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.
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.
Missing written program, no medical evaluation on file, expired fit tests, no annual training refresh, voluntary-use respirators without Appendix D notification.
ARKVOS stores per-worker medical clearance dates, fit-test results, and training acknowledgements. Each event is a selfie + GPS + record-integrity record. Annual reminders fire 30 days before expiry.
$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.
Arkvos generates Appendix D notifications for voluntary N95 use and tracks worker acknowledgement.
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.
Annually, plus whenever the worker's facial structure changes (significant weight change, dental work, scarring) or whenever a different respirator make/model is issued.
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.
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.
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.
Arkvos separates product capabilities from regulatory requirements. For federal OSHA requirements, the primary authority is OSHA's current regulations and guidance. California construction employers should also review the applicable Cal/OSHA Title 8 requirements.
OSHA 29 CFR 1904.33 requires the OSHA 300 Log, annual summary, OSHA 301 Incident Report forms, and privacy case list if one exists to be retained for five years after the end of the calendar year they cover. Cal/OSHA Title 8 §1509(e) requires construction supervisors to conduct toolbox or tailgate safety meetings, or equivalent, with crews at least every 10 working days. Requirements vary by jurisdiction and work activity, so employers should verify the rule that applies to their facts.
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