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Standard Interpretations

02/06/2006 - Facial hair and voluntary use of filtering facepiece
respirators.
Standard Interpretations - Table of Contents• Standard Number:1910.134; 1910.134(a); 1910.134(c)(2)(ii)

February 6, 2006
Mr. Gordon C. Miller
Lawrence Livermore Laboratory
P.O. Box 808 (L-379)
Livermore, California 94550
Dear Mr. Miller:
Thank you for your March 29, 2004 letter to the Occupational Safety and HealthAdministration (OSHA), Directorate of Enforcement Programs, concerning the voluntary useof filtering facepiece respirators. This letter constitutes OSHA's interpretation only of therequirements discussed and may not be applicable to any questions or situations notdelineated within your original correspondence. Your questions are repeated below alongwith our response.
Question #1: Does a principal employer have an obligation to prohibit the voluntary use offiltering facepieces by workers who have beards or other facial hair that interfere with thefunctioning of the filtering facepieces? Does an employer have an obligation to prohibit thevoluntary 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 functioningof the filtering facepieces?
Response: No, the voluntary use of respirators in atmospheres which are nothazardous 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.
Question #2: Does an employer have an obligation to ensure that a voluntarily usedfiltering facepiece is properly donned in accordance with manufacturer's instructions andworn properly (e.g., can the employer prohibit using a filtering facepiece if the user cuts off
one of the straps)? Does an employer have an obligation to ensure that a voluntarily usedfiltering facepiece of a contractor employees working on the principal employer's premises isproperly donned in accordance with manufacturer's instructions and worn properly (e.g., canthe employer prohibit using a filtering facepiece if the user cuts off one of the straps)?
Response: The standard does not require employers to ensure that workers, voluntarily
using filtering facepiece respirators in atmospheres which are not hazardous, wear
these respirators according to the manufacturers' instructions, as long as the use of themask itself is not creating a hazard. Employers may, however, prohibit such misuse as partof their respirator program.
Question #3: If an industrial hygienist specifies or suggests using a filtering facepiecerespirator for situations where exposures above a permissible exposure limit (PEL) will notoccur, is this considered a voluntary use of a respirator?
Response: If an industrial hygienist responsible for the safety and health of employees in acompany requires a respirator to be worn in a particular area, even when airborne
contaminants are determined to be below all PELs or other recognized exposure limits, any

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respirator use would not be considered voluntary.
Question #4: If the industrial hygienist allows or agrees to the use of a filtering facepiece,
is this a voluntary use of a respirator?
Response: If an industrial hygienist allows the voluntary use of a respirator to be worn inthe workplace and all airborne contaminants are below OSHA PELs or other recognized
exposure limits, the respirator use would still be considered voluntary.
Question #5: Is there an occasion when a filtering facepiece respirator is not a "dustmask" per 29 CFR 1910.134(c)(2)(ii)?
Response: The Respiratory Protection standard considers the terms "filtering facepieces"and "dust masks" to be synonymous.
Thank you for your interest in occupational safety and health. We hope you find thisinformation helpful. OSHA requirements are set by statute, standards, and regulations. Ourinterpretation letters explain these requirements and how they apply to particular
circumstances, but they cannot create additional employer obligations. This letter
constitutes OSHA's interpretation of the requirements discussed. Our enforcement guidance
may be affected by changes to OSHA rules. Also, from time to time we update our guidancein response to new information. To keep apprised of such developments, you can consult
the OSHA website at www.osha.gov. If you have any further questions, please feel free tocontact the Office of Health Enforcement at (202) 693-2190.
Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs

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