Are employers responsible for conducting a fit tests for employees that choose to wear respirators but their jobs do not require respirators?
According to an OSHA letter of interpretation issued February 6, 2006, “the voluntary use of respirators in atmospheres which are not hazardous does not require the mask to be fit tested or the wearer to a maintain a tight fit”. Therefore, the employer is not responsible for providing fit tests. In addition, “facial hair is not prohibited when voluntarily using respirators, but it is discouraged.” See the full letter here and another letter regarding voluntary use of respirators from April 26, 2018, for additional information.
Other relevant excerpts from the published OSHA response include:
The April 26, 2018, letter also states that “[i]f the employer determines that any voluntary respirator use is permissible, the employer must provide the respirator users with the information contained in Appendix D of the [respiratory protection standard under 29 CFR 1910.134, titled Information for Employees Using Respirators When Not Required Under the Standard].”
The letter goes on to offer that “[i]f employers allow the voluntary use of elastomeric facepiece and powered air-purifying respirators (after determining that such use will not itself create a hazard), the employer must implement the elements of a written respiratory protection program necessary to ensure that employees voluntarily using such respirators are medically fit to do so, and that the respirator is cleaned, stored, and maintained so that its use does not present a health hazard to the user. See 29 CFR 1910.134(c)(2)(ii).”
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