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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.
May 9, 2016
Mr. Matthew Sands
606 F Avenue
Altus Air Force Base, Oklahoma 73523
Dear Mr. Sands:
Thank you for your letter to the Occupational Safety and Health Administration (OSHA). Your letter has been referred to the Directorate of Enforcement Programs for an answer to your question. Your letter requested clarification on OSHA’s Respiratory Protection standard, 29 CFR 1910.134, which addresses facial hair and respirator fit. This letter constitutes OSHA’s interpretation only of the requirements herein, and may not be applicable to any questions not delineated within your original correspondence. Your paraphrased question and our response is below.
Question: If an employee with a neatly trimmed goatee is wearing a respirator and it does not interfere with the seal of the face piece or valve function, and has passed a fit test, does this meet the intent of the OSHA’s Respiratory Protection standard?
Response: The Respiratory Protection standard, paragraph 29 CFR 1910.134(g)(1)(i)(A), states that respirators shall not be worn when facial hair comes between the sealing surface of the facepiece and the face or that interferes with valve function. Facial hair is allowed as long as it does not protrude under the respirator seal, or extend far enough to interfere with the device's valve function. Short mustaches, sideburns, and small goatees that are neatly trimmed so that no hair compromises the seal of the respirator usually do not present a hazard and, therefore, do not violate paragraph 1910.134(g)(1)(i).
In general, however, beards present serious problems for tight-fitting facepiece respirators because their texture and density vary daily, causing unreliable respirator fit and, therefore, present a higher potential for leakage. However, some other types of respirators do not require a face seal, and thus, usually can be worn with facial hair, such as loose fitting powered air-purifying respirators and hooded powered air-purifying respirators.
OSHA has addressed similar questions and outlined the Agency’s interpretation in letters posted on OSHA’s public website, www.osha.gov. See 3/7/2003 and 4/1/2011 letters of interpretation to Senator Levin and Mr. Randy Southard, respectively (copies enclosed). In addition, OSHA’s Small Entity Compliance Guide for the Respiratory Protection Standard (#3384) and the compliance directive, Inspection Procedures for the Respiratory Protection Standard, CPL 02-00-158, provide additional information. These two guidance documents and others can be found on the Respiratory Protection Safety and Health Topics page at http://www.osha.gov/SLTC/respiratoryprotection/index.html.
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To assure that you are using the correct information and guidance, please consult OSHA’s website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Thomas Galassi, Director
Directorate of Enforcement Programs