Respiratory Protection: OSHA Requirements and Respirator Program Guide (2026)

Respiratory protection is one of the most frequently cited standards in OSHA’s general industry rulebook. The violations aren’t usually because employers don’t care. They hand out N95s or half-face respirators and figure that’s good enough. It isn’t.

29 CFR 1910.134 covers every aspect of respiratory protection, from when a written program is required to how often cartridges need to be changed. Getting this right protects workers. Getting it wrong puts you in front of an OSHA compliance officer.

When You Need a Written Respiratory Protection Program

The threshold is straightforward. If you require any employee to wear a respirator, you need a written respiratory protection program. That applies whether the hazard is a chemical, a dust, or an airborne pathogen.

Voluntary use changes the picture somewhat. If an employee wants to wear a filtering facepiece respirator (N95, N100) and you don’t require it, you only need to give them OSHA’s Appendix D informational sheet. No full written program required.

But if that voluntary respirator is a tight-fitting half-face or full-face air-purifying respirator, OSHA still requires a written program, medical evaluation, and fit testing. The distinction matters: filtering facepieces get the simplified path, tight-fitting respirators don’t.

Your written program must include procedures for selecting respirators, medical evaluations, fit testing, proper use, maintenance and storage, change-out schedules for cartridges, training, and program evaluation. It needs to be site-specific. A generic template doesn’t meet the standard.

Types of Respirators and When Each Is Required

The respirator you need depends on the hazard and the concentration. Here’s how to think through it.

Filtering facepiece respirators (N95, N99, N100) filter out particulates. The number tells you the filter efficiency: N95 filters 95% of airborne particles, N100 filters 99.97%. They have an Assigned Protection Factor of 10. That works for many common exposures but not for high-concentration environments.

Half-face air-purifying respirators cover the nose and mouth. They also have an APF of 10. But they accept interchangeable cartridges, so you can match the cartridge to the specific chemical hazard. Organic vapor cartridges for solvents, HEPA filters for fine particulates, combination cartridges for mixed environments. They’re the workhorse of most industrial respiratory protection programs.

Full-face air-purifying respirators add eye and face protection and jump to an APF of 50. Use these when your exposure measurement divided by the occupational exposure limit is between 10 and 50. They’re also the minimum for anything that causes severe eye irritation or can be absorbed through the eyes.

Supplied-air respirators and SCBAs are the heavy end. Supplied-air (Type C) runs a continuous flow of clean air through a hose from a compressor or tank. SCBAs carry the air supply on the wearer’s back. APF values reach 1,000 or higher depending on the mode of operation. These are required when air-purifying respirators can’t provide adequate protection, in oxygen-deficient atmospheres, or in IDLH (immediately dangerous to life or health) environments.

Assigned Protection Factors: What They Mean in Practice

The APF is how OSHA quantifies the protection level each respirator type provides to a properly fitted, properly trained user. To pick the right respirator, you calculate the hazard ratio: measured concentration divided by the occupational exposure limit (OEL). The respirator’s APF must meet or exceed that ratio.

If your air monitoring shows toluene at 150 ppm and the OSHA PEL is 200 ppm, you’re under the PEL. A respirator may not be required at all, depending on engineering controls. But if concentrations are at 500 ppm, your hazard ratio is 2.5. An N95 with APF 10 works mathematically, but you’d want cartridge selection based on the specific OEL and NIOSH certification.

At 2,000 ppm toluene, that’s a hazard ratio of 10. A half-face respirator at APF 10 is your minimum. At 5,000 ppm, you need a full-face unit at APF 50 or higher.

The math is simple. The mistake most programs make is skipping the air monitoring step and guessing at protection levels.

Fit Testing Requirements

Fit testing confirms that a specific respirator model and size creates an adequate seal on a specific employee’s face. It’s required before the first use and annually after that.

There are two types. Qualitative fit testing uses the worker’s senses to detect a test agent, typically saccharin (sweet) or Bitrex (bitter). The test agent is introduced into a hood around the wearer’s head. If they can taste or smell it, the seal isn’t adequate. Qualitative fit testing is acceptable only for half-face respirators and filtering facepieces.

Quantitative fit testing uses a machine to measure the actual concentration of a test agent inside and outside the respirator. It produces a fit factor number. For half-face respirators, you need a fit factor of at least 100. For full-face respirators, the minimum is 500. Quantitative testing is required for full-face respirators when used near or above a PEL.

Fit testing must be done for each specific make, model, and size. If you switch from one manufacturer’s half-face respirator to another, everyone needs to be retested. If an employee changes their facial hair significantly, or if they report that the fit feels different, you retest.

