All of the applicable Respiratory Protection Standard requirements e. There are many reasons workers might want to wear a respirator, even though it may not be required. But, there are other reasons.
For example, an employee who works with a smelly solvent to clean parts may find comfort in a respirator, even though the employer has evaluated the exposure and determined it is within acceptable limits. Note: The employer would still want to keep track of the hazards, especially if any changes in the process would increase exposure. When deciding whether or not to allow the voluntary use of a respirator, there are two sets of OSHA requirements with which employers must be familiar.
One set is for dust masks. The other set is for all other types of respirators. If an employee wants to use a dust mask on a voluntary basis, then the employer has minimal responsibility. OSHA places two requirements on employers when it comes to allowing employees to wear dust masks voluntarily:.
Employers are not required to provide any medical evaluation or fit test for voluntary use of a dust mask. Additionally, you asked OSHA to clarify the interplay between the Respiratory Protection Standard and other laws that may require an employer to provide an alternative to the N95 respirator as a reasonable accommodation to employees who maintain facial hair for religious reasons.
In an August 5, letter of interpretation, OSHA explained that the Respiratory Protection Standard permits the use of loose-fitting PAPRs by workers with facial hair in the majority of situations where respirators are required. In the context of exposure to people with suspected or confirmed COVID, the Respiratory Protection Standard permits employers to provide employees with various types of NIOSH-certified respirators, including filtering facepiece respirators e.
Therefore, an employer may provide a loose-fitting PAPR as a reasonable accommodation and comply with the Respiratory Protection Standard. Initially, OSHA notes that its letters of interpretation are in response to fact-specific circumstances and therefore OSHA is unable to respond to broad general requests to clarify the requirements of an OSHA standard.
February 6, Mr. Gordon C. Miller Lawrence Livermore Laboratory P. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions or situations not delineated within your original correspondence. Your questions are repeated below along with our response. Question 1: Does a principal employer have an obligation to prohibit the voluntary use of filtering facepieces by workers who have beards or other facial hair that interfere with the functioning of the filtering facepieces?
Does an employer have an obligation to prohibit the voluntary use of filtering facepieces by contractor employees working on the principal employer's premises who have beards or other facial hair that interfere with the functioning of the filtering facepieces? Response: No, the voluntary use of respirators in atmospheres which are not hazardous does not require the mask to be fit tested or the wearer to a maintain a tight fit, so beards that could interfere with the faceseal or functioning of filtering facepieces would be not be prohibited by the standard.
Miller, February 6, attached. If employers allow the voluntary use of elastomeric facepiece and powered air-purifying respirators after determining that such use will not itself create a hazard , the employer must implement the elements of a written respiratory protection program necessary to ensure that employees voluntarily using such respirators are medically fit to do so, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.
See 29 CFR Response 3: Facial hair is not prohibited when voluntarily using respirators, but it is discouraged. As mentioned above, please see the letter of interpretation from Mr. Miller for more information. Thank you for your interest in occupational safety and health.
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