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.

September 14, 2012

Mr. Sean Logan
Assistant Fire Chief
Helena Fire Department
300 Neill Ave.
Helena, MT 59601

Dear Mr. Logan:

Thank you for your April 27, 2012, letter to the Occupational Safety and Health Administration's (OSHA) Directorate of Enforcement Programs. Your letter requested clarification of OSHA's policy on facial hair, specifically hair at the temples, and use of a self-contained breathing apparatus.

The OSHA Respiratory Protection standard (29 CFR 1910.134) specifies certain requirements for employers to follow when their employees must wear respirators. The standard states that the employer cannot 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. [1910.134(g)(1)(i)(B)] OSHA has addressed similar questions in several letters of interpretation, including a letter to Mr. Mathew C. Kurzius, issued October 11, 1984. Essentially, it does not matter if hair is allowed to grow on other areas of the face (e.g., hair grown at the temples), as long as it does not protrude under the respirator seal, or extend far enough to interfere with the device's function. An employee who is required to wear a respirator may have hair that falls under the respirator straps, but is not permitted to have hair that interferes with the respirator's sealing surface. Facial hair in the temple region of the face may or may not impact on the facial seal area of the respirator. Sideburns that don't enter the sealing surface area, for instance, are acceptable. However, thick sideburns that intrude into the sealing surface of the respirator are not permitted.

An employer whose records show a respirator wearer passing a fit-test with facial hair in the respirator sealing surface area is not considered to be compliant with the standard. The fit that is achieved with a beard or facial hair is unpredictable; it may change daily depending on growth of the hair and position of the hair at the time the fit is tested.

Please also be aware that the Occupational Safety and Health Act of 1970 exempt employees of state and local governments from coverage by Federal OSHA. The Montana Department of Labor's (MT DOL) Safety and Health Bureau enforce sector workplace compliance in safety and health standards. The MT DOL may be contacted at:

USF&G Building
1625 11th Avenue
Helena, MT 59601
(406) 444-6401

Thank you for your interest in occupational safety and health. We hope you find this information helpful. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Thomas Galassi, Director
Directorate of Enforcement Programs