Face coverings, masks, N95s, respirators: What OSHA obligations do you have?

By: Travis Rhoden

Publication: Workplace Safety Regulatory Alert

Date Posted: 06/17/2020

With the prevalence of face coverings, masks, N95s, and similar protections related to COVID-19, employers will be faced with many questions as work operations ramp up once again.

“Is a cloth face covering a respirator?”

“What about an N95?”

“If employees wear these voluntarily, do I have to fit test them?” “What if we require it?”

What’s a respirator?

The first thing employers must realize is that OSHA’s Respiratory Protection standard only applies to respirators. This includes N95s and similar “filtering facepiece respirators,” as well as more protective half- and full-facepiece respirators.

It does not include cloth face coverings, such as homemade ones from t-shirts or similar fabric.

It also doesn’t include medical-type masks that you might see in a doctor’s office waiting room.

The key difference between these? Respirators protect the wearer, face coverings and similar masks protect others from the wearer.

So, for workers who only wear non-respirator face coverings, employers do not have to implement any sort of fit-testing or medical evaluations, or other obligations from the Respiratory Protection Standard. But, OSHA does provide some guidance. The Agency says employers who determine cloth face coverings should be worn at work, including to comply with local requirements, should ensure the coverings:

  • Fit over the nose and mouth and fit snugly but comfortably against the side of the face;
  • Are secured with ties or ear loops;
  • Include multiple layers of fabric;
  • Allow for breathing without restriction;
  • Can be laundered using the warmest appropriate water setting and machine dried daily after the shift, without damage or change to shape (a clean cloth face covering should be used each day);
  • Are not used if they become wet or contaminated;
  • Are replaced with clean replacements, provided by employer, as needed.
  • Are handled as little as possible to prevent transferring infectious materials to the cloth; and
  • Are not worn with or instead of respiratory protection when respirators are needed.

Guide to OSHA Face Coverings

What do we do for respirators?

If the employer requires respirators, such as N95s be used, then workers must receive a medical evaluation, be fit tested, trained, etc., under a full Respiratory Protection Program.

If the employer allows voluntary use of an N95 or similar filtering facepiece respirator, then the employer only has to make sure the use doesn’t pose any hazards in the workplace, and give the worker a copy of Appendix D from the OSHA Respiratory Protection Standards.

For voluntary use of respirators other than N95s and similar dust masks, for example, a half mask with a cartridge, the OSHA requirements are more involved.

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