THE COHEN GROUP
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The Cohen Group Newsletter - Volume 4  Issue 3, Article 5.  September 2002

Requirements When Using "Dust Masks" in the Workplace

Mark Golembiewski, CIH

Many employees who wear dust masks during the course of their work activities, or employers who specify them for use by their employees, still have misconceptions about the regulatory requirements. For example, some employers continue to believe that a dust mask isn’t really a respirator since it doesn’t form a tight seal with the face. Others may think that there are no regulatory requirements for those who wear a dust mask at work because they are only used for comfort or to avoid breathing nuisance dust. This article reviews the basic aspects of using dust masks and the regulatory requirements pertaining to their use in the workplace.

The technical term for a "dust mask" is a filtering facepiece, which Cal/OSHA defines as "a negative pressure particulate respirator with a filter as an integral part of the facepiece or with the entire facepiece composed of the filtering medium." In other words, the typical white fabric dust mask with dual elastic straps used by many workers is indeed a respirator that is regulated by the Cal/OSHA respiratory protection standard (8 CCR 5144).

Voluntary Use

An individual can either be required by the employer to wear a dusk mask for protection against airborne contaminants or can use one voluntarily for comfort or personal preference. Voluntary use of any respirator means that the employee requests a respirator even though the use of one is not required by a standard, or the employer has determined that the use of a respirator is not necessary to protect that individual’s health. When dust masks (or any respirators) are provided for voluntary use, the employer must determine that the respirator’s use will not itself create a hazard. A dust mask is not likely to create a hazard for most users, but using other types of respirators in some situations could impair vision or communication during work activities so that a hazard could result where one didn’t exist before.

A written respiratory protection program is not required when employees voluntarily use dust masks, but each user must be provided with a copy of the information contained in Appendix D of the Cal/OSHA standard (8 CCR 5144), "(Mandatory) Information for Employees Using Respirators When Not Required Under the Standard."

Required Use

When an employer requires the use of a filtering facepiece (dust mask) to protect the employee against exposure to an airborne hazard (whether a PEL is exceeded or the employer has a policy to require use to maintain exposures as low as possible), those employees must be included in the employer’s respiratory protection program. These individuals must be provided with a medical evaluation and received appropriate training as required by the standard. Since a dust mask is not a tight-fitting respirator, fit testing is not possible and is not required.

Additional Considerations

Although the Cal/OSHA standard exempts voluntary users from the requirements for medical evaluations and training, consideration should be given to providing these program elements for voluntary users of dust masks for the following reasons:

· The filtering material in each class of dust mask has approximately the same breathing resistance as the same filter type when used with a tight-fitting respirator (elastomeric facepiece); so there is little difference in breathing resistance, and therefore little difference in the physical stress resulting from use of either type of respirator
· A dust mask that is stored improperly could become contaminated and, if used, could cause the same problems that can result from using a contaminated tight-fitting respirator; and
· When a dust mask is required to be used because of overexposure or employer policy, the same requirements that apply to use of any other respirator must be met. That is, a complete respiratory protection program is required.

Employers seeking to go beyond compliance with the standard and minimize their liabilities should consider treating the voluntary use of dust masks as if they were required and include those voluntary users in the company’s respiratory protection program. If there is only voluntary use of dust masks within the company, those uses should be evaluated and consideration given to providing medical evaluations and training to employees as deemed warranted.