Post on 15-Aug-2020
Long-term care (LTC) facility generic respiratory protection program
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
1. BACKGROUND AND PURPOSE
The COVID-19 Pandemic created a need for workers at
LTC facilities to use respirators to protect themselves
from people (patients and residents) who are exhibiting
symptoms of the disease. Almost all of these LTC
facilities have previously used face masks in the normal
course of their business but most have never actually
required the use of respiratory protection as defined
by OSHA in their standards. This all changed in early
March of 2020 when it became clear that LTC workers
needed to protect themselves from potential exposure
to the airborne COVID-19 virus from infected residents
and patients.
OSHA requires employers to develop a site-specific
Respiratory Protection Program (RPP) if employees are
required to use respirators in performing their job. The
current Pandemic has put LTC facilities in a position to
require their employees to wear respirators when they
are in close proximity to people who are potentially
ill with the COVID-19 disease. This Generic RPP
has been designed as a guideline for LTC Facilities to
develop their own site specific RPP and can be used as
a template to assist in meeting this OSHA requirement.
Even though we have attempted to meet the OSHA
RPP requirements for LTC facilities we recognize that
each LTC facility is unique in many ways. Therefore we
cannot guarantee that this Generic RPP plan covers all
the various activities and operations of all LTC facilities.
This RPP guideline is focused on LTC facilities to create a
procedure for the use and care of respiratory protective
equipment at LTC Facilities providing skilled nursing and
sub-acute rehabilitative services.
This program addresses the respiratory protection
requirements for the staff of the LTC facility with a focus
on current issues during the COVID-19 Pandemic. The
objective is to ensure that the practices are in compliance
with Occupational, Safety and Health Administration
(OSHA) guidelines and requirements and applicable
CDC guidelines.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
2. SCOPE
3. INTERIM POLICIES FOR COVID-19
This program applies to all LTC Facility employees who
are required to wear a face mask or respirator while
performing a job task; and for those employees who
voluntarily use a face mask or respiratory protection.
We have limited our respirator use to only Filtering
Facepiece Respirators (FFRs). If the LTC Facility also
intends to use other respirators, such as air-purifying
elastomeric respirators or Power Air-Purifying
Respirators (PAPRs), then this must be added to the
site-specific RPP and is not covered in this Generic Plan.
The COVID-19 Pandemic created the need to make
many modifications to the use of face masks and
respirators. Many of these modifications clearly did not
meet the requirements and regulations under the OSHA
respirator standard. Many of these modifications were
permitted by OSHA recognizing that the Pandemic
created a crisis that necessitated lifting certain rules and
requirements so some level of respiratory protection
could be offered to employees of LTC facilities. These
policy changes are available on the OSHA.gov website
at:
www.osha.gov/SLTC/covid-19/news_updates.html
As the Pandemic subsides it is anticipated that many of
the interim respiratory protection policy changes made
by OSHA will be reversed and the full requirements of
the OSHA respirator standard will be enforced. When
this occurs this plan will need to be reviewed and
updated to meet the then current OSHA requirements.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
4. DEFINITIONS
4.1 Air Purifying Respirator (APR)
A respirator which is designed to remove air
contaminants (i.e. dust, fumes, mists, gases, vapors,
or aerosols) from the ambient air as the air enters
the respirator.
4.2 Approved Respirator
A respirator which has been tested, found to meet
established performance criteria, and listed as
being approved by NIOSH (National Institute of
Occupational Safety and Health).
4.3 Face-Mask
A covering over the nose and mouth of various
substances such as cloth, fortified paper, and other
filtration material. It is not expected that the Face-
Mask will pass a Qualitative Fit-test.
4.4 Filtering Facepiece Respirator (FFR)
A negative pressure particulate respirator with a
filter as an integral part of the face piece or with the
entire face piece composed of the filtering medium.
Typically the filtering medium is at minimum classified
as an N-95 or greater. It is expected that the FFR will
pass a Qualitative Fit-test.
4.5 OSHA and the OSHA respirator standard
The Occupational Safety and Health Administration
provides regulations on the use of respirators
(29CFR1910.134)
www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134
Some states (22) have their own State-OSHA respirator
requirements that will meet or exceed Federal OSHA.
This is the link of states with OSHA programs:
www.osha.gov/stateplans
4.6 NIOSH and NIOSH certification of respirators
The National Institute of Safety and Health is a federal
governmental agency under the Center for Disease
Control (CDC) and is the primary US Agency to test
and approve (certify) respirators. Only NIOSH certified
respirators were permitted to be used under the OSHA
respirator standard. This requirement has been lifted
during the COVID-19 Pandemic due to the lack of supply
of available NIOSH certified respirators. See link for
alternatives:
Enforcement Guidance for Use of Respiratory Protection Equipment Certified under Standards of Other Countries During the Coronavirus Disease 2019 (COVID-19) Pandemic. (April 3, 2020).
4.7 N-95 FFR
This refers to the ability of a filtering material to remove
particles of all sizes which will include the very small size
of the COVID-19 virus. The 95 refers to the requirement
that the material filters out 95% of particles at a size
of 0.3 microns (which is the size considered to be the
most difficult to filter). To determine if an N-95 FFR
is protective, it should also be certified by NIOSH and
successfully pass a qualitative fit-test. Other country
certifications (i.e. KN-95 by China) may not meet the
NIOSH criteria and may not successfully pass a fit-test.
If they cannot be successfully fit-tested then these FFRs
will be considered a face mask only.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
5. RESPONSIBILITIES
5.1 Respiratory Protection Program (RPP) Administrator
■ Responsible for administrating and overseeing
the Respiratory Protection Program (RPP) and
conducting the required evaluations of program
effectiveness required by 29 CFR 1910.134.
■ Reviews and revises the RPP as required by work
area, job tasks or regulation change and ensure
compliance with current federal, state and
local regulations.
■ Performs hazard assessments and exposure
assessments to determine the respiratory
protection requirement.
■ Issues approved respiratory protective equipment
to employees that have been cleared medically for
respirator use.
■ Periodically audits work areas and respiratory
storage areas to insure proper use and maintenance
of respiratory protective equipment.
■ Schedules annual fit testing and training for
all employees that use respiratory protective
equipment.
5.2 Supervisors
■ Notifies RPP Administrator of any operative changes
or new operations so that a hazard assessment
and/or exposure assessment can be performed to
determine the need for respiratory protection.
■ Receives training in the elements of the RPP.
■ Ensures that all staff have been medically cleared, fit
tested, trained, and have received a respirator from
the RPP Administrator prior to being assigned a task
requiring respirator use.
5.3 Staff
■ Receive training in the elements of the RPP.
■ Must be medically cleared and fit tested prior to
using respiratory protection.
■ Receive training in the use and limitations of
respiratory protection.
■ Uses proper respiratory protection when required.
■ Maintains respiratory protective equipment by
cleaning and storing properly.
4.8 Qualitative Fit Test
A pass/fail fit test to assess the adequacy of a respirator
fit that relies on the individual’s response to the test
agent. This is the typical fit-test required for a FFR.
4.9 Quantitative Fit Test
An assessment of the adequacy of a respirator fit by
numerically measuring the amount of leakage into
the respirator.
4.10 Respirator
Any device worn by an individual and intended to provide
the wearer with respiratory protection against inhalation
of airborne contaminants or oxygen-deficient air.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
6.1 Risk Designations
LTC Facility has identified the following current
operations where respiratory protection is required
during the COVID- 19 Pandemic (the LTC Facility has
to identify what specific job classification or titles that
would fit into these three risk areas). The designations
below are:
6.2 Filtering Face Pieces
For protection of staff from the COVID-19 virus and
other potential infectious diseases identified by the
LTC Facility pursuant to CDC Guidelines and alerts,
the required respiratory protection for all user groups
will consist of a filtering face piece respirator such as a
N95 or equivalent.
