Respirator Program Administrator

The Respirator Program Administrator, or RPA, has overall responsibility for the facility’s Respiratory Protection Program. The RPA should have enough training or experience to oversee the program development, coordinate implementation, and conduct the required program evaluations.

Please note: All activities relating to the respiratory protection program should be done on paid time and at no cost to the worker (i.e., the employer pays for the worker's time, travel, and any other associated costs for medical evaluations, fit testing, etc.

The RPA will need to create the facility’s written respirator program, implement what needs to be done, and evaluate the program’s effectiveness at keeping the workers safe from respiratory hazards. Setting the plan for any activities for the respirator program will need to include providing the workers with paid time to get their activities completed on time. The employer pays for any expenses related to the respirator program.

The RPA is the point person at the facility and should have the most knowledge of the rules and regulations about respirator use.

Also, the RPA may be the person making the decisions, and/or be the fit tester for the facility. After you implement your respirator program, it should become easier to maintain

Facility leadership decisions

Before fit testing can start, there are tasks to complete and you will need to make some decisions for your facility.

Complete your written respiratory protection program. The written program is your plan/policy/procedure on how the respirator program functions, and it will be a guide for the fit tester(s).
Identify how you will provide medical evacuations for workers needing to use a respirator. A Licensed Healthcare Provider need to review the worker’s medical information, and then determine if it is safe for the worker to wear a respirator.
Develop and implement your N95 worker training program. Your workers will need to complete this training before using their fit tested N95 in the facility.
The person doing the fit testing does not need to be a healthcare provider. Anyone can learn how to conduct a fit test.
For doing your own fit testing, select the number of staff you will train to become fit testers. Consider the number of workers you have who need a fit test, and the work shifts at the facility.
- Our recommendations are to train:
  - 1-2 fit testers for a facility with 1-15 workers
  - 2-3 fit testers for 16-30 workers
  - 3-4 fit testers for 31-50 workers
  - 4+ fit test staff for >50 workers
- If possible:
  - Select more than 1 person to do fit testing. This is to cover absences, and various work shifts.
  - Fit testing needs to occur on paid time. If staffing allows you to have more than 1 fit tester, select people so that you cover day and night work shifts.
What type of fit testing will be done? Qualitative or quantitative?
- For qualitative fit testing, you will need a fit test kit*:
  - Decide what solution you will use:
    - Bitter – Bitrex?
    - Sweet – Saccharine?
  - What type of hood will you use?
    - Hood with a collar
    - Hood without a collar
- For quantitative fit testing:
  - You will need a machine capable of fit testing N95s.
  - The machine tests one person at a time.
For qualitative fit testing, deciding how you will do the fit testing will help you determine how many fit test kits you will need. If you have more than 1 fit tester:
- Will the fit testers be fit testing together as a team or alone?
  - If they are fit testing alone, you will need 1 kit. If they are fit testing as a team, you will need multiple kits (i.e., each fit tester will need their own kit
- Will the fit testers be traveling to different locations to fit test workers? If they are traveling to different locations, it is likely they will each need their own kits

*See the Resources page for more information about fit test kits.

Medical Evaluation

As the RPA, you will need to either manage the medical evaluation or oversee someone who will manage it.

New hires need to complete their medical evaluation before they can use the N95. Have workers repeat their medical evaluation before the due date.

In-person medical evaluation for respirator use

If your worker does not clear or pass the medical evaluation, they may need further evaluation. They will need to see a local Licensed Healthcare Professional (LHCP) for an in-person evaluation. This provider should be knowledgeable about how respirators work and how using one can affect the person, especially if there are certain health conditions.

Do not send your worker to their PCP

Their healthcare insurance will be billed. WAC 296-842 requires the employer to cover the cost for medical evaluations (the medical evaluation needs to be at no expense to the worker).
Their PCP may not know or understand the risks of using the N95 and their medical condition.

Find an occupational medicine clinic or an occupational medicine provider. When sending your worker for further evaluation, have them bring in their job description, and a copy of the letter of recommendation from the first provider.

The clinic provider doing the evaluation will need to have a copy of your facility’s written respirator program, and a copy of WAC 296-842. You can send these documents to the clinic before the worker’s appointment, or have the worker bring copies with them to the appointment.

Medical evaluations done in-house

The questionnaires can only be reviewed by your appointed licensed health care professional (LHCP).

The questionnaire contains personal health information and falls under HIPAA regulations; it must be kept protected and stored securely.
It must be kept separate from the HR file.
It should not be available for supervisors to review.

For each person evaluated, the LHCP must provide you and the worker with a copy of the medical evaluation letter of recommendation.

The fit tester and the RPA need to see the letter of recommendation because it tells them if the worker has medical clearance to use an N95, if there are restrictions on use (and what type of restriction), or if the person requires further medical examination.

The letter of recommendation should include the following:

A statement about whether the worker is medically able to use the respirator (i.e., cleared, cleared with restrictions, or not medically cleared), and list any limitations on respirator use
A date when the next medical evaluation is due
A statement that the worker received a copy of the letter of recommendation
The name of the licensed health care professional who did the evaluation, and the date they completed it.

Fit Testing

Remember all activities related to respirator use will need to be done on paid time for the worker. This includes getting training on how to conduct a fit test.

