Comment from Dentec Safety Specialists Corp.

I am writing in response to the amendment for medical evaluation requirements in respiratory protection standard for certain types of respirators. My company has been manufacturing reusable elastomeric masks, particulate filters and cartridges and carbon based cartridges that are NIOSH approved for some 30 plus years. The amendment removing the requirement for medical evaluations for filtering facepieces (FFRs) and powered air purifying respirators is not fair. If you wish to make this amendment than reusable half mask elastomeric respirators must be included in this amendment for the following reasons. We have proof that our reusable half mask respirator with and without and exhalation valve provides the following advantages: - Lower breathing resistance the any FFR on the market. - Temperature build up inside our reusable elastomeric half mask respirator is lower than FFR's in N95 and P100 variations. - Greater comfort against the skin. - Superior sealing properties vs any disposable. - You cannot conduct a seal check on the disposable respirator prior to entering the hazardous area. You can quickly and simply contact a seal check on our reusable elastomeric half mask prior to entering the hazardous area. There has been a fallacy that reusable elastomeric half masks are uncomfortable versus FFR's when in fact this is not the case. We learned during the pandemic that reusable elastomeric half masks are more comfortable then disposable respirators and user acceptance is greater wanting to convert to a reusable mask. I would suggest the following; Maintain the medical evaluation for all respirator types. Alternatively, remove medical evaluation requirements for FFRs and reusable elastomeric half mask respirators, PAPR's using particulate filers ranging in N,R,P categories. If half mask or a PAPR uses a carbon based cartridge, medical evaluations would be necessary. This would allow the market the option to select the best respirator solution for their application.