The Occupational Safety and Health Administration (OSHA) is considering changes to respiratory protection requirements contained in 16 substance-specific standards. According to OSHA, the proposed rules that were originally published on July 1, 2025, are intended to provide greater compliance flexibility, remove certain duplicative or unnecessarily prescriptive provisions, and better align their requirements with the agency’s general Respiratory Protection Standard [29 CFR 1910.134].
OSHA held an informal public hearing on the proposed changes on August 25, 2026, and has published a meeting recording and transcript. Following the hearing, participating stakeholders had until September 24, 2026, to submit additional comments, evidence, and data and until October 9, 2026, to provide final written briefs.
The revisions under consideration are separate from OSHA’s planned amendments to the medical evaluation requirements under the general Respiratory Protection Standard. Those changes would apply only to certain filtering facepiece respirators and loose-fitting powered air-purifying respirators. We previously discussed that rulemaking in our OSHA Respiratory Protection Standard: Updates on Proposed Amendments blog.
Here, we focus on OSHA’s proposed revisions to respiratory protection requirements within 16 substance-specific standards.
What Is Being Proposed and Which Standards Would Be Affected?
Many of OSHA’s substance-specific standards contain detailed respiratory protection provisions that were adopted before, or separately, from the current general Respiratory Protection Standard. OSHA is now reassessing, standard by standard, whether certain existing requirements should be retained, revised, or removed.
The potential changes fall into three main categories, summarized below along with the affected standards.
- Revise requirements to allow the use of different types of respirators and better align with the Respiratory Protection Standard: 1,2-dibromo-3-chloropropane, 1,3-Butadiene, 13 Carcinogens (4-Nitrobiphenyl, etc.), Asbestos, Benzene, Cadmium, Coke Oven Emissions, Cotton Dust, Ethylene Oxide, Inorganic Arsenic, Lead, Methylene Chloride, and Methylenedianiline
- Remove language or requirements that are duplicative with the Respiratory Protection Standard: Vinyl Chloride and Formaldehyde
- Better align existing requirements with the Respiratory Protection Standard: Acrylonitrile
Potential Changes Affecting Life Sciences Employers
Of the substance-specific standards that could be affected by the proposed revisions, those involving methylene chloride, formaldehyde, and ethylene oxide are likely to be among the most relevant to life sciences employers. Additional details on the changes under consideration for these standards are included below.
- Methylene Chloride [29 CFR 1910.1052]: OSHA is considering, but is not currently recommending, removal of the requirement limiting employers to atmosphere-supplying respirators. OSHA has acknowledged that there are currently no other available respiratory protection options for methylene chloride and has requested information on how the standard might accommodate future technological developments. The agency, however, is recommending to eliminate the requirement to use full-facepiece atmosphere-supplying respirators, which would allow half-mask respirators to be used with adequate eye and/or skin protection.
- Formaldehyde [29 CFR 1910.1048]: OSHA’s proposed revisions to this standard primarily seek to eliminate duplicative requirements in the Respiratory Protection Standard. Notably, they are not currently looking to eliminate the substance-specific cartridge and canister changeout schedule. Although the agency considers the existing formaldehyde-specific requirement more protective than relying solely on the generic changeout provisions of 29 CFR 1910.134, they have requested input on whether it should be removed.
- Ethylene Oxide [ 29 CFR 1910.1047]: OSHA is considering allowing for greater flexibility in respirator selection under its Ethylene Oxide Standard. One revision under consideration would remove the existing prohibition against half-mask respirators. If finalized, employers could select a suitable half-mask respirator while providing separate eye and/or face protection, when necessary. OSHA is also considering removing a prescriptive requirement to provide respirators with front- or back-mounted canisters approved for protection against ethylene oxide because the requirement duplicates rules in the Respiratory Protection Standard.
Where Does the Rulemaking Stand and What Should Employers Do Now?
OSHA is currently considering the August 25, 2026 hearing record, post-hearing comments, and other stakeholder submissions. The agency will evaluate this information and determine how to proceed. OSHA may modify the proposed revisions, request additional information, or reopen the rulemaking record.
At this stage, employers do not need to update their respiratory protection programs based solely on these recommended changes, as they have not yet replaced existing regulatory requirements. Organizations should continue complying with current substance-specific requirements and applicable stipulations of the Respiratory Protection Standard. However, employers can use this rulemaking as an opportunity to review their processes and consider taking the following steps:
- Identify which, if any, of the 16 substance-specific standards apply to their operations.
- Verify that respirators are selected for the specific contaminant, exposure concentration, physical form, and anticipated conditions of use.
- Confirm that respirators are NIOSH-approved and used in accordance with their approved configurations and limitations.
- Ensure annual fit testing has been completed for all employees required to wear tight-fitting respirators and that employee training is current and complies with all applicable standards.
- Monitor the rulemaking for changes that could affect respirator selection or other respiratory protection requirements.
Safety Partners will continue to track OSHA’s rulemaking on respiratory protection provisions in substance-specific standards. For more information about the proposed changes, determining whether OSHA’s substance-specific standards apply to your organization, or maintaining a compliant respiratory protection program, contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training at Safety Partners.