One practical point: employees need to be clean-shaven where the facepiece seals. Beards break the seal. This is a training point and a policy point. It needs to be in your written program.

Medical Evaluations: The Step Most Programs Skip

Before any employee wears a tight-fitting respirator, OSHA requires a medical evaluation. The employee completes OSHA’s Appendix C medical questionnaire and a licensed health care professional (PLHCP) reviews it and provides written clearance.

The medical evaluation catches conditions that make respirator use dangerous. Heart or lung disease, claustrophobia, and certain medications can all increase the strain of breathing through a respirator. An N95 increases the work of breathing. A full-face SCBA in firefighting conditions is extreme physiological stress.

The questionnaire is confidential. The employer never sees it. You get a clearance letter from the PLHCP that says yes, no, or yes with conditions. That’s all you’re legally entitled to.

Medical evaluations happen before fit testing, before initial use. If an employee reports a medical condition that might affect respirator use, you get a follow-up evaluation. The PLHCP may also require additional evaluations based on questionnaire responses.

This is the step that routinely gets skipped. Employers hand out respirators, log a quick training session, do fit testing, and assume they’re done. The medical clearance requirement catches up with them on inspection.

Cartridge Change-Out Schedules

Air-purifying respirators only work if the cartridges haven’t reached their end of service life. For particulate filters, you change them when breathing resistance increases noticeably or when they get damaged. For chemical cartridges, it’s more complicated.

OSHA requires you to have a change-out schedule that’s based on objective information. You can use NIOSH-approved end-of-service-life indicators (ESLIs) if they’re available for your cartridge. For most chemical cartridges, ESLIs aren’t available, so you need to calculate or reference a published schedule.

The schedule depends on the contaminant, the concentration, temperature, humidity, breathing rate (work rate), and cartridge capacity. Cartridge manufacturers publish service life data and some offer online calculators. NIOSH has published a chemical cartridge service life calculator as well.

End of shift is a common default, but it may be overly conservative for low concentrations. It may be dangerously liberal for high concentrations. Calculate it based on your actual exposure data from your air monitoring program.

Store partially used cartridges in sealed bags if you’re reusing them day to day. Log when each cartridge was first used.

Training Requirements Under 1910.134

Training must cover why respiratory protection is needed, what the limitations are, how to put on and take off the respirator correctly, maintenance and storage, and the medical evaluation and fit testing requirements. It must happen before the employee wears a respirator in a hazardous environment.

Annual retraining is required. You can reuse the same program year over year, but the training must be documented and dated. If an employee’s observed use shows they’re wearing it wrong, you retrain regardless of when the last session was.

Fit testing isn’t training. Many employers conflate them. Showing someone how to put on a respirator during fit testing counts toward training, but the full training requirement covers more ground than just donning and doffing technique.

If you’re putting together your employer safety training requirements across multiple OSHA standards, respiratory protection training integrates naturally into your broader safety training calendar.

Common Violations Under 1910.134

OSHA’s inspection data consistently shows the same failure points.

No written program is the most cited violation. Employers issue respirators without establishing the program first.

No medical evaluation is the second most common. It’s often paired with the first. No program means no medical evaluation procedure, which means employees are wearing respirators without clearance.

No fit testing or inadequate fit testing covers situations where employers use a single person’s fit test for an entire workforce, or where fit testing happened years ago and was never repeated.

Failure to train shows up frequently in citations involving filtering facepiece use. Employers distribute N95s during high-dust operations without any documentation that employees understand how to use them.

The written program itself is also frequently cited as deficient even when it exists. Generic programs downloaded from the internet don’t cover site-specific procedures, hazards, or change-out schedules. OSHA wants to see your program, not a template.

Running OSHA 30 training for general industry gets safety leads and supervisors grounded in how these programs fit together. The 29 CFR 1910 standards don’t exist in isolation.

A full workplace PPE review that goes beyond respirators is worth doing alongside this program. The personal protective equipment guide covers the broader hierarchy.

Start Here: Get Medical Evaluations Done First

If your respiratory protection program is incomplete or hasn’t been set up yet, start with medical evaluations. It’s the requirement most programs skip. And it’s the one that can create genuine liability if an employee has a cardiac event while wearing an SCBA and there’s no medical clearance on file.

Get your PLHCP relationship set up. Distribute the Appendix C questionnaires. Build that into your onboarding process so new employees can’t start wearing respirators before clearance is documented.

Everything else in the program, the written document, fit testing, change-out schedules, training, builds on a foundation that includes medical clearance for every employee who wears a tight-fitting respirator. Get that step right and the rest of the program is far easier to build correctly.