Cal/OSHA Covid Standard PPE Requirements

June 15, 2021

There's been significant confusion regarding recent updates to the Cal/OSHA’s Covid-19 standard. After controversial revisions on June 3rd, 2021, there was another round of changes approved June 17th by the Department of Industrial Relations Standards board, and made effective immediately by executive order.

The most confusion seems to be regarding (D) Personal protective equipment.

To better understand Cal/OSHA’s convoluted and hasty attempts at regulating here, it helps to understand there are two broad categories of respirator use in the workplace. Side note: N95 filtering facepieces (aka: “N95 masks”) ARE respirators.

RESPIRATOR USE TYPES

Mandatory Respirator Use

Use of a respirator is required by the hazard or regulation. Employees must wear the respirator, they can’t choose not to. This has very comprehensive requirements that are explained in more depth in this article. But, in summary, the following requirements apply:

Written Program: The employer must have a comprehensive written respiratory program compliant with Cal/OSHA §5144(c)(1), and have an administrator in charge of the program.
Medical Approval: Required for all respirator users.
Training: Comprehensive training on respiratory protection and respirator use.
Fit Testing: Required for the specific model/size the employee is wearing at work.

Voluntary Respirator Use

Respirator use is optional for the employee. The employer has provided respirators for employees to use if they would like to (to feel more comfortable, to reduce levels of contamination that might be annoying but are not known to be harmful). Important point: You can't make a respirator situation "voluntary" just by decided you won't require respirators, it has to be justified that the risk is low enough to not require respirators.

Written Program: The employer should have a simple written respiratory program compliant with §5144(c)(2), and have an administrator in charge of the program.
Medical Approval: Medical approvals only for reusable elastomeric respirators (the rubber or silicone masks with filters on the side). No medical approval is required for filtering facepieces like “N95 masks.”
Training: Simple information on the basics of voluntary respirator use. With some minor modifications adding info on when voluntary use is most encouraged, you could make a handout or short training slide using Cal/OSHA appendix D.
Fit Testing: Not required.

Now, in the past, voluntary programs were at the discretion of the employer, if they wanted to have one. What we’re seeing here in the Covid standard is Cal/OSHA mandating that employers implement a voluntary program, and make respirators available for certain employees that want one. This isn’t totally unprecedented, as they have a similar requirement for outdoor workers when there’s heavy wildfire smoke: employees don't have to wear the respirator, but the employers must make them available.

REGULATORY ANALYSIS
With this understanding, let’s get into the text of the recently approved regs, specifically (E) Personal protective equipment. Regulation in black, Safewest commentary in color.

(D) Personal protective equipment.

1. Employers shall evaluate the need for personal protective equipment to prevent exposure to COVID-19 hazards, such as gloves, goggles, and face shields, and to provide such personal protective equipment as needed.

This is safety 101; employers should always do an assessment of workplace hazards, and provide PPE if needed. A safety program that doesn't operate under this concept has far bigger problems that complying with the nuances of Cal/OSHA's revised Covid 19 standard.

2. Upon request, employers shall provide respirators for voluntary use in compliance with subsection 5144(c)(2) to all employees who are not fully vaccinated and who are working indoors or in vehicles with more than one person.

This is referring to VOLUNTARY use. This requirement to provide a respirator only applies if all these conditions are met:

An employee it not vaccinated
That employee works indoors or rides in a vehicle with others
That employee wants a respirator

In this situation, the employer should make respirators available, and make sure they've had simple training on voluntary use. A written program is still required. A medical evaluation may be required (see the first section "RESPIRATOR USE TYPES"). A fit test is NOT required.

This may not be as burdensome as some employers assume...the vast majority of unvaccinated persons also don't think Covid-19 is a serious concern; they're not likely to want a respirator.

Whenever an employer makes respirators for voluntary use available, under this section or sections 3205.1 through 3205.4, the employer shall encourage their use and shall ensure that employees are provided with a respirator of the correct size.

This is very confusing (and Cal/OSHA is notorious for not providing written interpretations of convoluted standards)...it’s not clear how an employee shall ensure employees are provided with a respirator of the correct size without doing a fit test. However, fit testing is not and has never been required for voluntary respirator use. I think a good faith effort here would be to make sure you have a smaller size option if you have employees with smaller faces, or providing a single respirator model that fits a wide range of employee face sizes, and provide alternatives based on employee feedback.

3. Employers shall provide and ensure use of respirators in compliance with section 5144 when deemed necessary by the Division through the Issuance of Order to Take Special Action, in accordance with title 8, section 332.3.

