A respiratory protection program is the written program, with worksite-specific procedures, that 29 CFR 1910.134 requires where respirators are necessary to protect employee health or the employer requires them. Integral Healthcare Solutions (IHS) drafts that program for clinics, hospitals and laboratories: the written program, procedures and records forms, for your administrator and safety professional to adopt. IHS does not fit test employees, perform medical evaluations, deliver training or give legal advice.
Last updated: November 2026. Regulation text read 2026-11-05 (current eCFR, GovInfo copy built 2026-11-03).
What does OSHA's respiratory protection standard require in a written program?
It requires the employer to establish and maintain a written program with worksite-specific procedures, run by a designated program administrator, and covering each employee the section requires to use a respirator (1910.134(a)(2), (c)). The text is at 29 CFR 1910.134. The trigger in (c)(1) is a workplace where respirators are necessary to protect the health of the employee, or whenever the employer requires them.
Paragraph (c)(1) names nine provisions, each included "as applicable": respirator selection; medical evaluations; fit testing for tight-fitting respirators; use in routine and reasonably foreseeable emergencies; cleaning, storage, inspection, repair and maintenance schedules; breathing air for atmosphere-supplying respirators; training in respiratory hazards; training in proper use; and regular evaluation of program effectiveness.
Respirators, training and medical evaluations are at no cost to the employee (c)(4).
Who needs a respiratory protection program, and what triggers it?
An employer needs one when respirators are necessary to protect employee health or when it requires them (c)(1). In IHS's reading, deciding whether a job meets that test starts with the employer's respiratory hazard evaluation. Paragraph (d)(1)(iii) requires it to include a reasonable estimate of employee exposures and the contaminant's chemical state and physical form; where the employer cannot identify or reasonably estimate the exposure, it considers the atmosphere immediately dangerous to life or health.
Where use is not required, the employer may allow it if it determines the use will not itself create a hazard, must give users the Appendix D information, and must establish the elements that keep users medically able and respirators cleaned, stored and maintained. Employees whose only use is voluntary use of filtering facepieces (dust masks) need not be included in the written program (c)(2).
What usually starts a program build:
- Fit test results and medical clearances sit in several places, with no single written program.
- A change of facepiece (size, style, model or make) on a tight-fitting respirator calls for a new fit test (f)(2).
- A generic template does not describe the respirators in use.
What do the medical evaluation, fit testing and training paragraphs require?
They set a sequence and a yearly cycle: medical evaluation, then fit test, then use, with training before the employee is required to use a respirator.
| Item | What the text says | Paragraph |
|---|---|---|
| Medical evaluation | Provided before the employee is fit tested or required to use the respirator, by a PLHCP the employer identifies; the employer may discontinue it when the employee is no longer required to use one. | (e)(1), (e)(2)(i) |
| Fit testing | For tight-fitting facepiece respirators: before initial use, whenever a different facepiece (size, style, model or make) is used, and at least annually after that. | (f)(2) |
| Training | Comprehensive, understandable, recurring annually and more often if necessary; given before required use. | (k), (k)(3) |
Four conditions shape the written program. The PLHCP receives the respirator type and weight, duration and frequency of use, expected work effort, added protective clothing, temperature and humidity extremes, and a copy of the written program and the section before making a recommendation (e)(5). The PLHCP's written recommendation provides only the limits on respirator use, any need for follow-up and a statement that the employee received a copy (e)(6)(i). A new employee's training within the last 12 months can count if the employer can demonstrate it addressed the listed elements and the employee can demonstrate knowledge of them, and training not repeated at the start must be provided no later than 12 months from the date of the previous training (k)(4). Retraining is annual, plus when changes make earlier training obsolete, knowledge or use is inadequate, or retraining otherwise appears necessary (k)(5).
A tight-fitting facepiece may not be worn by an employee with facial hair that comes between the sealing surface and the face or interferes with valve function (g)(1)(i)(A).
What records does the standard require, and for how long?
- Fit test records: employee name or identification, type of test, make, model, style and size of respirator tested, date, and the pass or fail result or the fit factor and recording for quantitative tests (m)(2)(i). Retained for respirator users until the next fit test is administered (m)(2)(ii).
- The employer retains a written copy of the current program (m)(3).
- Medical evaluation records: retained and made available in accordance with 29 CFR 1910.1020 (m)(1). Its paragraph (d)(1)(i) sets at least the duration of employment plus thirty years, unless a specific standard provides a different period, except for three record types: health insurance claims records kept separately from the medical program; certain one-time minor first aid records; and records of employees with under one year of employment if provided to the employee on termination.
- Written materials are available on request to affected employees and to the Assistant Secretary or designee (m)(4).
Compliance with Appendices A, B-1, B-2, C and D is mandatory (o). This page does not summarize those appendices, breathing air quality (i), filter labeling (j) or the assigned protection factor tables; your safety professional confirms them against the full text.
How does IHS build a respiratory protection program?
IHS works as an outside drafting team under your administrator and safety professional, in five steps.
- Gap assessment against the text. IHS compares your documents to paragraphs (c) through (h), (k), (l) and (m) and lists what is missing.
- Record mapping. IHS maps each paragraph to its record.
- Drafting. IHS drafts the written program, the procedures, training plan, evaluation checklist, records forms and retention schedule. Your administrator and safety professional approve each one.
