This analysis examines OSHA enforcement of respiratory protection citations across various industries, indicating systemic noncompliance issues.
Respiratory protection is a critical exposure control strategy in workplaces where airborne hazards are present. The U.S. Occupational Safety and Health Administration (OSHA) respiratory protection standard (29 CFR 1910.134) specifies requirements for respirator selection, medical evaluation, fit testing, training, maintenance, and program administration. During the COVID-19 pandemic, respiratory protection programs and fit testing in particular were widely discussed in the context of healthcare. National enforcement patterns across industries and over extended timeframes, however, have not been comprehensively characterized. This study analyzed U.S. OSHA enforcement records to examine the industry distribution, geographic pattern, and temporal trend of citations issued under the respiratory protection standard. Across complete reporting years 2008–2024 (with partial 2007 and 2025 data shown but excluded from analysis), 109,689 citations referencing 29 CFR 1910.134 were identified across 50,388 inspections (2.18 citations per inspection). Citations were most frequent in automotive body and paint repair (5,224), fire protection and emergency response (3,965), cut stone and abrasive product manufacturing (3,080), masonry contractors (3,021), and painting and wall covering contractors (2,208). When healthcare codes were aggregated (NAICS 621–623: ambulatory care, hospitals, and nursing and residential care), the sector accounted for 4,493 citations—about 4.1% of the national total—still a minority relative to the leading industrial sectors. Fit-testing citations [1910.134(f)] represented a persistent component of enforcement in every year (12–20% of annual respiratory protection citations); their share held near 14% before the pandemic and rose during 2020–2022, largely because a temporary, healthcare-concentrated surge of COVID-19–related fit-testing citations (23–27% of national fit-testing citations in 2020–2021) offset the pandemic decline in routine inspections. This surge had effectively ended by 2023 and represented only about 4% of respiratory protection citations even at its peak. Citations were geographically concentrated in populous states and in OSHA State Plan jurisdictions with independent enforcement programs. These findings indicate that respiratory protection program noncompliance is multi-sector and systemic, rather than concentrated primarily in healthcare.
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Joshua Pilgreen (2026) studied this question.
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