Facial Hair, Respirators, and Fit Testing

A fundamental requirement of using respirators is NO facial hair that could interfere with the respirator’s operation or the respirator’s fit. OSHA states:

1910.134(g)(1)(i) The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:

1910.134(g)(1)(i)(A) Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or

1910.134(g)(1)(i)(B) Any condition that interferes with the face-to-facepiece seal or valve function.

I think we should not be fit-testing employees with facial hair. That is against the respirator policy. I will post an old document from the early days of NIOSH that show acceptable and unacceptable facial hair. I actually include this one-page sheet as an official appendix to my policy/procedure.

The practice of fit testing workers who have facial hair AND pass their QUALITATIVE fit test is a DANGEROUS practice. One, yes, employees will LIE THROUGH their teeth about the fit to keep their facial hair and not have to shave to get a proper fit. My aunt Ruth lied for years about her fit test and facial hair (a bit of Foxworthy Redneck humor there!). Even when using the Quantitative fit testing method and the employee passes with the facial hair, it is a dangerous practice as oftentimes the employees have the respirator pulled so tight during the fit testing that it is not representative of how they would be wearing it in the hazardous atm. They can also NOT control the fullness of the hair or the length, so in three weeks, their facial hair could be considerably different and thus negatively impact their face to mask seal when it matters most.

Fit testing employees with facial hair sends the WRONG message to employees about their safety and lulls them into believing that they can safely wear the respirator with any amount of facial hair. Not to mention the red flags that would arise if an OSHA CSHO was to witness this.

See the attachment for the NIOSH diagram of acceptable facial hair for respirator usage.

 
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