As federal, state and local governments advocate (and in some cases require) the use of cloth “face coverings” as a Covid source control measure, many businesses have questions about the regulatory compliance implications and whether use of face coverings is subject to the same requirements as use of respirators at work.
The OSHA respiratory protection standard (29 CFR 1910.134) establishes employer requirements when employees use respirators at work. Regulatory requirements are identical under the Cal/OSHA respiratory protection standard (8 CCR 5144). For OSHA, and Cal/OSHA, the term “respirator” refers to personal protective equipment (PPE) intended to protect the worker from inhalation exposures to hazardous materials (gas, vapor or particulate). In all cases, respirators must be certified for their intended use by the National Institute of Occupational Safety and Health (NIOSH).
Since face coverings are not respirators, use of face coverings at work is not subject to the requirements of the OSHA respirator standard, even if use of face coverings is required by the employer.
It is possible for workers to use disposable N-95 “filtering facepiece” respirators (or other “real” respirators) as a “face covering”. In this case, the N-95 (or other respirator) is still being worn for source control purposes, not personal protection.
Where N-95s (or other respirators) are used on a voluntary basis as a source control measure, and the respirators do not need to maintain any certification or qualifications, the respirators can be cleaned and/or re-used as appropriate, based on hygiene, physical condition and similar considerations.
If employers require employees to use N-95 respirators (or any other respirator) for covid-control (or for any other purpose), then the voluntary use provisions no longer apply and the employer is subject to the applicable requirements of the respiratory protection standard, including written program, training, medical surveillance, fit testing, etc.
Do you have any questions about respiratory protection and Covid? Or about respirator use in general? Or any other workplace safety or environmental compliance issues?
Contact [email protected]
James Kapin, MPH, CIH, CSP
Director of EM Services,