Use of Respirators - Voluntary or Mandatory?

 The OSHA Respiratory Standard requests all employers that require employees to wear a respirator to comply with the requirements of 1910.34.

These include the following:
* Development of a Written Respirator Program
* Air sampling of areas where respirators are required
* Annual employee training on the use, care and sanitation of the respirator provided
* Medical Questionnaire reviewed by an approved physician for all employees required to use a respirator
* Annual Fit Testing for all employees that are required to use a respirator
* Emergency controls where practicable to reduce exposure

I receive numerous questions on these requirements. Many employers want to provide a respirator for their employees, but do not want to have to comply with all of the above requirements. Unfortunately, if you require the use of a respirator then requirements are mandatory.

However, if respirators are not mandatory, but are provided only for an employee’s comfort, then these requirements are not mandatory. OSHA has an exception in the standard on this situation. It states that if employees are provided a respirator at their request and there is no documented exposure to an atmospheric hazard, this is permissible provided that the items in Appendix D of the standard are met.

Appendix D is a one page document. It sates that OSHA wants to encourage employers to provide employees protection from respiratory hazards even if there is no documented over exposure to an air borne contaminant.

If a respirator is provided to an employee for voluntary use or if the employee provides his/her own respirator, OSHA wants the employer to cover the following areas with their employee:
* Respirators are an effective method of protection against respiratory hazards when properly selected and worn.
* Instructions provided by the manufacturer are to be followed.
* Only certified respirators are to be used. A NIOSH label showing certification must appear on the package.
* Wear only the type of respirator for the atmosphere that the respirator is designed for.
* Keep the respirator issued in good condition, clean and sanitary. Also, keep track of the respirator supplied so another employee’s respirator is not used mistakenly.

NOTE: If a tight fitting respirator is supplied Annual Fit Testing is required. This is not the case for a paper mask type respirator.

If you do not require employees to use a respirator, but provide them on a voluntary basis for employee comfort, I recommend you get a copy of the Appendix D of the Respirator Standard and give each employee a copy. This will allow you to supply the additional protection without having to comply with all of the other requirements of the Respirator Standard.

If you need a copy of Appendix D or you have any additional questions or safety concerns, please feel free to call me at 1-800-356-1274.

By Mr. Gary Hanson, President of
American Safety & Health Management Consultants, Inc.