Clean-shaven worker wearing safety glasses and a reusable half-face respirator, cupping both hands over the filter cartridges to do a user seal check.
Respiratory Safety

B.C.'s Respirator Face Seal Amendments: What Sections 8.39 to 8.41 Now Say

6 min read

Short answer: B.C. Reg. 135/2026, in effect November 6, 2026, amended sections 8.39 to 8.41 of B.C.'s OHS Regulation. It defines a tight-fitting respirator as one that needs an effective face seal, says employers must not permit anything to interfere with that seal, and updates the fit test and user seal check sections to use the new term.

A tight-fitting respirator only protects the worker if it seals to the face. When anything breaks that seal, contaminated air takes the easy path around the filter instead of through it, and the worker breathes it in without knowing. That's why British Columbia's rules on face seal, fit testing and seal checks matter, and why three of them were amended on November 6, 2026.

What happened

WorkSafeBC's Board of Directors amended the Occupational Health and Safety Regulation with B.C. Reg. 135/2026. The amendment was deposited July 20, 2026, published in the B.C. Gazette, Part II on July 28, 2026, and is in effect November 6, 2026. WorkSafeBC lists three amended sections in Part 8:

  • 8.39 Face seal
  • 8.40 Fit tests
  • 8.41 User seal check

What the amended wording says

Here is what the official amending text changes, in plain terms:

Section 8.39 (Face seal) was repealed and replaced. The new section does two things:

  1. It defines a "tight-fitting respirator" as "a respirator that requires an effective seal with the face for proper functioning." The definition applies in sections 8.39, 8.40 and 8.41.
  2. It states the employer's duty: if a worker is required to wear a tight-fitting respirator, "the employer must not permit anything to interfere with the seal or the proper functioning of the respirator."

Sections 8.40 (Fit tests) and 8.41 (User seal check) now use the new term. Where they used to describe a "respirator which requires an effective seal with the face for proper functioning," they now say "tight-fitting respirator." In section 8.40(2.1)(a) and (3), "a respirator" became "a tight-fitting respirator."

The amendment is about wording and definitions. It doesn't publish a list of new tasks. The requirements in the current sections are worth re-reading anyway, because they're the ones an inspector will check.

What the current sections require

As consolidated on WorkSafeBC's site after the amendment:

  • Fit test before issue (8.40(1)): a tight-fitting respirator must not be issued to a worker unless a fit test shows the facepiece forms an effective seal with that worker's face.
  • When to fit test (8.40(2.1)): before first use, at least once a year, whenever the facepiece changes (including brand, model and size), and whenever a change in the worker's physical condition could affect the fit.
  • Test with the other PPE (8.40(3)): other PPE worn at the same time that could interfere with the fit, such as safety glasses or goggles, must be worn during the fit test.
3M 7502 medium silicone reusable half facepiece respirator in its sealed 3M retail bag
  • Seal check every time (8.41): before each use, the worker must do a positive or negative pressure user seal check in line with CSA Z94.4-18. This doesn't apply to emergency use of an escape respirator.
  • Records (8.44): the employer must keep a record of fit test results and worker instruction.

The Canadian Centre for Occupational Health and Safety (CCOHS) adds useful context: fit testing verifies that a respirator's make, model and size give the user appropriate protection, and the respirators that need it include disposable respirators such as N95s, half-face and full-face respirators, and SCBA.

What employers should review now

  • Your list of tight-fitting respirators. Use the new definition to confirm which respirators in your program it covers, including disposables.
  • Anything that could break the seal. Facial hair along the seal line, eyewear arms, hoods and other PPE straps can all get in the way. Section 8.39(2) puts the duty not to permit that on the employer. Where a worker can't keep a clean seal line, some powered air purifying respirators are available with loose-fitting hoods or helmets that don't rely on a face seal.
  • Fit test records against what's in use. Check that each worker's record matches the exact brand, model and size they were issued, and that it's less than a year old.
  • Seal check training. Make sure workers know how to do a positive or negative pressure check and that supervisors see it done.
  • Your written program wording. If your procedures copy the regulation, update them to use "tight-fitting respirator" so they match.

Keyline Safety's stand

The seal is the protection. A high-rated filter on a facepiece that leaks is close to no protection at all, so we treat anything that sits between the seal and the skin as a hazard in its own right, not a comfort issue.

We also think fit testing only works when the respirator on the worker's face is the one they were tested in. Stocking the same brand, model and size as your fit test records, and having more than one size on hand, does more for real-world protection than any single feature on a spec sheet.

What Keyline Safety does

Keyline Safety supplies reusable respiratory protection for crews in B.C. and across Canada:

Side view of a 3M Rugged Comfort 6502 medium reusable half facepiece respirator with its head harness and neck straps

Choose filters and cartridges, such as the 3M 60926 multi-gas/vapour cartridge/filter (P100), for the specific contaminant and follow the manufacturer's instructions and your respiratory protection program.

3M 60926 multi-gas/vapour cartridge with magenta P100 filter beside its grey filter retainer

Want help matching respirators to your fit test records, or comparing tight-fitting and loose-fitting options? Contact Keyline Safety.

Frequently asked questions

What changed in B.C.'s respirator rules on November 6, 2026?

Section 8.39 was replaced with a definition of tight-fitting respirator and an employer duty not to permit anything to interfere with the seal. Sections 8.40 and 8.41 now use the term tight-fitting respirator.

How often is respirator fit testing required in B.C.?

Before first use, at least once a year, whenever the facepiece changes, and whenever a change in the worker's physical condition could affect the fit (s. 8.40).

Do disposable N95 respirators need a fit test?

Yes. CCOHS lists disposable respirators such as N95s among the tight-fitting respirators that need fit testing.

What is a user seal check?

A positive or negative pressure check the worker does before each use, in line with CSA Z94.4-18, to confirm the respirator is sealing (s. 8.41).

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