Anyone can learn how to conduct a fit test. There is no certification to validate this skill. However, it is the employer’s responsibility to be sure the fit testing is done correctly.

Planning for Fit Testing

Fit testing ensures the N95 fits the worker’s face and provides a seal that protects the worker. Fit testing needs to be done every year. If the worker goes beyond their date for renewal, they cannot use the N95 until they get fit tested (see ‘Accommodations’ below for more information).

Work with your facility leadership to plan how fit testing will be accomplished.

Selecting your fit test staff will depend on many things, consider the following:

The number of workers you need to fit test
The number of shifts you have
The number of building locations your organization has, and
The severity of staffing shortage you are experiencing.

The best practice is to have more than one person trained to do fit testing. We recommend the following number of fit testers per number of workers at your facility:

1-2 fit testers for a facility with 1-15 workers
2-3 fit testers for a facility with 16-30 workers
3-4 fit testers for a facility with 31-50 workers
4+ fit testers for a facility with >50 workers

Fit Test Equipment

The number of fit test kits and equipment you purchase will depend on how your Fit Testing Program is set up. Two fit testers cannot share one kit while testing at the same time.

Purchase a qualitative fit test kit with either bitter or sweet solution. A qualitative fit test kit* will contain at the minimum:

A hood
Two complete nebulizers
Sensitivity solution
Fit testing solution
Extra atomizers and cleaning wires

*See the resource page for more information on fit test kits.

Equipment and solutions can be purchased separately. If you have a larger facility, consider having an extra supply of the following items on hand:

Hoods
Nebulizers
Sensitivity and fit testing solutions (you cannot conduct a fit test without the solutions)

N95

Be sure you are purchasing your N95s from a reputable distributor. Always check your new shipment of N95s for the key identifiers that will ensure your purchase is NIOSH approved N95.

During the pandemic, there were many counterfeit N95s. Always look for the NIOSH logo, manufacture name and model number, and the approval number also known as the “TC number”. If you cannot find it on your N95, look at the strap. There are some manufacturers that use the strap for that information. If you are not sure, please visit the NIOSH website NIOSH-Approved Particulate Filtering Facepiece Respirators, this site includes the N95.

Supplies

Besides a fit test kit, you will need the following supplies:

Clock with a sweep hand
Disinfectant wipes
Gloves
Hand Sanitizer
Mirror
Napkins/paper towels
Water, with cups

Location

Conduct fit tests in a quiet area. The room should have tables and chairs with enough room for fit testers and workers to comfortably conduct the fit test. The room should have a sink, or there should be a sink nearby.

Accommodations

If a worker does not clear the medical evaluation, or you do not have an N95 that fits your worker, the worker will not be able to provide care for a person in isolation for a respiratory hazard. You may want to provide accommodation. Accommodation offers the worker an alternative work assignment that does not involve entering an area with known or suspected respiratory hazards.

Examples of N95 accommodation

Assign the worker to care for residents that are not in isolation. Assign the worker to another type of job they are qualified to do that does not require them to use the N95.

N95 User Training

In your written respirator program, you will need to describe how you will deliver your training to your workers. The training will need to be complete every year, just as fit testing needs to be done every year.

Here is an example description about how the training could be done at your facility: ‘We use a self-paced PowerPoint module to train workers on respirator use. Workers complete this training upon hire, (before re first respirator use), and then repeat it annually (within 12 months of the last training date).’

If you do not have a respirator training program for your workers, you can use the DOH N95 User Training template. Download it to your device and then modify it to fit your facility. This training template is specifically for use in Washington State. THIS IS THE END

Recordkeeping

There are specific records you must keep and maintain. These records will help you keep track of when a worker is due to get a task done. Items you will need to keep:

The worker’s current fit test record.
The worker’s current training record.
The worker’s current medical evaluation letter of recommendation.
- Also, if your facility provides medical evaluations in-house, you will need to keep the medical questionnaires for 30 years after the worker leaves your employment. Completed questionnaires are HIPPA protected and will need to be kept separate from the worker’s HR file.
The written respirator program document. Keep this up-to-date.
- Update your written program as rules and regulations change, when there is a change in the facility’s plan for how the N95 will be used by the workers, if you change the types of N95s you provide at the facility, etc.

It is best practice to review your written respirator program document every year. Update it with any changes, and make a note that you completed a review.

Program Evaluation

The purpose of evaluating your respiratory protection program is to keep your workers from being exposed to respiratory hazards and getting ill. Evaluate your program regularly to see if it is working well and determine if you need to make improvements.

If there are barriers making it difficult for your workers to use the N95 when they need it, it may put them at risk of exposure because they will be less compliant in using it properly. As the Program Administrator, you should identify, investigate, and address any barriers. Removing barriers helps make it easier for your workers to use the N95 when required.

Example investigative questions you may want to ask of yourself or your workers:

Have there been changes in job duties that would change the requirement to use the N95?
Ask your workers how easy or difficult it is to use the N95.
Are your workers up-to-date with annual N95 respirator training, annual fit testing, and their medical evaluations for respirator use?
Can the worker articulate and demonstrate how to inspect, don, seal check, and doff the N95 properly?
Are your workers performing seal checks each time they don the N95?