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3-Part COVID-19 Q&A Series: Part 2 N95s, Masks, and Respirator Compliance

December 16, 2020
Compliance, Healthcare Consulting By Emile LeDoux, Senior Consultant

Recently, LW Consulting, Inc. was invited to present a three-part series on the subject of infection control for the New Jersey Hospital Association (NJHA).

During the first presentation in November, our panel of experts received many excellent questions. The panelists reviewed the questions after the session and have provided their answers. We are pleased to share them for the edification of all and hope that you find the answers useful in your everyday operations.

In Part 1 of this series, we discussed cleanliness and housekeeping. In Part 2, we will discuss questions that were asked regarding N95s, masks, and respirator compliance.

Please note – Some of the information is specific to New Jersey, but many items are consistent across state lines. If you have additional questions, we urge you to reach out to us at LW Consulting, Inc., and one of our experts can provide more specific information.


3-Part COVID Series - Part 2


Question 1: “N95's are required only for those providing direct care or cleaning within six feet of a resident, correct?”

Answer 1: N95 masks are required for any employee that may come within six feet of a COVID-19 positive individual. They must also be worn when entering a resident room or apartment where a resident has been quarantined for their initial fourteen days upon arrival, where a resident is presumed to be COVID-19 positive, or when a resident has tested positive. In addition, if a facility has created an isolation unit for COVID-19 positive residents, all employees must wear their N95 masks the entire time they are in the unit. Ensure that all masks are approved by the National Institute for Occupational Safety and Health (NIOSH) for use with COVID-19, that each employee has been fit tested, and that the masks are appropriately cleaned or discarded after use.

Question 2: “We had an infection control survey and was told that New Jersey is requiring all surgical masks, no cloth. We cannot find that info anywhere. Is this true?”

Answer 2: Cloth masks are not considered Personal Protective Equipment (PPE). The cloth masks do not protect your employees from air borne pathogens. Cloth facemasks have been noted to reduce the spread of respiratory droplets from the user but have not been identified as protecting the user from droplets or splashes. Healthcare workers should be using an approved respirator or surgical mask. Be careful, there are numerous masks that look like surgical masks but are not. Certified surgical masks have a fluid protection standard that improves the protection from respiratory droplets. Any employee that is working within six feet of a COVID-19 positive resident or works in a room or secured unit for COVID-19 positive patients must use an approved respirator. PPE must be approved and supplied by the employer.

Question 3: “Is it true that some KN95's can be used as an N95? I am told there is some type of cross-referencing number to look for?”

Answer 3: The KN95 masks respirators in general have not been found to meet the United States requirements for effectiveness. The U.S Food & Drug Administration (FDA) has provided a list of “Authorized Surgical Masks” that contains respirators, including the KN95 masks that have been approved for use during the pandemic. Use the FDA chart to identify your supplier and model number. The chart includes a link with instructions on how each respirator is to be used.

Question 4: “Our community is still having difficulty obtaining sized N95 masks in order to do fit testing.”

Answer 4: Due to the lack of supplies, some facilities have needed to use respirators other than N95 masks. Refer to the FDA’s chart of “Authorized Surgical Masks” to get a full list of approved respirators. Communities should be in communication with their local department of health if they are unable to obtain the appropriate PPE to manage their facility.

Question 5: “Can you clarify if staff can wear 2 masks. For example, a surgical mask or n95 with a cloth mask under or over it?”

Answer 5: According to the Centers for Disease Control and Prevention (CDC), it is not approved by NIOSH. NIOSH tests and certifies respirators and surgical masks for use as PPE. Since the respirators are not tested using a cloth or surgical mask over top of the respirator, they cannot approve this technique for use.

Question 6: “What exactly is the process for conducting medical evaluations for fit testing? Who can do it (we don’t have medical director in AL.)?”

Answer 6: There is not a certification for the individual completing the fit test. The person selected by the facility to conduct the fit test must be able to complete the requirements for testing and ensure each employee is fitted with the appropriate size respirator. The Occupational Safety and Health Administration (OSHA) has provided requirements for “Fit Testing Procedures.” In many cases, the facility may select the Infection Preventionist to perform all fit testing. The facility may consider using a consultant or a contracted agreement with a professional.

Question 7: “I can Fit test, but when I do not have different sizes of N95 and tomorrow may have staff using a totally different manufacturer, how can we truly fit test in Long-Term Care (LTC)?”

Answer 7: Communities will have to refit each employee each time they change manufacturers or model numbers. Refer to the FDA’s “Authorized Surgical Masks” to get a full list of approved respirators.

Communities should be in communication with their local department of health if they are unable to obtain the appropriate PPE to manage their facility.


Look for Part 3 of the “3-Part COVID-19 Q&A Series” where we will discuss questions asked regarding essential workers and visitation restrictions.


Do you have more specific housekeeping or environmental services questions? Contact Emile LeDoux, Senior Consultant, at 717-313-3120 or email

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