Overview

This article explores Occupational Safety and Health Administration/Virginia Occupational Safety and Health (OSHA/VOSH) requirements for the voluntary use of respirators. This article covers necessary provisions to allow the safe use of voluntary respirators in the workplace.

Determining Use and Program Requirements

An exposure assessment should be conducted before allowing any respirator to be worn in the work environment. The assessment should determine if employees will be exposed to either airborne contaminants over OSHA/VOSH mandated permissible exposure limits (PEL) or oxygen deficient atmospheres. If there are no atmospheric hazards or regulatory mandates, and the employer does not require a respirator, the use of a respirator is considered voluntary.

What Does “Voluntary Use” Mean?

Voluntary use, according to the OSHA/VOSH definition, occurs when an employee chooses to wear a respirator even though the use of a respirator is not required by the employer or by any OSHA/VOSH standard.¹

That said, there are several misconceptions about what OSHA/VOSH requires when allowing voluntary use of respirators in the workplace.

Understanding the employer’s responsibility can be confusing when reading 29 CFR 1910.134(c)(2) Respiratory Protection. There are two independent sets of requirements depending on the whether the respirator is a filtering piece or a tight- fitting negative pressure respirator. Regardless of the type of respirator chosen, the employer should evaluate the respirator selected and verify that it does not present any additional hazards to the employee, such as any obstruction of vision while wearing the respirator.

Filtering Facepiece Respirators

OSHA/VOSH identifies a filtering facepiece as a dust mask and there are specific minimal requirements for the use of this type of respirator. According to 29 CFR 1910.134(c)(2), the employer is only responsible for providing a copy of Appendix D of the standard to the employees.

Negative Pressure Respirators

There are several requirements if tight-fitting negative pressure respirators are allowed. The employer is responsible for developing and implementing a written program for this type of respirator that includes:

• Provisions for medical evaluations


• Procedures for cleaning, storing, and maintaining the respirators


• Training as outlined in Appendix D


• Designating a program administrator

OSHA/VOSH mandates the implementation of these program elements; otherwise, the following “potential hazards or problems could result:

• A respirator wearer’s health could be jeopardized due to an undetected medical condition (e.g. asthma, heart condition)


• A dirty respirator could cause dermatitis


• A dirty or poorly disinfected respirator could cause an ingestion hazard.”²

OSHA addresses “approved” respirators in a letter of interpretation dated October 1, 1999. This letter states, “The reason OSHA does not require employers to select National Institute of Occupational Safety and Health (NIOSH) approved respirators for voluntary use is because voluntary use is only permitted in an environment that presents no health hazard. However, as a matter of promoting safe work practices, OSHA continues to encourage voluntary users to select NIOSH-approved equipment.”⁴

Consider the following when implementing a voluntary respiratory protection program:

• Determining the type of respirator to be worn,


• Implementing the mandated program elements as required by OSHA/VOSH,


• Encouraging employees to read and follow the manufacturers’ instructions,


• Choosing a NIOSH approved respirator


• Maintaining good records (written program and medical evaluations), and


• Providing training.

¹ Occupational Safety and Health Administration. (September 30, 1998). Small Entity Compliance Guide for the Revised Respiratory Protection Standard. Retrieved April 10, 2008, from, http://www.osha.gov/Publications/SECG_RPS/secgrev-current.pdf.

² Ibid

³ Occupational Safety and Health Administration (February 6, 2006). Standard Interpretations: Facial hair and voluntary use of filtering facepiece respirators. Retrieved March 17, 2008, from: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25342.

⁴ Occupational Safety and Health Administration (October 1, 1999). Standard Interpretations: Respirators for voluntary use and cleaning respirators during fit testing. Retrieved March 17, 2008, from: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22788.

Resources

Janssen, Larry L. (January 18, 2000) What Constitutes Voluntary Use of Respirators? Occupational Hazards. Retrieved March 17, 2008, from, http://www.occupationalhazards.com/News/Article/32902/
What_Constitutes_Voluntary_Use_of_Respirators.aspx.

Occupational Safety and Health Administration (n.d). 29 CFR 1910.134-Respiratory Protection. Retrieved March 17, 2008, from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=12716.

Occupational Safety and Health Administration (n.d). 29 CFR 1910.134-Respiratory Protection: Appendix D: Information for Employees Using Respirators When not Required Under Standard. Retrieved March 17, 2008, from, http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9784.

Occupational Safety and Health Administration. (October 1998). Respiratory Protection eTool. Retrieved March 17, 2008, from, http://www.osha.gov/SLTC/etools/respiratory/index.html.

Occupational Safety and Health Administration. (September 30, 1998). Small Entity Compliance Guide For the Revised Respiratory Protection Standard. Retrieved April 10, 2008, from, http://www.osha.gov/Publications/SECG_RPS/secgrev-current.pdf.

Occupational Safety and Health Administration (December 23, 1998). Standard Interpretations: Clarification of respirator costs, annual training, and “effective” seal checks. Retrieved April 24, 2008, from: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22672.

Occupational Safety and Health Administration (February 6, 2006). Standard Interpretations: Facial hair and voluntary use of filtering facepiece respirators. Retrieved March 17, 2008, from: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=25342.

Occupational Safety and Health Administration (October 1, 1999). Standard Interpretations: Respirators for voluntary use and cleaning respirators during fit testing. Retrieved March 17, 2008, from: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22788.