OSHA’s proposed revisions to substance-specific respirator requirements may provide some flexibility for your team.
On July 1, 2025, the United States Occupational Safety and Health Administration (OSHA) released proposed revisions to its substance-specific respirator requirements (29 CFR Parts 1910, 1915, 1917, 1918, 1926) for arsenic, asbestos, benzene, cadmium, coke oven emissions, cotton dust, ethylene oxide, lead, and methylenedianiline.[1] OSHA is proposing to revise respirator-related provisions for these chemicals specifically that it deems unnecessarily prescriptive. This result would allow employers to have greater flexibility in selecting respirators for exposed workers, while providing equivalent worker protection.
This flexibility is driven by advances in respiratory technologies, which have made some provisions of these standards outdated. The proposed standard will be better aligned with OSHA’s Respiratory Protection standard.
Originally, the comment period, including requests for a hearing, was set to end on September 2, 2025. On August 20, 2025, OSHA announced that the period for submitting comments was extended by 60 days to allow stakeholders interested in the Notice of Proposed Rulemaking (NPRM) additional time to review the NPRM and collect information and data necessary for comment. The new deadline for submission is November 1, 2025.
Key Highlights of the Proposed Revisions
This proposed standard is intended to account for modern knowledge and technology and to streamline the selection of respirators. This proposed rule would neither substantially modify existing requirements for respiratory protection in workplaces, nor would it create new requirements. OSHA has made a preliminary determination that the proposed rule would be technologically feasible. Also, OSHA has made a preliminary finding that this proposal is economically feasible and expected to reduce costs for employers.
The proposed updates will also improve the standard because advances in technology have made that standard outdated in some areas. For example, the requirement for HEPA filters is no longer part of the revised 42 CFR part 84. This is due to additional types of filters being certified to provide protection from particulates, including particulates containing inorganic arsenic. The proposal will allow employers to provide N95 particulate filters rather than limiting employers to respirators equipped with HEPA filters.
What are the next steps?
OSHA requests comment regarding considerations that are unique to using respirators for protection against chemical-specific hazards in shipyards, marine terminals, longshoring, or construction that OSHA should consider when finalizing this proposal.
Also, OSHA is seeking comments and data on this preliminary analysis, including on the following questions:
- How much do employers expect to save based on the increased flexibility in respirator selection?
- Are there any other savings for employers that would result from the proposed change (i.e., moving from HEPA to N95 filters)?
- Are there any benefits for worker protection that can be anticipated from this proposed change?
- Are there any costs for employers that would result from this change that OSHA has not considered?
- Are there savings to employers outside of general industry related to this proposal? If so, would they be similar to what OSHA has estimated for general industry employers?
How Can EHS Support Help?
Our team of experts is focused on delivering practical environmental, health, and safety solutions to address the evolving changes faced by the wood preservation industry. Whether it’s safety, worker exposure, toxicology, environmental compliance, site decommissioning, and/or remediation, our experts have the skills and knowledge to provide you with the crucial advice and practical solutions you need to succeed. Reach out to Monica Meyer to discuss how this update may impact your organization and how we can assist you in assessing and implementing appropriate worker protection requirements.
