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.

March 29, 1985

Mr. Kenneth R. Thorson
278 Belleville Turnpike
Kearny, New Jersey 07032

Dear Mr. Thorson:

This is in response to your letter of February 10, 1985, concerning questions on facial hair and respirator wearing.

Answers to your questions are as follows: (Note: The numbered paragraphs below correspond to the numbers of your questions. There was no question III.)

I. There are several published studies which indicate that bearded individuals do not obtain a satisfactory facepiece seal on a tight fitting face piece because the growth, texture and density of beards vary around the face. A person may obtain an acceptable facepiece fit on a given day, but find that he is unable to achieve a consistently satisfactory fit on a daily basis, no matter whether the facepiece is of paper, fabric, plastic or rubber. We are enclosing these studies for your information.

II. The Occupational Safety and Health Administration (OSHA) regulation, 29 CFR [1910.134(g)(1)(i-iii)], addresses the safe use of respirators. Whenever a respirator is worn, proper precautions must be exercised to insure that the wearer is protected against overexposure to toxic air contaminants. The regulation does not differentiate whether the respirator is worn routinely or occasionally. We have been informed by Scott Aviation that they do not recommend that bearded individuals wear their tight fitting self-contained breathing apparatus.

IV. OSHA issues citations if it finds the employer is permitting bearded employees to wear tight fitting respirators. Respirators are only required if employees are overexposed to the toxic air contaminants. The employer must perform monitoring to determine whether the employee is exposed to toxic air contaminants in excess of the permissible exposure limit (PEL) as prescribed in our regulations, 29 CFR 1910, Subpart Z - Toxic and Hazardous Substances (enclosed). To achieve compliance with the Subpart Z, the employer must implement engineering or administrative controls whenever feasible. When such controls are not feasible to achieve full compliance, protective equipment or any other protective measures shall be used to keep the exposure of employees to air contaminants within the limits prescribed in Subpart Z.