Back to Federal guidance

P100, N100 and R100 filters in place of HEPA filters

Summary A respirator maker asked how newer NIOSH filter ratings related to OSHA standards requiring HEPA filters. OSHA said an employer could use a P100, N100 or R100 filter certified under 42 CFR Part 84, choosing among them for the environment where the respirator would be worn. The page carries a later correction note.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1996-03-18
Date issued
March 18, 1996
Status
Active
Status last verified October 9, 2026

Apply this to your situation

This page explains the general guidance. Ask about your specific situation and see what current federal labor law says, with citations.

About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

March 18, 1996
Kenneth V. Vaughan, President
Neoterik Health Technologies, Inc.
[Recipient address omitted]
Dear Mr. Vaughan:
This is in reply to your letter, dated March 7, 1996, concerning the relationship between OSHA standards and the usage of particulate respirators certified under 42 CFR 84. Specifically, you requested clarification concerning the requirement in the OSHA asbestos standards to use a HEPA filter respirator if concentrations do not exceed 1 fiber/cc.
It is OSHA policy that when any OSHA standard requires the use of HEPA filters then the employer may satisfy the requirement by choosing to use a P100, N100, or R100 filter certified under 42 CFR Part 84, since such filters would exhibit minimum leakage. The employer would be expected to choose either the P-, N-, or R-filter based on the environmental conditions under which the respirator would be worn.
Please contact this office if we can be of further assistance.
Sincerely,
Kenneth W. Gerecke
Assistant Regional Administrator
[Corrected 10/22/2004]

[Requester letter reproduced on OSHA page; omitted here.]

What does federal law require in your situation?

Ezel checks current federal labor law against your facts and answers with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace