Voluntary Use of Respirators: A Plain-Language Look at OSHA Requirements

OSHA encourages employees to use NIOSH-approved respirators for voluntary use, but this is not specifically required.

• By Travis Rhoden
• May 01, 2011

It is not uncommon for employees to approach their supervisor or safety manager and ask about wearing a respirator just because they will "feel more comfortable" doing the work. It is also not uncommon for the supervisor or safety manager to be unclear on whether to allow this type of voluntary use and, if so, what OSHA requires of the employer:

• "Is a fit test required?"
• "Do we have to train them?"
• "What about medical evaluations?"

All of these are questions that employers have from time to time when it comes to voluntary use.

Voluntary Use Defined
The first thing the employer must do is make sure that the respirator use is actually "voluntary" as defined in the OSHA Respiratory Protection Standard, 29 CFR 1910.134. In order for the use to be voluntary (and, thus exempt from many of OSHA's respiratory protection requirements), two factors have to be considered:

• Is there an atmospheric hazard that necessitates the use of respiratory protection?
• Does the employer require the respirator use?

If either of the above questions can be answered "yes," then the usage is not considered voluntary. In other words, if the employer requires employees to wear respirators, even if there is no hazardous atmosphere, then all of the applicable Respiratory Protection Standard requirements (e.g., fit test, medical evaluation, and cleaning) apply -- even for a dust mask respirator.

Why Would an Employee Want to Voluntarily Wear a Respirator?
In order to become more comfortable with voluntary respirator use, it helps to understand why employees may want to wear a respirator, even though the employer has proven there's no hazard.

One example, perhaps the most common, is illustrated in OSHA's Preamble to the Respiratory Protection Final Rule:

". . . some employees who have seasonal allergies may request a mask for comfort when working outdoors, or an employee may request a dust mask for use while sweeping a dusty floor. . . "

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. In these situations, the employer may know there isn't a health risk but still wants employees to be comfortable when doing the job; this might be a case where voluntary respirator use is appropriate. Note: The employer still would want to keep track of the hazards, especially if any change in the process would increase the exposure.

Two Sets of Voluntary Use Requirements
When deciding whether or not to allow voluntary use of a respirator, there are two sets of OSHA requirements with which employers must be familiar. One set is for dust masks (known as filtering facepiece respirators). The other set is for all other types of respirators.

Voluntary use of a dust mask
If an employee wants to use a dust mask on a voluntary basis, then there are very limited requirements with which employers must comply. OSHA places two requirements on employers when it comes to allowing employees to wear dust masks voluntarily:

1. Employers must determine that the masks themselves do not pose a hazard to workers; and

2. Employers must provide the information found in Appendix D to 1910.134 of OSHA's Respiratory Protection Standard to workers on a one-time basis. This appendix provides important information the employee needs to know about wearing dust masks.

Employers are not required to provide any medical evaluation or fit test for voluntary use of a dust mask.

Respirators other than dust masks
For voluntary use of respirators other than dust masks, the OSHA requirements are more involved. They still don't rise to the level of that required under the full Respiratory Protection Program, but do require employers to take quite a few protective measures.

The employer must:

• Determine that the respirator use will not in itself create a hazard,
• Provide the respirator users with the information contained in the standard's Appendix D,
• Ensure that the respirator users are medically qualified to wear respirators, and
• Ensure that the respirators are properly cleaned, stored, and maintained.

These types of respirators, such as tight-fitting negative-pressure respirators, place a much greater physiological burden on employees, so OSHA requires more of employers when allowing their use even on a voluntary basis. OSHA believes that by requiring employers to implement the above aspects of the Respiratory Protection Program for voluntary use, it will ensure that the respirator is used properly and does not create a hazard to the user. If these provisions are not implemented, potential hazards or problems could result:

• A respirator wearer's health could be jeopardized due to an undetected medical condition (e.g., asthma, heart condition).
• A dirty respirator could cause dermatitis.
• A dirty or poorly disinfected respirator could cause an ingestion hazard.

Who Must/Can Provide Voluntary-Use Respirators?
Either the employer or the employee can provide the respirator for voluntary use. The employer doesn't have to pay for the voluntary-use respirators, but the employer does have to pay for any expenses related to providing the Appendix D information, as well as any necessary medical evaluations and respirator cleaning equipment.

OSHA does encourage employees to use NIOSH-approved respirators for voluntary use, but this is not specifically required.

What About Facial Hair?
Unlike for required respirator use, OSHA does not prohibit employees from having facial hair when they use a tight-fitting respirator voluntarily -- because the air is safe to breathe. But, OSHA does discourage this and recommends following sound industrial hygiene practices, as well as the manufacturer's instructions, even for voluntary use.

Making Your Decision
There are many reasons employees may want to wear respirators voluntarily. In the majority of cases this will involve dust mask use, where the OSHA requirements for employers are not daunting. But, for other types of respirators, voluntary use carries with it more involved requirements for the employer.

The employer's respiratory protection program administrator ultimately must make the call as to whether the voluntary use is permissible. To do that requires a sound knowledge of the work practices, but also an understanding of what OSHA requires.

This article originally appeared in the May 2011 issue of Occupational Health & Safety.