Safety Tidbit 3.22 - Voluntary Use

Safety Tidbit 3.22 – Voluntary Use

Reference: OSHA Respiratory Protection Standard

Have you heard an employer say? “They are voluntarily wearing those respirators. I don’t have anything to do with them.” If your answer is yes, you’re not alone. Apparently, if a respirator is necessary (because engineering controls are inadequate or still being implemented), then the employer must provide one that is adequate for the purpose and maintain a comprehensive respiratory protection program. However, what happens when there isn’t any reason to wear a respirator because the airborne concentrations are below established workplace levels (e.g., PEL, TLV, REL, WEEL, etc.) but the worker still wants to wear a respirator? Well, the employer still has quite a bit of responsibility.

OSHA states that “an employer may provide respirators at the request of employees or permit employees to use their own respirators if the employer determines that such respirator use will not in itself create a hazard.(emphasis added) If the employer determines that any voluntary respirator use is permissible, the employer shall provide the respirator users with the information contained in Appendix D to this section ("Information for Employees Using Respirators When Not Required Under the Standard").” [1910.134(c)(2)(i)]

Additionally, the employer must “establish and implement those elements of a written respiratory protection program necessary to ensure that any employee using a respirator voluntarily is medically able to use that respirator, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user.” [1910.134(c)(2)(ii)]

Ultimately, if the only respirators used are filtering facepieces (dust masks) on a voluntary basis, then the employer does not need to have a written respirator program. Unfortunately, I find that the employer is only using dust masks but has not assessed the workplace adequately to know what the exposure levels are for her workers. A “gut feeling” is not an adequate hazard assessment.

Remember, that respirators are a potential hazard unto themselves. Therefore, workers must be medically qualified before they are required or permitted to use a respirator. More importantly, if the respirator is not needed why go through the hassle and expense of having them in the first place. Educate the workers on the perceived hazards and the abatement measures implemented such as engineering controls or work practices.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.