For those of us that are parents, we know the game of “keeping asking mom and dad in the hopes they’ll change their minds” and sometimes I think our profession acts like teenagers and OSHA has to play the role of “mom and dad”. Case in point, this OSHA LOI which was posted @ OSHA’s LOI page on the use of respirators and facial hair…
Question: If an employee with a neatly trimmed goatee is wearing a respirator and it does not interfere with the seal of the facepiece or valve function and has passed a fit test, does this meet the intent of the OSHA’s Respiratory Protection standard?
This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased question and our response is below.
Question: If an employee with a neatly trimmed goatee is wearing a respirator and it does not interfere with the seal of the facepiece or valve function and has passed a fit test, does this meet the intent of the OSHA’s Respiratory Protection standard?
Response: The Respiratory Protection standard, paragraph 29 CFR 1910.134(g)(1)(i)(A), states that respirators shall not be worn when facial hair comes between the sealing surface of the facepiece and the face or that interferes with valve function. Facial hair is allowed as long as it does not protrude under the respirator seal, or extend far enough to interfere with the device’s valve function. Short mustaches, sideburns, and small goatees that are neatly trimmed so that no hair compromises the seal of the respirator usually do not present a hazard and, therefore, do not violate paragraph 1910.134(g)(1)(i).
In general, however, beards present serious problems for tight-fitting facepiece respirators because their texture and density vary daily, causing unreliable respirator fit and, therefore, present a higher potential for leakage. However, some other types of respirators do not require a face seal, and thus, usually can be worn with facial hair, such as loose fitting powered air-purifying respirators and hooded powered air-purifying respirators.
OSHA has addressed similar questions and outlined the Agency’s interpretation in letters posted on OSHA’s public website, www.osha.gov. See 3/7/2003 and 4/1/2011 letters of interpretation to Senator Levin and Mr. Randy Southard, respectively (copies enclosed). In addition, OSHA’s Small Entity Compliance Guide for the Respiratory Protection Standard (#3384) and the compliance directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, provide additional information. These two guidance documents and others can be found on the Respiratory Protection Safety and Health Topics page at http://www.osha.gov/SLTC/respiratoryprotection/index.html.
NOTE: We can also look to 1910.134 App A Fit Testing Procedures (Mandatory) in which OSHA makes it clear in this MANDATORY Appendix
9. The test shall not be conducted if there is any hair growth between the skin and the facepiece sealing surface, such as stubble beard growth, beard, mustache or sideburns which cross the respirator sealing surface. Any type of apparel which interferes with a satisfactory fit shall be altered or removed.
CLICK HERE for the full LOI