Nov. 27, 2020 —
R 181550 NOV 20
FM COMDT COGARD WASHINGTON DC//CG-11//
SUBJ: COVID-19: RESPIRATOR USE POLICY UPDATE
A. Safety and Environmental Health Manual, COMDTINST M5100.47 (series)
B. Respiratory Protection, 29 CFR § 1910.134
C. Respiratory Protection Program Tactics, Techniques and Procedures, CGTTP 4-11.4
D. Communicable Disease Force Health Protection Tactics, Techniques and
Procedures, CGTTP 4-02.2, Chap-3.C
1. Background. REF (A) establishes the United States Coast Guard respiratory
protection program policy for use of respirators, to include filtering face
piece N95 respirators. This ALCOAST provides an update to the policy
governing voluntary use of respirators by Coast Guard members and employees.
Coast Guard members and employees are encouraged to follow Occupational
Safety and Health Administration (OSHA) and Center for Disease Control and
Prevention (CDC) guidance for use of respirators and cloth face coverings
in all work environments. Currently CDC/FAA advice for commercial air travel
describes the wearing of cloth face coverings. If non-fit-tested, N95
respirators are worn, they can provide a false sense of security to the
wearer and not provide the desired respiratory protection.
2. Voluntary Respirator Use Policy Discussion. Per REFs (A) and (B), if
respiratory protection is not required by the Coast Guard, the Coast Guard
did not advise the employee to use respiratory protection, and the Coast
Guard did not issue the respirator to the employee, but the employee desires
to use his/her own personally procured respiratory protection, this situation
is considered voluntary use. This applies to workspace activities as well as
official travel on commercial air. Where the employee procures his/her own
respirator, there is no requirement for a unit to develop a written Respiratory
Protection Program (RPP), nor enter the employee into a RPP. However,
the employer would be responsible to provide the employee with a copy
of Appendix D of 29 CFR § 1910.134 as described in REF (A).
3. Issued Respirators. In situations where the Coast Guard issues a
respirator to the employee, the Coast Guard is required to establish
a written RPP and enter the employee into that RPP. Elements of the RPP
include a medical assessment to ensure employee health is compatible with
respiratory protection, and fit testing to ensure proper respirator size
and model selection, as well as to ensure a face seal can be established
to provide protection as described in REFs (A) and (C).
4. Policy Update.
a. REF (A), Chapter 9.B.3.g.(1).(b) is amended as follows: Remove,
“Personnel must not supply their own respirators.”
b. REF (A), Chapter 9.B.3.g.(1).(c) is amended as follows: Remove, “NIOSH
approved filtering face pieces can be issued without medical screening and
fit testing.” Replace with, “Personally procured NIOSH approved filtering
face pieces do not require entry into a RPP. USCG issued NIOSH approved
filtering face pieces require employee entry into a RPP.”
c. These amendments to REF (A), Chapter 9.B.3.g will be reflected in
the next revision of REF (A) scheduled for CY21.
d. As required in REFs (A) and (B); link to Appendix D of 1910.134 is
5. ROM and quarantine considerations. A personally procured respirator (N95)
that has not been fit tested does not qualify as personal protective
equipment (PPE). If an employee wearing a non-fit-tested N95 respirator comes
into close contact with a COVID-19 positive person, that employee will have
to undergo a 14-day quarantine, as described in the Risk Assessment Flowchart
(ENCL 02 of the COVID-19 PLANORD).
6. REF (C) describes local Respiratory Protection Program implementation
7. HSWL SC (se) POC: CAPT Michael Boley (757) 628-4426
8. COMDT (CG-113) POC: Mr. Glenn Gebele (202) 475-5195
9. RADM Dana L. Thomas, Director, Health, Safety, and Work-Life, sends.
10. Internet release is authorized.