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 http://www.osha.gov.

February 21, 1985

Honorable Bill Bradley
United States Senator
Post Office Box 1720
Union, New Jersey 07083

Dear Senator Bradley:

This is in response to your letter dated December 6, 1984, on behalf of your constituent, Mr. Kenneth R. Thorson, concerning facial hair and the wearing of respirators. Please accept my apology for the delay in our response.

Under current Occupational Safety and Health Administration (OSHA) regulations, engineering controls or administrative controls shall be implemented whenever it is feasible to control the employee's exposure to harmful air contaminants and physical agents. When such controls are not feasible, or during the period of implementation, personal protective equipment such as respirators may be used to keep the exposure of employees to air contaminates within the limits specified in the OSHA health standards.

There are many studies that indicate that bearded persons cannot achieve a satisfactory seal of the respirator facepiece, even with a positive-pressure respirator such as a self-contained breathing apparatus. A copy of a recent study on this subject is enclosed for your information. The U.S. Supreme Court has upheld the rulings made by police and fire departments concerning the length of hair of their employees (copies enclosed).

Several loose-fitting types respirators are available for routine or emergency use such as the hood or helmet-type powered air-purifying respirators (PAPRs), continuous flow supplied air respirators (SAR) and hood-type self-contained breathing apparatus. These respirators could accommodate bearded wearers because facial hair does not interfere with the facepiece seal of these units. However, each of these respirator types has its own limitations. Its acceptability of use must be determined on a case-by-case basis by the employer.

Sincerely,



Edward J. Baier
Director
Directorate of Technical Support