The Voluntary use of Respirators
Monday, March 11, 2019 John Coniglio
This topic continuously presents itself when we arrive on job sites and see respiratory protection in use. Whether construction or general industry, a response is often used that the employee is using on a voluntary basis.
There are specific requirements for the use of respirators even when used voluntarily. First, in order to be considered a voluntary use, you must know what levels of contaminants are actually present. To do so, a site assessment must be completed to see if the contaminants employees are protecting themselves from are actually below the permissible exposure limit. For each contaminant that is considered, a test must be completed to see that the levels are below the PEL before voluntary use can even be considered as a possibility. There are NO exceptions. So, you need to know the suspect contaminant and its level of exposure.
A complete written respiratory protection program must still be established, even when the use is voluntary (Reference: 29CFR 1910.134). If voluntary use of a respirator is to be allowed, a competent person or program administrator must analyze the use to make sure that a greater hazard is not being created. In that case, voluntary use may be prohibited. Some examples include:
- A location where respiratory protection may be required in some areas, but there is no way for you to monitor workers who are not part of the written respiratory program. You must also have a way to insure that the voluntarily used respirators are being maintained and cleaned as necessary. Further, “if you do decide to allow voluntary respirator use, you have the option to only allow filtering facepieces (disposable dust masks), or to allow elastomeric facepieces. It’s your option, but you must establish a written respiratory protection program that includes procedures for training workers and, if elastomeric facepieces are allowed, procedures for cleaning, maintaining and storing the respirators.” [Occupational Health & Safety, November 2009, Lynn Feiner]
- Workers who wear respirators voluntarily must be medically evaluated to make sure they can wear them safely. Remember that conditions such as asthma, bronchitis or other respiratory airway diseases can definitely impact the user in a negative way.The use of filtering facepieces (disposal dust masks) is the only exception to this requirement.
- Any worker who is being allowed to wear a respirator voluntarily must be provided with a copy of OSHA’s Appendix D from 29CFR 1910.134. While some workers may want to use “comfort masks” which may have one or two straps but are not certified by National Institute of Occupational Safety & Health (NIOSH), they should not be allowed. Only approved equipmentshould be allowed, even on a voluntary basis. You must make sure that the respirator is in fact designed for the contaminant of concern. Again, this goes back to the site assessment and the levels of contaminants.
- Any worker who uses a respirator voluntarily or otherwise must be trained in its use, selection and maintenance. Like medical evaluation, disposables used voluntarily are the only piece of equipment exempt from the cleaning, storage and maintenance requirement.
- Fit testing (and facial hair) is not a direct consideration when voluntary use of a respirator is allowed. Remember, when use is voluntary you must already know that levels are below any permissible exposure limit and that the environment is essentially safe, with or without the respirator. Since the level is safe there is no requirement for the fit test and/or facial hair being removed. However, it is important that during training workers be made aware of the need to be properly fit tested and to remove all facial hair.
Voluntary use of respirators essentially has all the requirements of a regular respiratory program with the exception of disposable type facepieces. However, employers should make it a point to fully invoke all the requirements of a properly prepared respiratory protection program and have a competent person oversee respirator use, whether voluntary or required. Again, the key is making sure you know what the quantitative levels of exposure are before even considering the use of any voluntary respirator use.
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