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Toolbox Talk: Voluntary Respirators & Cloth Face Coverings

By April 7, 2020 September 9th, 2021 No Comments
Garco Construction, toolbox talk, building, gc cm, washington, idaho, oregon

Voluntary Use Defined

The first thing the employer must do is make sure that the respirator use is actually “voluntary” as defined in both OSHA and WAC Respiratory Protection Standard. In order for the use to be voluntary (and, thus exempt from many of regulatory 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.  

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 (Garco does not have a voluntary use program for any 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 Table 2 of WAC 296-842 Respiratory Protection Standard to workers on a one-time basis. This table 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.

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.

Respirators protect against airborne hazards when properly selected and used. Respirator usage that is required by DOSH or your employer is not voluntary use. With required use, your employer will need to provide further training and meet additional requirements in this chapter. DOSH recommends voluntary use of respirators when exposure to substance is below DOSH permissible exposure limits (PELs) because respirators can provide you an additional level of comfort and protection.

If you choose to voluntarily use a respirator (whether it is provided by you or your employer) be aware that respirators can create hazards for you, the user. You can avoid these hazards if you know how to use your respirator properly and how to keep it clean. Take these steps:

  • Read and follow all instructions provided by the manufacturer about use, maintenance (cleaning and care), and warnings regarding the respirator’s limitations.
  • Choose respirators that have been certified for use to protect against the substance of concern. The National Institute for Occupational Safety and Health (NIOSH) certifies respirators. If a respirator is not certified by NIOSH, you have no guarantee that it meets minimum design and performance standards for workplace use.
    • A NIOSH approval label will appear on or in the respirator packaging. It will tell you what protection the respirator provides.
  • Keep track of your respirator so you do not mistakenly use someone else’s.
  • Do Not wear your respirator into:
    • Required use situations when you are only allowed voluntary use.
    • Atmospheres containing hazards that your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against solvent vapor, smoke or oxygen deficiency.
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