For any person wearing an item of close fitting respiratory protective equipment a face fit test is a mandatory requirement.
Regulation 7 of the Control of Substances Hazardous to Health (COSHH) Regulations states the requirement for fit testing and refers to the Operational Circular 282/28 which sets out some very helpful guidance to approaching your fit testing programme. Fit testing is also referenced in the Control of Lead at Work (CLAW) Regulations and also the Control of Asbestos Regulations (CAR).
Rather than repeat all the very helpful guidance contained in the 282/28 document here are some key points to keep in mind when approaching your fit test programme, and what you definitely need to know as someone involved with Respiratory Protective Equipment (RPE)
You need a fit test for a close fitting respirator – regardless of whether it is a dust mask, half mask, full face mask, supplied air mask or positive pressure breathing apparatus, if it is close fitting and its protecting you against an airborne hazard you need a fit test.
You need to be clean shaven for your fit test – but remember that means you need to be clean shaven every time you wear that RPE. This can be a big issue and one that is explained in more detail below.
Your fit test needs to be done by a competent person – if you get an outside company to do your fit testing look out for Fit2Fit accreditation www.fit2fit.org , and if you have someone from internally doing it, make sure they have completed a train the trainer course provided by a Fit2Fit accredited provider. Having the Fit2Fit accreditation to provide fit testing is not mandatory but it’s a very effective way to prove competence if your fit test is ever called into question.
Your fit test is specific to the Manufacturer, Model and Size of Mask – for example being fit tested on a Scott Vision 2 full face mask in Medium doesn’t mean you are suitable for their whole range of full face masks, or for that same mask in Small size.
Your fit test doesn’t last forever – after your initial fit test it is good practice to regularly repeat fit testing. 282/28 is not prescriptive on the re-test period, although it guides those doing licensed asbestos removal to re-test annually. The only stipulations are that you should be re-tested when you ‘lose or gain weight’, ‘undergo substantial dental work’ or ‘develop any facial changes. However, because it can be difficult to accurately measure these changes, industry best practise is to re-test regularly, usually at 2 year intervals, dependant on the risk of exposure and frequency that RPE is worn.
The one question that nearly always comes up is in relation to facial hair. What do I do if I have an employee with facial hair? Can I fit test them with facial hair and just see if they pass? The answer is very simple - close fitting RPE that must be fit tested for cannot be worn with facial hair of more than 24 hour’s growth. That means clean shaven when worn as well as tested. You can’t just turn up for your fit test clean shaven, pass the fit test and then decide next week you will wear it with a beard. You have to wear your mask clean-shaven for it to be effective and to be compliant.
What can you do then if you have facial hair or persons working with you have facial hair, and Respiratory Protection is required? You have one of two choices.
First option you have is to change your or your employees job scope. Find a job that doesn’t require the use of RPE or engineer something into the task that removes the requirement for respiratory protection.
Second is to use a loose fitting powered air hood, a quick example would be something like this. Here the system protects the user by providing a clean air flow into a loose fitting hood, rather than relying on a seal to the face. We will cover in more detail the use of Powered Air systems in our upcoming article.
The one thing that you absolutely cannot do is potentially expose you or your staff to respiratory hazards.
For more information or to talk through a particular situation and get some help or advice, please get in touch firstname.lastname@example.org