Standard Interpretations - Table of Contents|
| Standard Number:||1910.134(g)(1)(i); 1910.134(g)(1)(ii); 1910.134(g)(1)(iii)|
The Honorable Christopher J. Dodd
United States Senate
Washington, D.C. 20510
The Honorable Nancy L. Johnson
House of Representatives
Washington, D.C. 20510
Dear Senator Dodd:
This is in response to your letter of October 29, on behalf of John F. Wildman of Bethlehem, Connecticut, regarding the use of respirators. Mr. Wildman is concerned about a provision of the Occupational Safety and Health Administration's (OSHA) respiratory protection standard which concerns the fitting of respirators.
A copy of the pertinent section of the respirator standard that applies, [29 CFR 1910.134(g)(1)(i-iii)], is enclosed. It states that 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, or temple pieces on glasses. This regulation does not ban facial hair on respirator users, per se, from the workplace. However, when a respirator must be worn to protect employees from airborne contaminants, it has to fit correctly, and this will require the wearer's face to be clean-shaven where the respirator seals against it.
It does not matter if hair is allowed to grow on other areas of the face, if it does not protrude under the respirator seal, or extend far enough to interfere with the device's function (such as the interference with valve function). Accordingly, short mustaches, sideburns and small goatees that are trimmed so that no hair underlies the seal of the respirator present no hazard and do not violate [29 CFR 1910.134(g)(1)(i)]. In general, however, beards present serious problems of acceptability because their texture and density vary daily, there is no consistency to respirator fit, and there is higher leakage.
Some types of respirators do not require a face seal, and thus usually can
be worn by bearded employees. Specifically, these are positive pressure
respirators of the hooded and helmet type, and types that can be used with a
continuous-flow, supplied-air respirator, where facial hair and beards will
have less effect on the fit. For emergency use, there is an escape hood with
a continuous flow of air and a fifteen-minute service life. Respirators of
this type that have been approved by the National Institute for Occupational
and Health and the Mine Safety and Health Administration are available
on the market.
[This document was edited on 03/29/99 to strike information that no longer reflects current OSHA policy.]
It should be emphasized that all respirators must be properly fitted, regardless of which type is worn or whether or not the wearer has facial hair. Positive pressure-type respirators can have leakage paths which can cause aspiration of the outside atmosphere. On self-contained breathing apparatus, high leakage will markedly reduce the service life of the tank. In addition, research reported at the American Industrial Hygiene Conference in June 1982 demonstrated that even modest facial hair growth can have a significant adverse impact on the protection of a positive pressure system.
In addressing this specific situation, Mr. Wildman may wish to contact the State of Connecticut, which administers its own occupational safety and health program for public employees under a provision of the Occupational Safety and Health Act of 1970, subject to close monitoring by Federal OSHA. OSHA requires States to cover volunteers only if they are considered "employees" under the State's occupational safety and health act. Under the Connecticut program, volunteer firefighters are deemed "employees" and therefore are required to be covered under the Connecticut public-employee-only plan. If Mr. Wildman needs further information from the administering State agency, the address and telephone number are:
P. Joseph Peraro, Commissioner
Connecticut Department of Labor
200 Folly Brook Blvd.
Wethersfield, Connecticut 06109
If we may be of further assistance, please feel free to contact us again.
John B. Miles, Jr., Director
Directorate of Field Operations
|Standard Interpretations - Table of Contents|