- Mock review. IHS reads the finished program as a reviewer would and traces a sample employee to the evaluation, fit test and training record.
- Readiness support. IHS drafts a records index and one-page summary.
What you supply: which respirators are used, by whom and where; the hazard evaluation; the PLHCP; fit testing capability or a vendor; and a trained program administrator.
The real limit: IHS drafts the paperwork. IHS does not perform medical evaluations, fit tests or training, and does not communicate with OSHA or a state plan for you. Your safety professional confirms specialized paragraphs and any state-plan variation.
IHS was founded in 2002 and is led by Thomas G. Goddard, JD, PhD, former Chief Operating Officer and General Counsel of URAC. IHS works across three practice lines: accreditation consulting, compliance services and program development.
What should a healthcare employer have ready for a respiratory protection review?
- The designated administrator and the basis for the person's qualification (c)(3).
- The written program with worksite-specific procedures (c)(1).
- The hazard evaluation behind each assignment (d)(1)(iii).
- The selection procedure, with NIOSH certification confirmed (c)(1)(i), (d)(1)(ii).
- The identified PLHCP, the information sent to the PLHCP, and the written recommendation for each employee (e)(2)(i), (e)(5), (e)(6).
- An inventory of respirators by make, model, style and size for each user, so a change triggers a new fit test (f)(2).
- Fit test records with the (m)(2)(i) contents, and training records showing training before use and annual retraining (k)(3), (k)(5).
- The program evaluation procedure and the notes from consulting employees who use respirators (c)(1)(ix), (l).
- A retention schedule for fit test, program and medical records (m).
If most of these do not exist yet, a free introductory call with IHS is the place to sort what to build first.
How does an outside program build compare with the other routes?
The routes are not exclusive. The table lists them without ranking them.
| Route | What it involves | Where the work sits |
|---|---|---|
| Generic or state model written program | A template the employer fills in. IHS did not review any for this page. | Your safety officer fits it to your workplace. |
| Occupational health vendor | Performs medical evaluations and fit tests. | The clinical and testing work, which IHS does not do. |
| Internal build | The safety officer writes the program and forms. | Your staff time, with no outside drafting capacity. |
| Outside drafting support (IHS) | IHS drafts the written program, procedures and records forms. | IHS drafts; your administrator approves and runs the program. |
What does a respiratory protection program build cost?
The section states no fee payable to OSHA for having a program. It assigns costs to the employer: respirators, training and medical evaluations are provided at no cost to the employee (c)(4), plus internal staff time for the administrator and safety professional. IHS scopes each engagement after a free introductory call and states no figure here.
What this is not
This is not legal advice. IHS is a consulting firm, not a law firm. Whether the standard applies to a particular job is a question for your safety professional and counsel.
It is not medical evaluation, fit testing or training, and it is not a guarantee of an inspection result. IHS does not communicate with OSHA or a state plan for you.
Frequently asked questions
What does OSHA 1910.134 require in a written respiratory protection program?
Where respirators are necessary to protect employee health or the employer requires them, paragraph (c)(1) calls for a written program with worksite-specific procedures. It names nine provisions "as applicable." IHS drafts the program for your administrator to approve.
Who administers a respiratory protection program?
The employer designates a program administrator "qualified by appropriate training or experience that is commensurate with the complexity of the program" (1910.134(c)(3)). IHS drafts the appointment.
When must medical evaluation happen relative to fit testing?
Before. The employer provides the medical evaluation before the employee is fit tested or required to use the respirator (1910.134(e)(1)), through a physician or other licensed health care professional (PLHCP) it identifies (e)(2)(i).
How often is fit testing required?
For a tight-fitting facepiece respirator: before initial use, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually after that (1910.134(f)(2)). Reported or observed physical changes that could affect fit call for another test (f)(3).
What training must respirator users receive and how often?
Training must be comprehensive, understandable, and recur annually and more often if necessary (1910.134(k)), and it comes before the employee is required to use a respirator (k)(3).
What records must an employer keep for respirator fit tests and medical evaluations?
Fit test records are kept for each respirator user until the next fit test is administered, and the employer keeps a written copy of the current respirator program (1910.134(m)(2)(ii), (m)(3)). Medical evaluation records follow 29 CFR 1910.1020 (m)(1).
Does a healthcare employer whose staff wear respirators voluntarily need a program?
Sometimes. The employer may allow voluntary use if it determines the use will not itself create a hazard, then gives users the Appendix D information and establishes the elements that keep them medically able and their respirators cleaned, stored and maintained (1910.134(c)(2)). Employees whose only use is voluntary use of filtering facepieces (dust masks) need not be included.
What changes in an employee trigger an additional fit test or medical evaluation?
A different facepiece (size, style, model or make) or a reported or observed physical change that could affect fit calls for a new fit test (1910.134(f)(2), (f)(3)). Additional medical evaluations follow, at a minimum, on reported medical signs or symptoms related to respirator use, a reevaluation request from a PLHCP, supervisor or program administrator, program information such as fit test observations, or workplace changes that may substantially raise the physiological burden (e)(7).
Related pages
See the Compliance Services overview | Compliance program development | ADA Title II web and mobile accessibility program for public health providers | Prison Rape Elimination Act standards compliance program.