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OSHA Respiratory Protection Standards 29 CFR 1910.134

The use of disposable paper respirators, often called "paint masks", is often debated.  Consensus is that these respirators do NOt offer much, if any real protection against small particulates and may lead to a false sense of security and increase risk.  Following are relevant OSHA interpretation and compliance letters.

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OSHA - Occupational Safety and Health Administration

OSHA Standards Interpretation and Compliance Letters
03/04/1993 - Respiratory protection using single-use dust masks.
bulletRecord Type: Interpretation
bulletStandard Number: 1910.134
bulletSubject: Respiratory protection using single-use dust masks.
bulletInformation Date:03/04/1993

March 4, 1993

Mr. James Nickerson
VP, Loss Prevention Champion
One Champion Plaza
Stamford, Connecticut 06921

Dear Mr. Nickerson:

Thank you for your letter dated October 20, 1992, requesting clarification of the requirements of the Respiratory Protection standard (29 CFR 1910.134), as it pertains to single-use dust masks used at the employee's discretion, and only in concentrations below the permissible exposure limit. The answers to your questions are as follows:

1. What is OSHA's definition of a "single-use dust mask"? How does this definition agree/disagree with OSHA's definition of a "respirator"?

OSHA considers a respirator to be a device designed to protect the wearer from inhalation of harmful substances. Respirators fall into the following three general classifications, according to mode of operation: (1) atmosphere-supplying respirators (2) air-purifying respirators and (3) combination atmosphere-supplying and air-purifying respirators.

Air-purifying respirators include the following three types of respirators: (1) gas and vapor respirators (2) particulate (aerosols including dust, fog, fume, mist, smoke, and spray) and (3) combination gas, vapor, and particulate. Specifically, single-use dust masks are considered to be air-purifying particulate respirators.

2. What is OSHA's position on the use of single-use dust masks in concentrations below the PEL? How does this position agree/disagree with OSHA's position on the use of respirators in concentrations at or above the PEL?

OSHA's policy is that if the respirator itself could present an adverse health condition if a specific requirement of the respiratory protection standard is not observed, then the requirement applies. Examples may include a dirty respirator that is causing dermatitis, a worker's health being jeopardized by wearing a respirator due to an inadequately evaluated medical condition, or a significant ingestion hazard created by an improperly cleaned respirator. This is so regardless of whether the employee purchases the respirator or the employer provides it.

Failure to establish and maintain a respiratory protection program would be recorded as a de minimis violation, unless there was a hazard associated with the use of the respirator. A de minimis violation is documented in the compliance officer's case file, but the employer is not issued a citation.

OSHA's position on the use of respirators in concentrations below OSHA's exposure limits is presented in the Field Operations Manual, chapter IV, section C.4.a.(2) and (3) [copy enclosed].

For respirator use in concentrations above OSHA exposure limits, compliance with the Respiratory Protection Standard, 29 CFR 1910.134, and/or respiratory protection requirements of other applicable substance specific standards is required.

3. What is OSHA's compliance/enforcement policy and procedures regarding the use of single-use dust masks in the workplace? How do these agree/disagree with OSHA's compliance/enforcement policy and procedures regarding respirator usage?

See response to question #2.

4. It is widely recognized throughout the safety and health professions that single-use dust masks cannot consistently achieve and maintain an effective facepiece-to-face seal, and cannot be adequately fit-tested. How, then, can single-use dust masks be incorporated into an employer's respiratory protection program and effectively comply with the requirements of 29 CFR 1910.134?

When a respirator is not required by OSHA, then OSHA does not regulate the type of respirator that is provided or the face seal of the respirator. The face seal prohibition only applies to personal respiratory protection devices of a design relying on the principle of forming a face to facepiece seal to perform at maximum effectiveness.

Paragraph (e)(5)(i) requires employers to provide respirator wearers with fitting instructions including demonstrations and practice in how the respirator should be worn, how to adjust it, and how to determine if it fits properly, wearing the respirator in normal air for a long familiarity period, and wearing the respirator in a test atmosphere. Employees must be made aware that certain conditions such as growth of a beard, sideburns, a skull cap that projects under the facepiece, temple pieces on glasses and absence of one or more dentures can affect the fit of a facepiece. In addition, the wearer should follow the manufacturer's facepiece fitting instructions.

5. What is OSHA's position on the use of non-approved "comfort masks" in the workplace for exposures below the PEL? Above the PEL? Champion's respiratory protection program specifies that only appropriate NIOSH/OSHA approved respiratory protection devices are to be used; however, our manufacturing locations receive many sales pitches from vendors for these non-approved "comfort masks".

Only respirators worn to comply with OSHA standards must have OSHA/NIOSH approval. An unapproved respirator cannot be worn if an overexposure is possible.

6. What are OSHA's recommendations/guidelines on the appropriate way(s) to accommodate employee's expressed desire to wear respiratory protection for "comfort" purposes in concentrations below the PEL?

Although OSHA requires the use of respirators only for compliance with permissible exposure limits (PEL's) and respiratory protection requirements of substance specific standards, the voluntary use of respirators and other personal protective equipment at other times may further enhance worker safety and health. However, OSHA discourages the use by employees of any unapproved respiratory protection device.

We appreciate the opportunity to clarify this issue for you.

Sincerely,



Roger A. Clark, Director
Directorate of Compliance Programs




October 20, 1992

Directorate of Compliance Programs
Occupational Safety and Health
Administration
U.S. Department of Labor
200 Constitution Avenue, NW, Room N-3468
Washington, DC 20210

Attn: Roger A. Clark, Director of Compliance

Re: Request for Clarification of OSHA Standard: 29 CFR 1910.134, Respiratory Protection

Dear Mr. Clark:

This letter will initiate a formal request for clarification of the requirements of the Respiratory Protection Standard (29 CFR 1910.134), as it pertains to single-use dust masks used at the employee's discretion, and only in concentrations below the permissible exposure limit.

At many of Champion's locations, industrial hygiene monitoring has documented that exposures to dusts and particulates are well below the OSHA PEL's; however, many workers elect to wear single-use dust masks in these areas, for "comfort" purposes. Champion's current respiratory protection guidelines specify that all respirators must be NIOSH/MSHA approved and that each location's respiratory protection program require training, fit-testing, and medical examination for each designated respirator user in compliance with 1910.134.

Complying with the requirements of 1910.134 for fit-testing and medical examination for workers electing to wear single-use dust masks in concentrations below the PEL, has proven inordinately difficult, in that employees themselves are actively resistant to wearing more effective respiratory protection devices in concentrations below the PEL. Our inquiries to various OSHA area offices and state plan offices throughout the country have obtained inconsistent and widely divergent responses on the proper use and management of single-use dust masks, and on OSHA's enforcement policy and procedure. Our telephone conversation with Mr. John Steelnack in the Health Standards office in Washington, served only to magnify the confused state of affairs regarding single-use dust masks, and the lack of a clear, consistent policy on this issue.

Thus, in order to administer Champion's respiratory protection program in the most safe and healthful manner, we are requesting OSHA's clarification and guidance on this matter. Specifically:

1) What is OSHA's definition of a "single-use dust mask"? How does this definition agree/disagree with OSHA's definition of a "respirator"?

2) What is OSHA's position on the use of single-use dust masks in concentrations below the PEL? How does this position agree/disagree with OSHA's position on the use of respirators in concentrations at or above the PEL?

3) What are OSHA's compliance/enforcement policy and procedures regarding the use of single-use dust masks in the workplace? How do these agree/disagree with OSHA's compliance/enforcement policy and procedures regarding respirator usage?

4) It is widely recognized throughout the safety and health professions that single-use dust masks cannot consistently achieve and maintain an effective facepiece-to-face seal, and cannot be adequately fit-tested. How, then, can single-use dust masks be incorporated into an employer's respiratory protection program and effectively comply with the requirements of 1910.134?

5) What is OSHA's position on the use of non-approved "comfort masks" in the workplace for exposures below the PEL? ... Above the PEL? Champion's respiratory protection program specifies that only appropriate NIOSH/MSHA approved respiratory protection devices are to be used; however, our manufacturing locations receive many sales pitches from vendors for these non-approved "comfort masks."

6) What are OSHA's recommendations/guidelines on the appropriate way(s) to accommodate employee's expressed desire to wear respiratory protection for "comfort" purposes in concentrations below the PEL?

Your clarification and guidance on the issue of single-use dust masks in compliance with the requirements of 1910.134, and your answers to the above listed questions, will serve to enhance the quality of Champion's respiratory protection program(s) and to enhance the safety and health of Champion employees.

We shall be awaiting your response.

Sincerely,



James Nickerson
VP, Loss Prevention

 

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