Safety Tidbit #16: Dust Masks versus Respirators

Question: I permit employees to use 3M 7500 respirators on a voluntary basis for dust exposures.  We also have Moldex N100 dust masks.  I have them enrolled in my respirator program with the other workers who are required to wear a respirator.  However, I prefer they wear the more protective 3M 7500 respirator.  Some of my employees that use respirators on a volunteer basis don’t want to be clean shaven and, therefore, cannot pass a fit testing protocol. Also, I am told all N95, and the Moldex N100 dust masks require fit-testing. Is this true?

If I understand you correctly, your employees are using regular respirators equipped with at least N95 dust filters.  So, first, you (the employer) must ensure that the voluntary use of these respirators will not place the workers at risk simply by wearing the respirators [1910.134(c)(2)(i)].  If they do not, and you permit them to wear the respirators, you must include them in your written program under the voluntary use category and ensure they given them Appendix D of the Respirator Standard, medically qualified to use the respirator, and that they keep the respirator clean, maintained and stored appropriately. (in other words they need to be properly trained) [1910.134(c)(2)(ii)].  As you can see, what is missing is the fit-testing requirement.  Mainly because no verified airborne hazard exists so, does it matter if they wear it properly?  Hopefully, they will.

Now to answer the next part of your question, do all N95 mask not need to be fit-tested?  First, let distinguish between regular filter or cartridge type respirators and filtering facepiece (dust mask) type respirators.  OSHA allows you a bit more freedom when you decrease the level of respiratory protection to filtering facepieces. If the use of the regular filter/cartridge type respirators is voluntary, proceed as we discussed above.  If the worker uses a disposable filtering facepiece or dust mask (Moldex N100) on a voluntary basis, these folks don't even need to show up in the respirator program.  Note: if you require any of the above respiratory protection then all bets are off, and the full respirator program and all its parts must be implemented (including fit-testing).

Ultimately, prudent practice recommends keeping track of any respiratory protection used at the facility and train all users as to the respirator's proper maintenance and limitations.  Personally, I see no value with a worker that has a full beard using any respiratory protection that involves a seal with their face. They should use a hood under positive pressure or nothing at all.