SCBA Fit-testing for hose teams

I have an Industrial Hygienist telling me that to meet OSHA standards the crew needs annual quantitative fit testing to wear the SCBA on a hose team. Just to be clear, a quantitative fit test is where you are hooked up to a breathing machine attached to the mask and they measure how well it fits. Its usually done at a shore based facility. This is a step beyond the qualitative (sniff) testing most us are familiar with.

Has anyone else been told they have to comply with this? I have never heard of this being a requirement of the hose team before. Does anyone know the exception to the rule on this?

I’m pretty sure nobody at sea has to do anything OSHA says.

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Short form:

OSHA does not mandate SCBA operation rules for a vessel. As long as your type of vessel has CFRS mandating SCBAs, then OSHA does not have authority over how SCBAs are used/tested by your mariners.

An industrial hygienist would have no idea of the complexity of the regulatory authority re: USCG versus OSHA, so it is not surprising they are incorrect.

By the way, I have experience with attempting a quantitative fit testing program for SCBAs for mariners. You don’t want any part of it. Physicians get involved quick, and things spiral out of control.


I am of the exact same opinion

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Some of the companies transporting oil require everyone in the crew to do annual fit tests. This might be an AWO Responsible Carrier Program recommendation, or an oil major (cargo owner or refinery) requirement.

I recall that certain refineries would not let guys with beards across the dock for crew change. I recall seeing fit tests in a certain company’s SMS.

Usually they want guys to shave before the test. There are many guys who will not shave. Most guys that do shave promptly regrow beards. There are some guys that simple cannot pass a fit test, or that can only pass with a particular type of mask.

If you have trouble getting a seal with a beard, apply KY jelly or vasoline to your face, you will then most likely get a seal and pass.

Like many things, the concept of fit testing is good in theory, but it’s rarely necessary or desirable in practice.

The USCG and OSHA have a Memorandum of Understanding that OSHA will not meddle in anything that the USCG regulates, but if the USCG elects not to regulate something, that OSHA can step in and regulate it.

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Washington State Ferries fit test every year. They have an in house tester with an outfitted van that travels to all the docks and boats to test engine and deck crew. They have be clean shaven. Mustaches and chin straps allowed. Essentially have to be able to make the seal for SCBA. The health form and check is outsourced.
Captains can have beards if they chose not to work CM. Some deckhands can have beards if for health reasons they “can’t” shave. They’re not allowed to work AB or be on the hose team for the station billet.


The issue I had with a quantitative fit testing program (not legally necessary on our fleet, as I stated above) was the OSHA-compliant medical questionnaire. A mariner who had passed a USCG medical exam could later be flagged for further checks by a physician based on what they answered on the questionnaire, even though the OSHA quantitative test is not required by the USCG.

Which caused all kinds of problems when we tried it. AB has the USCG med cert to sail, but another doctor, based on the OSHA- questionnaire, suddenly says the AB can’t use an SCBA until further testing. Now the AB fears their employment is in jeopardy…

After dealing with those quasi-legal conundrums we simply went back to solely qualitative testing.


Thank you all. This has been extremely helpful.

OSHA only applies when a Vessel is in a US Shipyard.

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Or when the USCG “incorporates by reference” OSHA rules.

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