Voluntary Respirator Use

When an employer does not mandate the use of a respirator or require one due to an Occupational Safety and Health Administration (OSHA) standard, they may still allow employees to use their own, provided they do not introduce additional hazards. Referred to as “voluntary use” under the Respiratory Protection Standard, the employer must provide employees with a copy of 29 CFR 1910.134 Appendix D (a copy is provided on page 2 of this document), which outlines important information for using respirators when not required by the OSHA standard.

Workers cannot be asked to replace their more protective masks (e.g., a well-fitting N95) with less protective options (e.g., a procedure mask) unless the mask is visibly soiled or damaged. However, personal protective equipment from home may not be sufficient for all job-related hazards. Masks can be worn for an entire shift; however, if the mask is used during patient care where a National Institute for Occupational Safety and Health (NIOSH) approved respirator is required, it should be replaced after each patient encounter.

In some circumstances, healthcare facilities may consider implementing the use of NIOSH-approved respirators with N95 filters or higher and eye protection during certain patient encounters:

Aerosol-generating procedures
Surgical procedures that might pose a high risk for transmission
Positively identified respiratory illness

ARE EMPLOYERS REQUIRED TO PAY FOR RESPIRATORS WORN VOLUNTARILY?

No, employers are not required to pay for filtering facepiece respirators used voluntarily. However, the employer must provide voluntary users with appropriate facilities and time to clean, disinfect, maintain, and store respirators. Guidance can be found at:

https://www.osha.gov/Publications/3384small-entity-for-respiratory-protection-standard-rev.pdf.

IS AN EMPLOYER REQUIRED TO FIT TEST VOLUNTARY USE EMPLOYEES?

No, voluntary respirator use in non-hazardous work environments does not require the respirator wearer to be fit tested. The employer must implement a written respiratory protection program to ensure that employees voluntarily using respirators are medically fit to do so and that the respirator is cleaned, stored, and maintained so that its use does not present any health hazards. See 29 CFR 1910.134(c)(2)(ii).

DOES AN EMPLOYER HAVE AN OBLIGATION TO ENSURE VOLUNTARILY USED RESPIRATORS ARE WORN FOLLOWING THE MANUFACTURER’S INSTRUCTIONS?

No, OSHA does not require employers to ensure that workers who voluntarily use filtering facepiece respirators in nonhazardous environments wear them according to manufacturer’s instructions.

HOW DO I KNOW IF MY MASK FITS CORRECTLY?

A fit test ensures that the respirator provides the intended level of protection by minimizing the risk of contaminants leaking into the facepiece. Urgent care centers, doctor’s offices, and occupational medicine clinics may offer this service in your local area.

There are two types of fit tests:

Qualitative fit testing is a pass/fail assessment that relies on the user’s sensory response. A testing substance will trigger a specific taste, smell, or involuntary cough.
Quantitative fit testing uses instruments to provide a numerical measurement of effectiveness.

HOW OFTEN SHOULD FIT TESTING BE DONE?

According to OSHA, fit testing must be conducted annually or whenever changes affect the respirator’s fit/seal, such as a physical change, including facial scarring, dental alterations, cosmetic surgery, or changes in body weight.

ONCE FIT TESTED, CAN I USE ANY BRAND/MAKE/MODEL RESPIRATOR?
No, a successful fit test only qualifies you to use the specific brand, make, model, and size of the respirator worn during the test. Respirator sizing is not standardized across brands or models, so switching to another type may compromise the fit.

CAN I HAVE FACIAL HAIR?
The OSHA respirator standard prohibits using tight-fitting respirators with facial hair because it interferes with the seal. Studies show that facial hair under the sealing surface can cause up to 1,000 times more leakage than a clean-shaven face. While it’s a common misconception that human hair can act as a filter, hair is far too large to capture tiny hazardous particles, gases, or vapors.

DO POWERED AIR PURIFYING RESPIRATORS (PAPRs) REQUIRE FIT TESTING?

Loose-fitting PAPRs, where the hood or helmet is designed to seal around the wearer’s neck or shoulders, do not require fit testing.

RESOURCES: