Voluntary disposable respirators without expected overexposure

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

December 4, 1995

Mr. Marvin Dinkel
Industrial Safety Coordinator
Kansas Department of Human Resources
Division of Labor-Management Relations
& Employment Standards
Industrial Safety and Health Section
Accident Prevention Unit
[Recipient address omitted]
Dear Mr. Dinkel:

This is in response to your August 21, letter to the Director of Compliance Programs, requesting clarification of the requirements of the Respiratory Protection Standard, 29 CFR 1910.134, as it pertains to employees wearing disposable dust respirators

Ms. Patricia K. Clark's, March 19, 1991 letter remains basically correct, in that, in situations where an over-exposure to a chemical does not exist and the potential for an over-exposure is not anticipated, the employer is not mandated to comply with the Respiratory Protection Standard. However, it should be noted that in some circumstances adverse health conditions can be caused by the wearing of a respirator. Examples of those circumstances include, but are not limited to, (1) the wearing of a dirty respirator that causes dermatitis, or ingestion of a hazardous chemical; (2) the sharing of a respirator that leads to transmittal of disease; (3) an employee's health being jeopardized by the wearing of a respirator (e.g., employee has a cardiac and/or pulmonary disorder). Therefore, it is recommended that training and medical surveillance be considered for all employees who may elect to use a respirator for personal comfort.

We appreciate the opportunity to clarify this matter for you. If you have any further questions, please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 219-8036.

Sincerely,
John B. Miles, Jr., Director
Directorate of Compliance Programs

[Requester letter reproduced on OSHA page; omitted here.]