6.3 Post COVID-19
Once the Pandemic is over and there are no infectious
diseases of concern identified by the CDC rising to
the level of COVID-19, then the LTC Facility can
downgrade it’s High Risk classifications to Medium
so Respirators are no longer mandated for those
job functions.
6. REQUIREMENTS
Low Risk
Medium Risk
High Risk
staff with direct resident contact
(within 6 feet for >10 minutes):
■ Medical staff (physicians, nurses, nursing aides)
■ Occupational and physical therapists
staff with minimal direct contact
(< 6 feet for short periods of time <10 minutes)
■ Housekeeping, custodial, and maintenance staff
■ Food service staff
staff with incidental or no direct contact
(< 6 feet for short periods of time <5 minutes)
■ Administrative personnel
■ Kitchen Staff
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
7.1 Application
This procedure outlines the selection, use, and
maintenance of respiratory protective equipment at
LTC Facility as required by 29 CFR 1910.134 (OSHA’s
Respiratory Protection Standard) and LTC Facility’s
internal policy. All employees who use respiratory
protective equipment, or manage those who use
respiratory protective equipment, shall be trained in
the content of this procedure.
7.2 Engineering and Administrative Controls
LTC Facility utilizes engineering and administrative
controls when feasible. Engineering controls include
physical barriers between residents/patients and
staff. Administrative controls include staff rotation
to minimize contact as much as possible. If these
controls are not feasible, or not effective, appropriate
respiratory protective equipment is used. Respiratory
protection will meet the requirements as outlined in
29 CFR 1910.134.
7.3 Respirator Selection
Respirators certified by the National Institute for
Occupational Safety and Health (NIOSH) must be
selected and used in compliance with the conditions of
its certification. In accordance with the April 3, 2020
guidance provided by OSHA, respirators manufactured
in other countries that are certified by that other
country’s standards may be used if they successfully
pass a qualitative fit-test.
Respirators must be selected on the basis of the
respiratory hazard(s) in the work area and user factors
that affect respirator performance and reliability.
7.4 Respirator Fit Testing
Each employee required to wear a respirator shall be
fit tested using accepted fit test methods as described
in 29 CFR 1910.134, Appendix A. The fit testing
requirements include:
■ Qualitative or Quantitative fit testing must be
performed prior to initial use of respirators.
■ 29 CFR 1910.134 states fit testing must be
performed at least annually thereafter. A March
3, 2020 memorandum released by OSHA states
that field offices will use discretion regarding
the annual fit testing requirements as long as the
employer has made a good-faith effort to comply
with the requirements of the Respiratory Protection
Standard.
■ Quantitative fit testing must be performed for
respirators with a Fit Factor greater than 100
(e.g. full-face air purifying respirator). Generally
Quantitative fit testing is not conducted on
N-95 FFR. A qualified person must administer fit
testing. The person performing the fit testing will
provide required documentation of the fit test
protocol(s) used and results.
■ Fit tests shall be performed using the same make,
model and size of respirator to be worn. The March
3, 2020 memorandum released by OSHA states that
field offices will use discretion when an employer has
switched to a similar make/model due to shortages of
respiratory protection.
■ A user seal test following Appendix B-1, 1910.134
(Attachment A) must be performed immediately
after donning and adjusting the respirator, each time
a respirator is used.
7. PROCEDURE
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
7.5 Respirator Training
Employees required to wear respirators must be
trained before wearing a respirator. Training must
be comprehensive and understandable. It must be
performed prior to requiring the employee to use a
respirator and annually thereafter.
The following, as a minimum, shall be included in
the training:
■ Why the respirator is necessary
■ How improper fit, usage, or maintenance can
compromise the respirator.
■ The limitations and capabilities of the respirator.
■ How to use the respirator effectively in
emergency situations.
■ How to inspect, don, doff, and seal check
the respirator.
