Anonymous Public Comment

I appreciate the Occupational Safety and Health Administration (OSHA)’s efforts to reduce unnecessary steps for certain employee respirator fittings, yet I urge the administration to advance this rule with caution. The proposed changes suggested in this rule would eliminate the medical evaluations for filtered facepiece respirators or loose-fitting PAPRs (OSHA, 2026). There would be no changes for the additional respirator types. Traditionally, respirator medical evaluations, also known as fit tests, were required before use from a healthcare professional (OSHA, 2026). OSHA believes that mandatory medical evaluations improve safety for those wearing filtering facepiece respirators or loose-fitting PAPRs (2026). OSHA is not eliminating respirator protection requirements but is proposing no medical clearance prior to use of the N95 or loose-fitting PAPRs (2026). Personally, I can understand why the administration wishes to propose change to this rule because this tends to happen in practice and eliminates extra work. During COVID-19, I personally witnessed employees were not fit tested before utilizing filtering facepiece respirators, like N95s. However, a recent study demonstrates that there was a significantly (p = 0.0264) higher respiratory infection rate among individuals who were not properly fit tested for N95s compared to those who were (Fujimoto et al., 2025). Although I understand that more desperate times, like during COVID-19, rules were bent, however the most recent evidence demonstrates the necessary fitting of N95s to improve provider safety (Fujimoto et al., 2025). On the other hand, the U.S. Centers for Disease Control and Prevention (CDC) recommends that loose-fitting PAPRs do not require a fit test prior to use (CDC, 2025). A suggestion for this proposed rule would be to implement change just one respirator at a time. Since the current literature recommends that loose-fitting PAPRs do not necessitate medical evaluation prior to use, it is appropriate for the administration to implement this in the proposed rule. As supported by the current evidence, filtering facepiece respirators still need proper fit testing prior to use and should be held off in the proposed rule until evidence can support the change. References Fujimoto, G., Obikane, S., & Kubouama, K. (2025). Effectiveness of N95 mask fit testing for the prevention of severe acute respiratory syndrome coronavirus 2: A retrospective case-control study. Cureus, 17(1). https://doi.org/10.7759/cureus.77168 Occupational Safety and Health Administration (OSHA). (2026). Amending the medical evaluation requirements in the respiratory protection standard for certain types of respirators. Federal Registrar. https://www.federalregister.gov/documents/2026/06/03/2026-11093/amending-the-medical-evaluation-requirements-in-the-respiratory-protection-standard-for-certain U.S. Centers for Disease Control and Prevention (CDC). (2025). Powered air-purifying respirators. https://www.cdc.gov/niosh/ppe/respirators/papr.html