Even though the use of respirators is not required in all situations, some workers may still want to wear a respirator on the job. As far as OSHA is concerned, this is permitted as long as the employer follows the requirements for voluntary use of respirators.
Most workers only use respirators when required by an employer to protect from airborne hazards, such as Silica dust. However, in some situations, a worker may want to wear a respirator even though respirator use is not necessary. Though not required, a worker may still want to wear a dust mask while they cut pavement outdoors using a walk-behind saw with an integrated water system. If the employer permits a worker to wear a respirator where it is not required, it is considered voluntary respirator use.
Before voluntary respirator use is permitted, the employer must ensure its use does not present a health hazard, as described below. However, employers do not have to develop and implement a written respiratory protection program when workers only voluntarily use filtering facepiece respirators.
Voluntary use of respiratory protection is permitted under the OSHA respiratory protection standard 29 CFR 1910.134(c)(2). However, employers that allow their employees to wear filtering face-piece respirators (dust masks) and other types of respirators on a voluntary basis to provide an additional level of comfort and protection must first determine that the exposure levels are below the safe levels established by OSHA’s permissible exposure limits (PEL) and the recommended Threshold Limit Values (TLV) for the potential hazardous materials to which workers might be exposed.
Employers can determine that voluntary use of respiratory protection will not in itself create a hazard by implementing certain elements of a written respiratory protection program. For example, when employees voluntarily want to use any other types of respirators—e.g., half-face cartridge or powered-air-purifying respirator—the employer must ensure that those employees are medically able to use that respirator by having them complete medical questionnaires that will be evaluated by a licensed healthcare professional.
Once approval granted, the employer must ensure that the respirators are cleaned, stored and properly maintained so that they do not present a health hazard to the users. The employer is responsible for the equipment that is used onsite. Fit testing is not required if respirators are used in atmospheres that are not hazardous. Finally, the employees voluntarily using respirators must be given a copy of Appendix D (see below).
Appendix D to Sec. 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under the Standard
Respirators are an effective method of protection against designated hazards when properly selected and worn. Respirator use is encouraged, even when exposures are below the exposure limit, to provide an additional level of comfort and protection for workers. However, if a respirator is used improperly or not kept clean, the respirator itself can become a hazard to the worker. Sometimes, workers may wear respirators to avoid exposures to hazards, even if the amount of hazardous substance does not exceed the limits set by OSHA standards. If the employer provides respirators for your voluntary use, or if the worker uses his/her own respirator, the employer needs to take certain precautions to be sure that the respirator itself does not present a hazard. Start by:
- Explaining all instructions provided by the manufacturer on use, maintenance, cleaning and care, and warnings regarding the respirator’s limitations.
- Choose respirators that have been certified by NIOSH for protection against the contaminant of concern. A label or statement of certification should appear on the respirator or respirator packaging.
- Instructing employees to not wear a respirator into atmospheres containing contaminants for which the respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke.
- Instructing employees to keep track of their respirators so they do not mistakenly use someone else’s respirator.
Remember, voluntary use is only permitted when the employer has determined there is no airborne hazard that requires the use of a respirator.
One last thing to keep in mind, forced air ventilation is the best to control most airborne hazards. Engineering controls are always the best way to control a hazard and respirators should be the last choice when nothing else will work.
George Kennedy is vice president of safety for the National Utility Contractors Association (NUCA) and is a Certified Safety Professional (CSP).