■ Procedures for maintenance and storage of
the respirator.
■ Recognizing medical signs and symptoms that
may limit the respirator use.
7.6 Respirator Maintenance and Care
■ Respirators shall be properly maintained and be
in working order.
■ Respirators that are not functioning properly
shall be removed from use by turning in to the
RPP Administrator.
■ Respirators must be stored to protect them from
damage, contamination, dust, sunlight, extreme
temperatures, excessive moisture, damaging
chemicals, and to prevent deformation of the
face piece.
7.7 Respirator Inspection
■ Respirators must be inspected as follows and must
include a check of respirator function, tightness of
connections, and the condition of the various parts
of the respirator, including a check of the elastomeric
parts for pliability.
7.8 Filtering Face Piece Respirator Use and Reuse
Donning (Putting the respirator onto the face)
■ Wash hands and use hand sanitizer
■ Put gloves on clean and dry hands
■ Don filtering face piece respirator (N95 or
equivalent). Avoid touching the inside of the
respirator. If inadvertent contact is made with the
inside of the respirator, perform hand hygiene as
described above.
■ Use a pair of clean (non-sterile) gloves when donning
a used filtering face piece respirator and performing a
user seal check. Discard gloves after the filtering face
piece respirator is donned and any adjustments are
made to ensure the respirator is sitting comfortably
on your face with a good seal.
■ Don fresh pair of gloves
Doffing (Removing the respirator from the face)
■ Remove gloves and place in garbage bag
■ Clean hands with soap and water. If soap and water is
not available, disinfectant wipes or hand sanitizer may
be used.
■ Don fresh pair of gloves on dry hands
■ Remove gloves and place in garbage bag
■ Don fresh pair of gloves on dry hands
■ Remove N95 (or equivalent) and place in a clean
paper bag. Avoid touching the inside of the respirator.
■ Remove gloves and discard in garbage bag
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
Reuse
■ Wash hands and use hand sanitizer
■ Put gloves on clean and dry hands
■ Remove N95 (or equivalent) from paper bag;
discard bag
■ Follow protocol in Sections 6.3.1 (Donning) and
6.3.2 (Doffing)
■ N95s (or equivalent) may be reused if they meet the
following criteria:
■ No obvious contamination or heavy soiling
of respirator
■ Not deformed; has original shape
■ Straps still functional – holds respirator tight
to face
■ Not obviously damaged or has become hard to
breathe through
■ Stored correctly in a clean paper bag
■ Follow manufacturer’s guidance on # of times it can
be re-used, or CDC/NIOSH guidance of no more than
5 uses. For reuse guidance see:
www.cdc.gov/niosh/topics/hcwcontrols/recommendedguidanceextuse.html
Disinfecting N95 (or equivalent)
■ Do not use alcohol or any type of cleaner on the
filtering face piece respirator.
■ If available, use UV-C light according to instructions
that come with the light to kill pathogens on the
surface. (Note – there is no guarantee pathogens that
are not touched by UV-C light will be killed, but the
“bioburden” should be substantially reduced).
■ Ensure employees understand the hazards of UV-
light to their own skin and eyes, and use appropriate
controls/PPE
■ If available, use any other disinfection method
appropriate, such as ozone chamber treatment
Storage
■ N95 (or equivalent) is to be stored in a clean paper
bag in a clean and dry area
■ Employee’s name and number of uses are to be
written on the paper bag
7.9 Respirator Repair
■ Respirators that fail an inspection or are otherwise
found to be defective are removed from service
and discarded.
7.10 Medical Surveillance
■ Employees assigned to tasks requiring the use of
respirators shall be medically evaluated to determine
if they are physically able to wear respirators without
posing a physical hazard. These determinations
must be made prior to any use, including fit testing,
and must be completed by a physician or licensed
health care professional (PLHCP). These medical
evaluations shall be reviewed periodically as
deemed appropriate by the physician or RP
Administrator or if there are medical reasons
to evaluate the employee.
