Nov 18, 2025· Comment from Sloan, Lawrence; American Industrial Hygiene Association (APHA)· OSHA-2025-0016-0013
OSHA should issue an appendix or guidance that maps current prescriptive respirator selections to their equivalents under 1910.134, including APFs, fit testing modalities, cartridge/canister types, change out schedules (with example calculations), IDLH protocols, and agent specific limitations. The guidance should state that employers in compliance with the mapped equivalents are deemed compliant - thereby minimizing retraining burdens and reducing the potential for misinterpretation or enforcement disputes.