Beards and tight-fitting respirator face seals

October 3, 1996

(Name Withheld)
Dear (Name Withheld):

This letter is in response to your inquiry on beards, respirator use, and fit testing of respirators. As background information it may be helpful to state, in general terms, OSHA's requirements about the respirator face seal and beards. As you are aware, [29 CFR 1910.134(g)(1)(i)] states the following:

~~Respirators shall not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, a skull cap that projects under the facepiece, or temple pieces on glasses.~~

(Correction 03/29/99)

[(1) Facepiece seal protection.

(i) The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:
(A) Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or
(B) Any condition that interferes with the face-to-facepiece seal or valve function.]

This requirement applies to both negative or positive pressure respiratory protective devices that rely on the principle of forming a face to facepiece seal.

Beard growth at points where the seal with the face and respirator occurs is a condition that has been shown by numerous studies to prevent a good face seal. Copies of relevant articles documenting this have been enclosed. Thus an employer using a respirator to protect an employee with a growth of beard where the seal is compromised by the beard growth is violating [29 CFR 1910.134(g)(1)(i)(A)]. The OSHA standard does allow beards with the use of respirators that do not rely on a tight facepiece seal between the respirator inlet covering and the underlying skin (i.e., both loose fitting helmets and hoods are acceptable in this regard).

In response to your list of questions, the following is provided:

1. If a hospital had a policy that any employee that has a beard and can achieve a good face seal may enter an "AFB" isolation room if he has documented proof of a consistent good face seal by quantitative fit testing, would OSHA fine or cite that hospital? Would that hospital be in violation of any OSHA regulation because of such a policy?

As has already been stated, it is OSHA's policy to enforce [29 CFR 1910.134(g)(1)(i)(A)]. Also, as already stated, it has been shown that beard growth prevents a good face seal. The regulatory language in the paragraph does not make any exceptions when fit testing shows that a good fit has been achieved for persons with beards. Also, seeing that facial-hair growth occurs daily and, thus, fit testing performed on a previous day may not be valid for the day the respirator is worn, OSHA cannot concur with your hospital policy as an allowable exception to the requirement in [1910.134(g)(1)(i)(A)].

2. Is there any OSHA standard that states that a person with a beard cannot be quantitatively fit tested?

~~No: our respiratory protection standard only requires that the user of a respirator be fit tested. The fit-test method accepted can be either quantitative or qualitative. As previously mentioned, there have been numerous studies conducted that have shown that individuals with a beard or beard growth cannot consistently achieve an adequate face to respirator seal.~~

[This document was edited on 03/29/99 to strike information that no longer reflects current OSHA policy.]

3. Is there any regulation stating that a beard that does not touch the area of the seal (and the area of the seal is clean shaven) is not permitted when entering a "TB" isolation room?

No: if employees can trim their beards so that the beards do not come between their face to respirator seals or interfere with respirator-valve function, then their use of the respirators would be acceptable provided they passed a proper fit test.

4. If OSHA is requiring an employer to abuse an employee's civil rights by forcing an employee to shave his beard or be fired - shouldn't OSHA require the employer to provide a positive pressure hood system instead?

The current 29 CFR 1910.134 respiratory protection standard requires that the respirator be certified by the National Institute for Occupational Safety and Health (NIOSH), be appropriate for the intended use, and provide adequate protection against the hazardous exposure. The standard does not require the employer to provide a more protective respirator if its use is not warranted by the hazardous exposure.

~~For your information, OSHA is completing revisions to the final respiratory protection standard that will replace the current 29 CFR 1910.134 standard. The new respirator standard is tentatively scheduled for release this fall.~~ We hope these answers satisfactorily address your questions. If you have any other comments or concerns, please contact the Office of Health Compliance Assistance at [(202) 693-2190].

[This document was edited on 03/29/99 to strike information that no longer reflects current OSHA policy.]

Sincerely,

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

Enclosure

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