■ The following information must be provided to the
physician or licensed health care professional
before a medical determination can be made:
■ Type and weight of respirator that is to be used
■ Duration and frequency of respirator use
■ Expected physical work effort
■ Additional protective clothing and equipment to
be worn;
■ Temperature and humidity extremes that may
be encountered
■ Written copy of this respiratory protection
program.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
■ A written recommendation must be obtained from the
PLHCP. The recommendation will provide information
on any limitations on respirator use. Additional medical
evaluations must be provided if any of the following
occurs:
■ An employee reports medical signs or symptoms that
are related to ability to use a respirator.
■ A PLHCP, supervisor, or the Respirator Program
Administrator determines that an employee needs
to be reevaluated.
■ Information from the respiratory protection program,
including observations made during fit testing and
program evaluation, indicates a need for employee
reevaluation.
■ A change occurs in workplace conditions that may
result in a substantial increase in the physiological
burden placed on an employee.
■ The Medical Surveillance questionnaire can be found
in the OSHA regulation 29 CFR 1910.134 Appendix C.
7.11 Special Considerations in Respirator Use
Facial Hair
■ Respirators shall not be worn when conditions prevent
a good respirator face piece-to-face seal. Persons with
facial hair that interferes with the face piece-to-face
seal or the operation of the inhalation or exhalation
valves shall not be permitted to wear or be fitted with
a respirator until such conditions are corrected.
Eyeglasses & Corrective Lenses
■ Employees with eyeglass temple pieces which interfere
with the face piece-to-face seal of the respirator shall
not be permitted to wear or be fitted with a respirator
until such conditions are corrected.
■ If corrective lenses are required, contact lenses or
special lens holding devices which do not interfere
with the face piece-to-face seal may be utilized.
7.12 Recordkeeping
■ Records of employee exposure, monitoring, medical
surveillance, training, inspection and maintenance
will be maintained in accordance with the
requirements of 29 CFR 1910.134.
■ Fit Tests
Records of qualitative and/or quantitative fit tests
shall be maintained until the employee’s next fit test.
The records must include the name and identification
of employee, type of fit test performed, make, model,
style, and size of respirator tested, date of fit test, and
fit test results.
■ Medical Evaluations
Records of the employees’ medical evaluation
indicating that they are capable of wearing a tight-
fitting facepiece will be maintained for the length of
their employment plus 30 years.
7.13 Program Evaluation
The Respiratory Program Administrator shall, at
least annually, conduct periodic evaluations of the
Respiratory Protection Program. The Respiratory
Program Administrator should:
■ Consult with users to determine program acceptance
■ Conduct inspections of respirator use
■ Review required records.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
7.14 Voluntary Use of Respiratory Protection
■ Respirators will be provided at no charge to
employees for voluntary use.
■ The Respiratory Program Administrator will provide
all employees who voluntarily choose to wear
respirators with a copy of Appendix D of OSHA’s
Respiratory Protection Standard (Attachment B).
Appendix D details the requirements for voluntary
use of respirators by employees. Employees choosing
to wear a half face piece APR must comply with the
procedures for Medical Evaluation, Respirator Use,
and Cleaning, Maintenance and Storage.
■ The Respiratory Program Administrator shall
authorize voluntary use of respiratory protective
equipment as requested by all workers on a case-
by-case basis, depending on specific workplace
conditions and the results of the medical evaluations.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
ATTACHMENT A – 29 CFR 1910.134 Appendix B ATTACHMENT B – 29 CFR 1910.134 Appendix D
Appendix B-1 to § 1910.134: User Seal Check
Procedures (Mandatory)
The individual who uses a tight-fitting respirator is to
perform a user seal check to ensure that an adequate
seal is achieved each time the respirator is put on.
Either the positive and negative pressure checks listed
in this appendix, or the respirator manufacturer’s
recommended user seal check method shall be used.
User seal checks are not substitutes for qualitative or
quantitative fit tests.
