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  • Face Masks & Respirators—Mandatory or Voluntary, Know the Difference

    It’s very important right now that employers ensure the proper protections against COVID-19, and employees and employers understand the limitations and requirements for employees wearing respirators or face masks for protection against the virus or other contaminants.

    You can’t turn on the news without hearing about COVID-19. It is the subject of all conversations, news articles, and even employer discussions. While every employer is different, it’s important to know that in your rush to ensure the safety of your employees, the use of respirators is the last line of defense and should be considered after all other options have been addressed as outlined in the hierarchy of controls.

    If exposures cannot be reduced using social distancing, sanitation, or allowing employees to work from home, then respirators or face masks may be the last line of defense to protect against community spread or infection.

    We’ve gotten a lot of questions about this topic recently, so in this blog, I’m going to do my best to outline the use of face masks and respirators, when they’re mandatory or voluntary, and how to know the difference.

    OSHA Standards on Protection Equipment

    First, here’s a look at the different types of equipment available:

    When it comes to the OSHA standard, there are specific, detailed respiratory protection requirements, which apply depending on if use is considered voluntary or involuntary and what is worn by the employee. Check out this chart.

    Whether it’s for mandatory or voluntary respirator use, those responsible for safety in their organizations should know the difference and provide specific details to employees for proper protection.

    Recommended Wear of a Cloth Face Mask for COVID-19

    The CDC now recommends the wear of a cloth (non-surgical mask) face mask to slow community spread. If a face mask is required to be worn as part of the job requirement, then the limitations and purpose of the face mask should be explained to employees. A policy should be established to require the wear by all employees to prevent community spread as part of a larger pandemic response plan.

    Employees should be trained on the fact that:

    • Face masks may obstruct vision.
    • Face masks could get caught in moving machinery.
    • Face masks do not protect the wearer against pathogens.
    • Face masks could spread the virus if contaminated and left on surfaces or machinery.
    • They need to be replaced daily.
    • The wear of face masks can stress the respiratory system in some individuals or the infected. Employees with underlying respiratory or cardiac health conditions may be particularly susceptible to this hazard.

    When Should a Respirator be Mandatory or Emergency

    If a respirator is required to be worn as part of a job requirement or the use is required during an emergency, then the entire OSHA Standard 29 CFR 1910.134 (the chart above) applies.

    This consists of filtering facepiece respirators, including disposable dust masks. Along with the equipment, employers must establish and implement a written respirator program and specific workplace procedures.

    A respirator program must include worksite-specific procedures that address the following:

    • Proper respirator selection
    • Medical evaluations of employees required to use respirators
    • Fit testing procedures for tight-fitting respirators
    • Procedures for proper use of respirators in routine and reasonably foreseeable emergency situations
    • Procedures and schedules for cleaning, disinfecting, storing, inspecting, repairing, discarding, and otherwise maintaining respirators
    • Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere-supplying respirators
    • Training employees in the respiratory hazards to which they are potentially exposed during routine and emergency situations
    • Training employees in the proper use of respirators, including putting on and removing them, any limitations on their use, and their maintenance
    • Procedures for regularly evaluating the effectiveness of the program.

    All of these must be addressed for mandatory and emergency respiratory use.

    Voluntary Wear of Face Masks or Respirators

    This chart explains what is required by OSHA depending on what is worn. Cloth face masks are not included in the OSHA standard.

    ADA Considerations

    Employees with compromised immune systems and respiratory conditions may be at particular risk from community transmission of COVID-19. In workplaces that have not permitted voluntary use of face masks, these employees may request to use face masks as a reasonable accommodation.

    Employers will be required to engage in a robust interactive process and come to a determination as to whether a face mask is a reasonable accommodation or cannot be allowed, for example, if the face mask presents a direct threat due to the health of that employee or an entanglement hazard.

    Training Requirements for COVID-19 Hazards and Policies

    We recommend training employees on COVID-19 hazards and providing appropriate training relating to face mask or respirator policies. Employers can demonstrate the effectiveness of training by preparing documentation of the training sessions and employee sign-offs.

    Training helps eliminate improperly worn, poorly maintained, or nonfunctional equipment that leads to a false sense of security, which can be worse than no protection at all. OSHA’s training provisions require employers to ensure that each employee can demonstrate knowledge of at least the following:

    • Why the respirator is necessary and how improper fit, usage, or maintenance can compromise the protective effect of the respirator
    • What the limitations and capabilities of the respirator are
    • How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions
    • How to inspect, put on and remove, use, and check the seals of the respirator
    • What the procedures are for maintenance and storage of the respirator
    • How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators
    • The general requirements of the respiratory protection regulation

    Training must be conducted prior to respirator use. Retraining is required annually, whenever changes in the workplace or type of respirator would make previous training obsolete, when there are indications that the employee’s knowledge is inadequate, and under any other circumstances where retraining would be necessary to ensure safe respirator use. The only exception is the voluntary use of filtering facepiece respirators (dust masks).

    It’s crucial right now that employees understand the limitations and requirements for whatever they’re wearing. This will ensure they’re protected or are protecting coworkers from contaminants as we all work through this period of COVID-19.

    If you  have any questions, don’t hesitate to reach out to us or visit our COVID-19 Resource Center (updated daily with the latest information). We are here for you!

    Published on: 04.13.20

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Face Masks & Respirators—Mandatory or Voluntary, Know the Difference