What 29 CFR 1910.134 is
OSHA 29 CFR 1910.134 is the federal respiratory protection standard. It applies to any workplace where employees are exposed to airborne hazards above the OSHA permissible exposure limit — which includes Category 3 water environments (sewer backup, flood), Condition 3 mold remediation, fire-damage cleanup with soot and combustion byproducts, and lead/asbestos abatement.
The standard requires a written respiratory protection program, medical clearance for each respirator user, fit testing, training, cartridge/filter change-out schedules, and proper respirator selection based on the hazard. Compliance is OSHA-enforceable; non-compliance is OSHA-citable.
Where it shows up in claim disputes
Restoration contractors performing Category 3 or Condition 3 work in compliance with 29 CFR 1910.134 carry PPE costs the carrier estimate frequently omits — full-face respirators, P100 / N100 cartridges, change-out per use, fit-test documentation, and the time component of donning / doffing PPE for each technician.
When a carrier scopes a Cat 3 or Condition 3 job WITHOUT respiratory protection line items, the carrier is implicitly suggesting the contractor violate OSHA. That’s a meaningful argument: "the scope your estimate produces, performed as scoped, would expose my technicians to a regulated hazard without required PPE."
How to cite it in a supplement
Reference the specific subpart — 29 CFR 1910.134(c) for the written program requirement, (d) for respirator selection, (e) for medical evaluation, (f) for fit testing. The supplement should list each PPE line item with the corresponding subpart citation in the basis column.
For Condition 3 mold work specifically, 29 CFR 1910.134 + IICRC S520 §12.1.1 (containment) + EPA "Mold Remediation in Schools and Commercial Buildings" together form the regulatory + consensus-standard stack. Citing all three makes the PPE scope defensible.
Where to apply in a VVON audit
Upload the carrier estimate plus the loss documentation (Category / Condition determination, scope of work). VVON cross-references the scope against OSHA + IICRC PPE requirements and surfaces missing line items with the specific subpart citation.