Voluntary Use of Respirators

You must give every worker who opts to wear a respirator a copy of Appendix D.

• By Lynn Feiner
• Nov 03, 2009

If there are no contaminants at your worksite or the concentration levels are below the Permissible Exposure Limit (PEL), you, as the employer or Respiratory Protection Program Administrator, may allow your employees to wear respirators for relief from nuisance dusts or other contaminants, including relief from nuisance odors. But before you give the go-ahead, you need to know what your responsibilities are and the options you have as the Employer/Program Administrator.

Establish that respirators are not required.
Do a complete site assessment to determine what, if any, contaminants are at your site and that contaminants that may be present are below the PEL. Take into account variations, such as the start of a shift versus the end, and seasonal differences, such as improved ventilation in summer, etc. If it is not practical to factor in all variations, use the worst case.

Even if contaminant concentrations at a specific worksite are under the PEL, it is still possible that respirators will be required. Perhaps workers' blood tests indicate they have elevated levels of lead or mercury, and respiratory protection will be one of the measures used to protect these workers. If respirators are required for any reason, whether by you as the Program Administrator or by a contaminantspecifi c standard, it is not voluntary. Voluntary use does not apply in these instances -- no exceptions. A complete, written Respiratory Protection Program must be established.

Determine whether you want to allow the voluntary use of respirators and, if so, what type of respirators.
Allowing voluntary use is your choice; it is not a requirement. There may be many reasons why you, as Program Administrator, may prohibit the use of respirators where they are not required. You should not allow voluntary use if it creates a hazard at your work site. Some examples might include a factory where respirators are required in some areas, and there is no way for you to monitor workers who are not part of your written Respiratory Program, or perhaps there is no way to ensure voluntarily used respirators are maintained and cleaned.

If you do decide to allow voluntary respiratory use, you have the option to only allow filtering facepieces (disposable dust masks) or to allow elastomeric facepieces. It's your option, but you must establish a written Respiratory Protection Program that includes procedures for training workers and, if elastomeric facepieces are allowed, procedures for cleaning, maintaining, and storing the respirators. You may choose to prohibit the voluntary use of respirators because it would be a financial burden to your company, or to limit voluntary use to disposables.

Have workers medically evaluated.
Before you can allow workers to wear a respirator, even voluntarily, they must be medically evaluated to determine that each worker is physically able to wear that respirator and that it will not jeopardize his health. Respirators restrict breathing and can aggravate conditions such as asthma. Use of filtering facepieces (disposable dust masks) is the one exception to this requirement. Refer to the section below on Disposables for more information.

Provide a copy of Appendix D from OSHA's Respiratory Standard, 29 CFR 1910.
You are required to give every worker who opts to wear a respirator a copy of Appendix D. Best practices include reviewing these instructions with your employees and answering any question they may have. Copies of Appendix D in English and Spanish are available on OSHA's Web site.

Make sure workers use a NIOSH-certified respirator, and that it is the right respirator.
These two items are reviewed in Appendix D but are important enough to stress again. This is also where there are a lot misconceptions.

Some people might want to use "comfort masks," one- or two-strap masks that are not certified by the National Institute for Occupational Safety and Health (NIOSH). One of the biggest misconceptions is that using a non-NIOSH-approved product automatically exempts that company from OSHA requirements, or because a comfort mask is not a respirator, it is not considered voluntary use of respirators. One hopes you will never have an OSHA inspector knock on your door, but if that ever happens, do you want to run the risk of an OSHA fine? If your answer is no, reread #2 of Appendix D.

Another common misuse is allowing a dust mask designed for protection from particulates for nuisance levels of a gas or vapor. The wearer has all of the downside of increased breathing resistance and none of the benefits from wearing the right mask. Even though contaminant concentrations at your site are below the PEL, the respirators workers use should be appropriate for those contaminants. Again, you may never receive a citation, but do you want to take the chance? Reread #3 of Appendix D.

Because these respirators are not required, they are not part of OSHA's requirement that employers provide personal protective equipment at no cost to employees. You, therefore, are not required to purchase any respirator that is used voluntarily or even pay for respirators that workers have purchased on their own. However, to ensure workers are using the right, NIOSH-approved respiratory protection, you might want to become involved, at least in which respirators are purchased.

Train workers and ensure respirators are maintained. You must implement all parts of a Respiratory Protection Program that ensure workers are trained in the use and limitations of respirators and that the respirators are properly cleaned, maintained, and stored. Like Medical Evaluations, the cleaning, storing, and maintenance of disposables used voluntarily is exempted from this requirement.

Disposables & Voluntary Use

OSHA has exempted disposable respirators from some of the Voluntary Use requirements.

You do not need to:

• Have workers medically evaluated; or
• Have procedures to clean, store, and maintain respirators You do need to
• Perform a site assessment and determine that respiratory protection is not required;
• Train workers on use and limitations; and
• Provide a copy of Appendix D

Fit testing, Facial Hair & Voluntary Use

Good news: You do not need to fit test or be concerned about facial hair. Why? Remember, this is voluntary use below the PEL. A respirator is not required, so even if a mask leaks like a sieve, the worker is not exposed to dangerous levels of a contaminant.

Summary

Allowing voluntary use of respirators can provide workers with an added level of comfort and relief from nuisance levels of particulates, gases, or vapors. But misuse can result in illness or injury to the worker. Understanding and following OSHA's guidelines on voluntary use of respirators is one of the many ways you help provide a safe workplace and ensure your employees stay healthy.

This article originally appeared in the November 2009 issue of Occupational Health & Safety.