This is referring to MANDATORY use, in scenarios where Cal/OSHA, under authority in 332.3, has told a specific employer or group of employers they need to have a respirator program. If this applied to your organization, you would almost certainly know it and already be dealing with Cal/OSHA.

4. Employers shall provide and ensure use of eye protection and respiratory protection in compliance with section 5144 when employees are exposed to procedures that may aerosolize potentially infectious material such as saliva or respiratory tract fluids. NOTE: Examples of work covered by subsection (c)(7)(D)4. include, but are not limited to, certain dental procedures and outpatient medical specialties not covered by section 5199.

This is referring to MANDATORY use, and applies primarily to medical clinics and certain research settings where employees are potentially exposed to aerosolized human body fluids. A more detailed hazard assessment is required for these industries, but if there is potential exposure, all the elements of a mandatory respirator program (written program, medical approvals, fit testing, and training, and all required annual renewals) must be implemented.

Need help? Safewest provides consulting, written program development, and onsite respiratory protection services including training and fit testing.

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Counterfeit Respirators: A Preventable Purchasing Failure

By carlo • December 20, 2025

Respirator facepieces, cartridges, and filters are routinely counterfeited. Most buyers cannot verify whether what they received is authentic, and the marketplace isn’t set up to ensure authenticity. Respiratory protection is especially vulnerable to counterfeits because the most safety-critical functions cannot be confirmed by visual inspection. A trained eye might catch subtle tells, inconsistent molding marks, off-color materials, or printing and labeling errors. But appearance does not verify performance. You cannot reliably determine by sight whether a cartridge contains the correct sorbent, whether a particulate filter actually meets its required performance rating, or whether facepiece materials and components will maintain a stable seal under real-world conditions over time. A respirator’s protective performance is driven by materials and manufacturing tolerances, including the composition and consistency of the facepiece elastomer, the integrity of the lens and frame, strap and buckle hardware strength and elasticity, sealing surface geometry, and the design and quality of inhalation and exhalation valves. Small substitutions or dimensional changes can materially affect fit, seal reliability, and durability. For filter cartridges, protection depends on the correct filter media or sorbent formulation, a reliable seal between the cartridge and the facepiece, and internal construction that controls airflow distribution and loading. Substitutions in media, sorbent, adhesives, gaskets, or internal geometry can reduce protection immediately and may lead to premature chemical breakthrough or inadequate filtration performance. Because these performance characteristics cannot be confirmed by inspection, the only practical safeguard is a verifiable supply chain. When chain of custody is unclear, the buyer has no defensible basis to trust authenticity, certification, or performance. The risk is highest when products come from online marketplaces like Amazon, especially third-party sellers, liquidators, or “new in box” resellers with no traceable sourcing. Commingled inventory practices, where “identical” products from different sellers can be pooled in warehouses, further increase the risk of counterfeit products entering the supply chain. Despite specifically advising clients not to purchase PPE, especially respirators, from Amazon, eBay, or similar online marketplaces, we are seeing this guidance disregarded. We arrive to fit test respirators that show subtle differences from the authentic 3M products we supply. In multiple cases, those units are ultimately confirmed as counterfeits purchased through the exact sources we advised against. Using price as the primary, or only, selection criterion for a personal protective equipment vendor is irresponsible. The employer owns the consequences of negligence in purchasing. If there’s an exposure incident, an injury, or an audit, “we got it online” or "it had free Prime shipping" is not a defense. Workers notice too. When employees don’t trust the gear, company safety culture quietly collapses. Buy PPE through: - Authorized distributors - Direct from the manufacturer - Established industrial or safety suppliers with traceability

The Important Difference Between a Shop Vac with HEPA Filters and a HEPA-rated Dust Extractor

October 27, 2025

At a glance, a shop vacuum with a HEPA filter and a dedicated HEPA-rated dust extractor might seem to do the same job: collect dust and debris. In reality, the difference between them is substantial, especially for fine particulate control, worker protection, and regulatory compliance. Adding a HEPA filter to a standard shop vacuum improves filtration, but it doesn’t turn the unit into a true HEPA-rated system suitable for hazardous dust. Key takeaway: If you’re collecting fine dust from hazardous materials, use an extractor designed and certified for that purpose. Don’t rely on a shop vac with a retrofit HEPA filter. Here’s why: Most shop vacs leak around seals or bypass fine dust through motor vents, even if they use a HEPA filter. A proper dust extractor is designed from the ground up for fine dust control. All seals, gaskets, and joints are engineered to prevent leakage, and the entire system, not just the filter, is tested to meet HEPA performance. Shop vacs are built for high pulling force (static pressure) to pick up debris, nails, or sawdust through hoses. Dust extractors are designed to steadily move larger volumes of air (airflow) and catch fine, respirable dust particles before they disperse. Shop vacs clog quickly when used on fine dust; when the filter clogs, vacuum pressure drops, and more dust escapes into the air. Dust extractors include self-cleaning or pulse-clean mechanisms that shake accumulated fine dust off the filter. This leads to consistent pressure levels, and extends filter life. A shop vac is meant for short-term cleanup. Dust extractors are designed for longer periods of use, often with features like automatic tool-start functions, variable speed control, anti-static hoses, and spark-resistant motors for combustible dust safety. For operations covered under Cal/OSHA or Federal OSHA silica standards, or for controlling other hazardous respirable dusts like carbon, graphite, metals, wood, or asbestos, a simple shop vac with a HEPA filter is not sufficient. Hazardous materials require commercial-grade HEPA-filtered dust collection systems engineered and tested for fine particulate containment and exposure control.

