most cases, it is reasonably practicable for employers to ensure staff are wearing respirators that fit properly. And the only way to know this for sure is to get a fit test.

The AS/NZS 1715:2009

The AS/NZS 1715:2009 is the standard that outlines the selection, use, and maintenance of respiratory protective equipment (RPE). Section 2.6 states, "The program administrator shall ensure a suitable fit test is carried out for all users of RPE with a close-fitting facepiece."

In fact, all international respiratory protection program standards, including ISO 16975-3 and OSHA 1910.134, require that tight-fitting respirators be fit-tested to ensure they are providing their stated level of protection.

Standards are not laws per se. But they do provide guidance to help duty holders ensure they're meeting their legal obligations in relation to various work health and safety requirements, including the use of RPE.

And just so you know - fit testing is just one aspect of a comprehensive respiratory protection program. Other essential components include:

  • Assigning a program administrator

  • Use, selection and wearing of RPE

  • Exposure assessment

  • Medical evaluations

  • Education and training

  • Record keeping

  • Audits and evaluations

  • Cleaning, repairs and maintenance

If your employees are required to wear any type of RPE, you should have a written respiratory protection program in place and enforced. (Fit Test Victoria can help with that.)

Consequences of Skipping Fit Testing

Failure to comply with respirator fit testing requirements and work health and safety regulations can have serious consequences. Not only does non-compliance jeopardise the health and safety of workers, but it can also result in legal penalties for employers.

In the event of a workplace incident or inspection, authorities will assess whether the employer took reasonable steps to ensure worker safety, which can include compliance with fit testing standards.

Penalties for non-compliance can vary depending on the jurisdiction and the severity of the violation. Fines, work orders, and even criminal charges could be levied against employers found to be negligent in meeting their obligations. Additionally, non-compliance can damage a company's reputation and erode employee trust.

In a recent WorkSafe Victoria construction blitz, there was focus on reducing the risks associated with respirable crystalline silica. WorkSafe Director of Construction and Earth Resources Matt Wielgosz noted, "There are measures employers can and must take to protect workers engaged in high-risk silica work, including providing tools with water suppression, supplying well-fitted PPE and carrying out air monitoring."

There's no way to know if a respirator is "well fitted" unless the wearer gets a fit test.

Boral Quarry was convicted and fined $180,000 after pleading guilty to exposing staff to harmful silica dust by not enforcing correct mask use. WorkSafe Victoria prosecuted them over failure to provide and maintain a system in which staff were required to wear respiratory protective equipment, that equipment was fit-tested and safety measures were followed.

This bears repeating. Fit testing will likely always be deemed "reasonably practicable" by WorkSafe and other OHS authorities to ensure staff are wearing respirators that fit properly.

Don't skip this important measure to keep you and your workers safe.

Wrapping Up

Under OHS regulations, employers are obligated to do everything reasonably practicable to keep workers safe. In most cases, fit testing is considered to be reasonably practicable. Non-compliance can lead to serious consequences, both legally and in terms of worker health.

AS/NZS 1715:2009 sets the standards for respiratory protection programs in Australia, emphasizing the importance of proper fit testing. By adhering to this Standard, employers demonstrate a commitment to safeguarding their workers and fostering a culture of workplace safety.

As the landscape of workplace safety evolves, staying informed about these legal obligations is crucial for employers and organizations across Australia.

If you have any questions about anything you've read here or you want to book fit testing for your organization, email or call 0428 630 109. We're here to help.

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All rights reserved. No part of this blog post may be reproduced, distributed, or transmitted in any form or by any means, including photocopying, recording, or other electronic or mechanical methods, without the prior written permission of the copyright owner.


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