What Constitutes Voluntary Use of Respirators?

Do you need a respiratory protection program if exposures are below the OSHA PEL? A look at voluntary respirator use and the revised OSHA standard.

The Occupational Health and Safety Administration (OSHA) has always required employers to have a complete respiratory protection program when respirators are used to protect employees from air contaminant exposures above the OSHA Permissible Exposure Limits (PELs). However, respirators often are used in two situations in which the PEL is not exceeded:

  • When employer policy requires respirator use for specific operations; and
  • When employees ask to wear respirators, and the employer permits their use ( i.e., voluntary respirator use).

Exposure assessment, preferably air sampling, must be conducted to determine whether overexposures exist.

Revised OSHA Regulation Specifies Requirements

Since the OSHA Respiratory Protection regulation, 29 CFR 1910.134, was published in 1971, it has listed the elements of a respiratory protection program. These include:

  • Proper respirator selection;
  • Training;
  • Fit testing;
  • Medical evaluation;
  • Maintenance procedures, including cleaning, inspection, repair and storage;
  • Procedures for proper respirator use;
  • Breathing air quality assurance for atmosphere supplying respirators; and
  • Program evaluation.

These elements are intended to maximize the capability of respirators to reduce worker exposure to air contaminants and to ensure that respirator misuse does not create hazards for workers.

The original regulation did not identify respiratory protection program requirements for situations in which there is no overexposure. However, the Jan. 8, 1998, revision to 1910.134 specifies program elements necessary when respirators are used for exposures below the PEL.

When Employers Require Respirators

The program requirements are stated very simply for situations in which employers require respirators: All elements of a respiratory protection program must be in place. An employer's decision to require respirator use indicates a belief that a hazard may exist even though the OSHA PEL is not exceeded. For instance, an employer may decide to control exposures to a lower, advisory exposure limit, such as the Threshold Limit Value established by the American Conference of Governmental Industrial Hygienists. Clearly, it makes sense to maximize respirator effectiveness with a complete respiratory protection program, because protection from a perceived hazard is intended.

Voluntary Respirator Use

Before reviewing OSHA's program requirements for voluntary respirator use, it is important to understand clearly what voluntary use is and is not. Voluntary use means:

  • An exposure assessment has been conducted;
  • The PEL is not exceeded;
  • No OSHA regulation requires that respirators be provided by the employer (For example, 1910.1025, requires employers to provide respirators upon request to employees exposed to lead at any concentration.);
  • The employer does not believe it is necessary to reduce exposures below their current levels (i.e., there is no perceived hazard);
  • The employer does not require, recommend, encourage or suggest that respirators be used;
  • Workers ask to wear respirators; and
  • Respirators will not be used for emergency response or escape.

If one or more of these conditions are not met, respirator use is not voluntary. Therefore, a complete respiratory protection program is required.

If respirator use is permitted and all of the above conditions are met, a voluntary-use situation exists. Paragraph (c)(2) of 1910.134 requires a limited respiratory protection program in this case. The only program elements specified are those that OSHA believes will prevent respirator use from creating a hazard to the user. These are:

  • Medical evaluation, principally because the breathing resistance associated with negative pressure respirators may be intolerable to a few individuals;
  • Cleaning, storage and maintenance, because a respirator contaminated by improper storage or not cleaned could promote skin irritation or similar problems; and
  • Minimal training, such as information found in Appendix D of the regulation.

Puzzling Exemption

Interestingly, for voluntary use of filtering facepiece respirators, which OSHA also calls dust masks, the regulation contains an exemption from two of these program requirements. Workers who wear filtering facepieces voluntarily need only be provided with the information in Appendix D. This exemption is puzzling for the following reasons:

  • A filtering facepiece of a given class, has approximately the same breathing resistance as the same filter type used in an elastomeric facepiece;
  • A filtering facepiece that is stored improperly could become contaminated and cause the same problems that a contaminated elastomeric facepiece can cause; and
  • When use of filtering facepieces is required because of overexposure or employer policy, the situation is handled in exactly the same manner as with any other respirator: A complete respiratory protection program is required.

For these reasons, filtering facepieces and other respirators should not be treated differently in voluntary-use situations. The same program elements appropriate for elastomeric respirators should be implemented for filtering facepieces.

Consider Additional Program Elements

Employers must decide if OSHA's voluntary-use program requirements are sufficient for voluntary use in their workplaces. In many situations, additional program elements should be considered. The following two examples illustrate this point.

OSHA does not require procedures for proper respirator use in voluntary situations. This omission permits misuse, such as wearing a beard with a tight-fitting respirator. This practice is prohibited when respirator use is required. At the very least, allowing voluntary respirator users to have beards would cause administrative problems if workers in another part of the facility are required to wear respirators and be clean-shaven. For this reason, (and others), many employers may choose to require voluntary respirator users to be clean-shaven.

Fit testing is not required for voluntary use. Employers must determine if waiving fit testing is compatible with their reasons for allowing respirators to be used voluntarily. If the goal of voluntary-use programs is enhancing employees' comfort, with the full understanding that there is no real or potential hazard present, employers may be comfortable not requiring fit testing. Specifically, a nonhazardous atmosphere leaking into the facepiece is not a concern. Conversely, employers who believe that exposures should be reduced to the lowest possible level, even when there is no known hazard, will include fit testing in their voluntary-use programs.

Given the litigious nature of our society, many employers will conclude it is prudent to maximize respirators' effectiveness whenever they are used. If so, they will elect to implement complete respiratory protection programs for voluntary use.

Larry L. Janssen is a certified industrial hygienist in 3M's Occupational Health and Environmental Safety Division.

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