Respirator Cartridge Changeout Schedules

By • August 31, 2025

Respirator cartridges for gas or vapor protection have a limited service life. They need to be changed before they become saturated and can no longer purify the air effectively. If an employer is using air-purifying respirators for protection against gases and vapors, Cal/OSHA T8 §5144(d)(3)(C) requires that the employer either: Use a cartridge with an end-of-service-life indicator (ESLI) that provides an indication to the user that the cartridge has reached the end of its service life. Unfortunately, ESLI cartridges are not available for most chemicals. Implement a time-based cartridge changeout schedule. This must be, per Cal/OSHA, “based on objective information or data that will ensure that ... cartridges are changed before the end of their service life. The employer shall describe in the respirator program the information and data relied upon and the basis for the ... cartridge change schedule.” Relying on users to detect the end of the cartridge service life by smell, taste, or irritation of the chemical passing through is not compliant as a primary method for cartridge changeout. It may be used only as a secondary safeguard to the employer's time-based changeout schedule. This is a common mistake: an employer identifies a potential respiratory hazard, buys respirators, and provides fit testing - yet skips the crucial step of a formal, documented hazard assessment and changeout schedule. For gas or vapor exposures, your written program should clearly specify: • The correct respirator type for the task • Appropriate cartridge or combination filter-cartridge • A time-based changeout schedule supported by data Safewest can help develop or review your respirator program, including hazard assessments and cartridge change schedules. Contact us to make sure your program is compliant and your employees are protected.

Hazwoper Training Levels

By carlo • January 27, 2025

HAZWOPER (Hazardous Waste Operations and Emergency Response) training requirements apply to certain operations involving hazardous waste. These requirements dictate the amount, type and levels of training that employees working with hazardous waste must receive. The requirements for hazwoper training can be found in Cal/OSHA § 5192 and Federal 49 CFR 1910.120 . In general, there are three categories of hazmat operations, and specific training requirements for each. These three categories are hazmat site cleanup, emergency response, and operations at treatment, storage, and disposal facilities. Site Cleanup Cleanup and removal work at sites that have been identified by a government agency (state, federal, or local) as having an accumulation of hazardous substances that creates a threat to the health and safety of individuals or the environment or both. General site workers removing hazmat with potential exposure to hazardous substances and health hazards shall have 40 Hours of Training + 3 Days Supervised Field Experience. General site workers in areas where hazard levels have been fully identified, exposures are below published safety limits, there are no health hazards, no possibility of an emergency release, and respirators are not required shall have 24 hours of training + 1 day supervised field experience. Occasional/limited site workers (such as those doing monitoring or surveying) and are unlikely to be exposed to dangerous levels of hazmat shall have 24 hours of training + 1 day supervised field experience. Supervisors of general site workers shall meet the same training requirements as that category of general site worker, plus have an additional eight additional hours of specialized hazardous waste operations management training. All categories of site cleanup workers shall have 8 hours of annual refresher training. Emergency Response Emergency response to releases of, or substantial threats of releases of, hazardous substances, regardless of location. Awareness Level (FRA): Basic awareness, recognize hazmat threat, call for help. Competence based, no hourly requirement. Operations Level (FRO): Defensive response, contain and limit the release. Competence based, or 8 hours of training required. Hazmat Technicians and Hazmat Specialists: Direct response to stop a release of hazardous substances. Training scope and duties varies depending on position/role. 24 hours of training required. Incident Commander/Manager: Control and manage scene, implement response plans. 24 hours of training required. All emergency response workers shall receive annual refresher training or evaluation to demonstrate competency in their required areas. TSDF Operations Operations at Hazardous Waste Treatment, Storage, and Disposal Facilities (TSDFs) Workers are required to have 24 hours of initial training, and 8 hours annual refresher training.