OSHA 1910.134 — Respiratory Protection, Documented

1910.134 requires a written respiratory protection program, medical evaluation, fit testing, and training before a worker can wear a tight-fitting respirator. It's a Top 5 OSHA citation. ARKVOS documents every part of the program.

The rule, in plain English

Before issuing a tight-fitting respirator (N95, half-face, full-face, SCBA), employers must (1) have a written program with a designated administrator, (2) medically evaluate the worker, (3) fit-test annually, and (4) train at hire and annually.

Most-cited violation patterns

Missing written program, no medical evaluation on file, expired fit tests, no annual training refresh, voluntary-use respirators without Appendix D notification.

How ARKVOS documents compliance

ARKVOS stores per-worker medical clearance dates, fit-test results, and training acknowledgements. Each event is a selfie + GPS + SHA-256 record. Annual reminders fire 30 days before expiry.

Penalty math

$16,550 per serious citation. Respiratory citations are often issued per-worker (each worker without a current fit test) — a 50-worker production line can face $800,000+ in a single visit.

Voluntary-use tracking

ARKVOS-1 generates Appendix D notifications for voluntary N95 use and tracks worker acknowledgement.

Frequently asked questions

Is medical evaluation always required?

For any tight-fitting respirator (N95, half-face, full-face, SCBA), yes — before fit testing. For voluntary-use filtering facepieces only, medical evaluation is recommended but Appendix D notification is required.

How often must fit testing happen?

Annually, plus whenever the worker's facial structure changes (significant weight change, dental work, scarring) or whenever a different respirator make/model is issued.

Can ARKVOS replace our fit-test machine?

No — fit testing uses dedicated equipment (Portacount, Bitrex, saccharin). ARKVOS records the fit-test event, results, and expiry date, and alerts when re-testing is due.

What records must I keep?

1910.134(m): medical evaluations, fit-test records (including protocol, model, test result), and the written program. ARKVOS stores all three with cryptographic audit hashes.

Already holding an OSHA citation?

Arkvos offers a free OSHA citation response generator. Upload the citation and get a formal response letter, a corrective action plan with dates, and a checklist of evidence to attach. Employers have 15 working days from receipt of a citation to contest it. Open the free citation responder.