I. Facepiece Positive and/or Negative Pressure Checks
A. Positive pressure check. Close off the exhalation
valve and exhale gently into the facepiece. The face fit is
considered satisfactory if a slight positive pressure can
be built up inside the facepiece without any evidence of
outward leakage of air at the seal. For most respirators
this method of leak testing requires the wearer to first
remove the exhalation valve cover before closing off the
exhalation valve and then carefully replacing it after the
test.
B. Negative pressure check. Close off the inlet opening
of the canister or cartridge(s) by covering with the
palm of the hand(s) or by replacing the filter seal(s),
inhale gently so that the facepiece collapses slightly,
and hold the breath for ten seconds. The design of the
inlet opening of some cartridges cannot be effectively
covered with the palm of the hand. The test can be
performed by covering the inlet opening of the cartridge
with a thin latex or nitrile glove. If the facepiece remains
in its slightly collapsed condition and no inward leakage
of air is detected, the tightness of the respirator is
considered satisfactory.
II. Manufacturer’s Recommended User Seal CheckProcedures
The respirator manufacturer’s recommended
procedures for performing a user seal check may be
used instead of the positive and/or negative pressure
check procedures provided that the employer
demonstrates that the manufacturer’s procedures are
equally effective.
Appendix D to Sec. 1910.134 (Mandatory)
Information for Employees Using Respirators
When Not Required Under the Standard
Respirators are an effective method of protection
against designated hazards when properly selected
and worn. Respirator use is encouraged, even when
exposures are below the exposure limit, to provide an
additional level of comfort and protection for workers.
However, if a respirator is used improperly or not kept
clean, the respirator itself can become a hazard to the
worker. Sometimes, workers may wear respirators
to avoid exposures to hazards, even if the amount of
hazardous substance does not exceed the limits set by
OSHA standards. If your employer provides respirators
for your voluntary use, or if you provide your own
respirator, you need to take certain precautions to be
sure that the respirator itself does not present a hazard.
You should do the following:
1. Read and heed all instructions provided by the
manufacturer on use, maintenance, cleaning and care,
and warnings regarding the respirator’s limitations.
2. Choose respirators certified for use to protect against
the contaminant of concern. NIOSH, the National
Institute for Occupational Safety and Health of the U.S.
Department of Health and Human Services, certifies
respirators. A label or statement of certification should
appear on the respirator or respirator packaging. It will
tell you what the respirator is designed for and how
much it will protect you.
3. Do not wear your respirator into atmospheres
containing contaminants for which your respirator
is not designed to protect against. For example, a
respirator designed to filter dust particles will not
protect you against gases, vapors, or very small solid
particles of fumes or smoke.
4. Keep track of your respirator so that you do not
mistakenly use someone else’s respirator.
The undersigned has read and understands this procedure:
Printed Name:
Signature:
Date:
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
Prioritizing efforts to acquire and use equipment in the
following order:
■ NIOSH-certified equipment; then
■ Equipment certified in accordance with standards of
other countries or jurisdictions except the People’s
Republic of China, unless equipment certified in
accordance with standards of the People’s Republic
of China is manufactured by a NIOSH certificate
holder[6]; then
■ Equipment certified in accordance with standards of
the People’s Republic of China, the manufacturer of
which is not a NIOSH certificate holder[6]; then
■ Facemasks (e.g., medical masks, procedure masks).
[6] According to the National Institute for Occupational
Safety and Health (NIOSH), it has observed that
products from the People’s Republic of China may not
meet the requirements of the standards to which they
are certified and may not offer or sustain the protection
claimed as typically expected when using NIOSH-
approved N95 respirators. However, devices supplied by
current NIOSH approval holders producing respirators
under the standards authorized in the countries and/
or jurisdictions addressed in this memorandum are
expected to provide the protection indicated, given that
a proper fit is achieved.
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LONG-TERM CARE (LTC) FACILITY GENERIC RESPIRATORY PROTECTION PROGRAM
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