OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 25, 1982

Mr. Richard A. Uhlar
Industrial Hygienist
International Chemical Workers Union
1655 West Market Street
Akron, Ohio 44313

Dear Mr. Uhlar:

This is in response to your letter of October 1, 1981, regarding previous correspondence on the possible use of a rubber skindiving hood under a respirator to provide an adequate face seal in cases where employees have beards or other facial hair. Please accept my apology for the delay in our response.

The proposal for the use of a device that would effectuate a respirator face seal over a beard or other growth of hair appears to be in conflict with the provision of OSHA's respiratory protection standard, 29 CFR [1910.134(g)(1)(i)], which states in part:

"Respirators shall not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, a skull cap that projects under the facepiece,...."

(Correction 08/12/99)

["The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:

Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or Any condition that interferes with the face-to-facepiece seal or valve function."]

For example, the mere covering of excessive facial hair with such a rubber hood might alter the natural facial contours, which could significantly obstruct the conformity of the facepiece to the geometry of the face.

At this time, no evidence has been presented to demonstrate that an adequate quantitative fit test could be obtained by this modification. Therefore, OSHA would consider it an unacceptable practice for respirator usage in hazardous atmospheres, unless it were validated by evidence of an effective face seal in quantitative fit tests and the effectiveness in actual usage. Moreover, there are serious concerns about potential leakage of the system, the porosity of the rubber skindiving hoods, and problems with employee acceptance related to the comfort of the system.

A number of questions were posed in the previous response to your inquiry. These were framed to elaborate on the industrial hygiene aspects necessary in the determination of protection for the worker. If you wish to explore this further when you have more information, please do not hesitate to contact us.

We hope that this discussion is helpful.


Patrick R. Tyson
Federal Compliance and State Programs