Comment on OSHA’s Proposed Changes to Respirator Requirements

OSHA is making moves to update several respirator-related standards, and now is the time to speak up. Public comments are being accepted until November 1, 2025 on a series of proposed changes that primarily affect filtering facepiece respirators (i.e., N95s) and powered air-purifying respirators (PAPRs), two types of respiratory protection widely used across healthcare, construction, manufacturing, and other high-risk industries.

**Note: The public comment deadline was initially September 2, but in late August, this date was pushed back to November 1.

What’s changing?

There are two main areas of focus:

1. Medical Evaluation Requirements:

OSHA is proposing to remove certain medical evaluation requirements for workers using filtering facepiece respirators (FFRs) and loose-fitting PAPRs. These respirators are typically used in lower-risk environments compared to tight-fitting respirators, and OSHA believes the medical evaluation step may be unnecessary in many cases. This change could simplify compliance for employers and reduce delays in employee fit testing.

2. Substance-Specific Standards Update:

OSHA is also revising substance-specific respirator rules for 16 chemicals, including formaldehyde, lead, methylene chloride, and more. The goal is to bring these older rules in line with the more modern Respiratory Protection Standard (29 CFR 1910.134). This would allow a wider range of approved respirators to be used for specific chemical exposures, giving employers and workers more flexibility while still protecting health.

The 16 chemicals and their applicable regulations that would be affected by this change are listed below:

• 1,2-Dibromo-3-chloropropane (DBCP) – 1910.1044
• Acrylonitrile – 1910.1045
• Arsenic (inorganic) – 1910.1018
• Asbestos – 1910.1001
• Benzene – 1910.1028
• Cadmium – 1910.1027
• Coke Oven Emissions – 1910.1029
• Cotton Dust – 1910.1043
• Ethylene Dibromide (EDB) – 1910.1049
• Ethylene Oxide – 1910.1047
• Formaldehyde – 1910.1048
• Lead – 1910.1025
• Methylene Chloride – 1910.1052
• Vinyl Chloride – 1910.1017
• 4,4’-Methylenedianiline (MDA) – 1910.1050
• 13 Carcinogens (a group regulated together) – 1910.1003

Why does this matter?

If your workplace uses FFRs or PAPRs, or you handle chemicals regulated under substance-specific standards, these updates could affect your training, compliance processes, and PPE program.

This is your chance to weigh in. OSHA wants to hear from stakeholders like you before finalizing the rule. Visit the Federal Register Notice to review the proposed rule in detail and submit your comments under Docket No. OSHA‑2025‑0006.

Need help understanding how these changes could impact your facility?

Walden can assist with:

• Evaluating your current respiratory protection program
• Coordinating medical evaluations and conducting fit testing
• Updating written safety plans
• Training employees

Contact our EHS team at 860-846-4069 to discuss your needs with an experienced safety specialist.