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.
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