The Cohen Group Newsletter - Volume 18 Issue 3, Article 3. September 2007
Clarifications for the
Voluntary Use of Dust Masks
By Dustin Christensen
Federal OSHA frequently responds to questions of interpretation concerning its regulations. One regulation that seems to generate a substantial number of questions is the Respiratory Protection Standard. A recently published Letter of Interpretation [which can be found at www.osha.gov] addresses many of the questions concerning the use of dust masks. Here is just a summary of OSHA’s responses to several questions dealing with the voluntary use of filtering facepiece respirators.
OSHA clarified that the terms “filtering facepiece” and “dust mask” are synonymous. The standard states that when dust masks are worn voluntarily, employers are not required to do fit testing or provide medical evaluations for the users. Furthermore, employers do not need to prohibit employees from having beards or other facial hair when such employees are voluntarily using dust masks. However, if an employer specifies, or suggests, that employees use a dust mask in work situations, even when exposures are below the PEL, the use of the mask would no longer be considered voluntary and all of the requirements of the Respiratory Protection Program would apply. The employer would then need to provide fit testing for each dust mask user, as well as ensure that the employee has been medically evaluated and approved by a physician to wear the respirator.
Lastly, the Letter of Interpretation indicates that dust masks which are used voluntarily may be altered by employees, as long as the altered dust mask does not pose a hazard itself.
These OSHA responses to questions posed by employers help clarify the liberties that employees and employers may take when the use of dust masks is strictly voluntarily. However, the situations of voluntary use in every company should be carefully evaluated to make sure that all the conditions for voluntary use are met. If you have any questions, feel free to contact The Cohen Group.
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