Respiratory Protection (29 CFR 1910.134)
The Respiratory Protection standard requires employers to establish a written respiratory protection program when respirators are necessary to protect worker health. It is one of the most documentation-intensive OSHA standards.
What 29 CFR 1910.134 Requires
Respiratory protection is one of the most documentation-heavy OSHA standards. Unlike fall protection or ladder safety, where physical conditions drive most citations, respiratory protection violations are almost entirely paperwork-based. The standard requires a layered system of medical evaluations, fit testing, training, and an overarching written program:
- Written respiratory protection program required when respirators are used
- Medical evaluations before initial respirator use
- Fit testing annually and before initial use for tight-fitting respirators
- Training on respirator use, limitations, maintenance, and emergency procedures
- Proper respirator selection based on workplace hazards
- Regular inspection, cleaning, maintenance, and storage procedures
Most Common Violations
Respiratory protection citations are overwhelmingly documentation failures. An inspector who sees workers wearing respirators will immediately request the written program, fit test records, and medical clearance letters. If any of these are missing, the citation is issued on the spot — there is no physical condition to dispute:
- No written respiratory protection program
- Missing or expired fit test records
- No medical evaluation documentation prior to respirator use
- Inadequate training on respirator use and limitations
- Voluntary use without proper appendix D information
- Using respirators not appropriate for the identified hazard
Penalty Exposure
Penalty range: $1,190–$16,550 per serious violation; up to $165,514 per willful violation
Respiratory protection violations are particularly costly because each element of the standard is cited separately. A single inspection can produce citations for a missing written program, expired fit tests, absent medical evaluations, and inadequate training — each carrying a penalty up to $16,550 in 2026. Four separate citations from one inspection can easily total $50,000 or more.
The willful classification risk is especially high with respiratory protection. If workers are wearing respirators and you have no written program, OSHA may argue you knew respiratory hazards existed (you provided respirators) but failed to implement the required protections — the textbook definition of a willful violation at $165,514 per citation.
Documentation You Need
Respiratory protection requires more documentation than almost any other OSHA standard. Each worker who wears a respirator must have individual records on file. Refer to the complete documentation requirements for contractors for the broader picture. Here is what you need specifically for respiratory protection:
- Written respiratory protection program with program administrator named
- Medical evaluation records (confidential physician clearance letters)
- Fit test records with date, employee name, respirator make/model/size, and pass/fail
- Training records covering use, limitations, maintenance, and emergency procedures
- Respirator inspection and maintenance logs
- Exposure assessment records justifying respirator selection
What Inspectors Look For
Respiratory protection triggers one of the most document-intensive inspector reviews. During an OSHA inspection, if the compliance officer sees a single worker wearing a respirator, they will request the entire respiratory protection program file. There is no partial compliance — you either have the documentation or you do not:
- Written program — this is the first document requested if respirators are observed
- Fit test records for every worker wearing a tight-fitting respirator
- Medical clearance documentation (does not need to include medical details)
- Training records with specific content covered, not just attendance
- Respirator condition — are they being maintained and stored properly?
- Correct respirator type for the hazard — are protection factors adequate?
Respiratory Protection Is a Documentation Standard
The OSHA Defense Documentation System includes training record templates, equipment inspection logs, and respiratory protection items in the pre-inspection checklist — covering the documentation framework for respiratory protection compliance.
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