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by Bill Taylor, CSP
Principal Safety Scientist

There has been a great deal of confusion and misinformation lately regarding the use of respirators as a safeguard from COVID-19. The most recent guidance from the Centers for Disease Control (CDC) states that wearing some type of face mask may prevent the spread of the Coronavirus, but offers little protection from contracting the disease. This blog article is intended to guide employers whose workers wish to voluntarily wear personal protective equipment (PPE) where there is no hazard.

A frequently asked question is centered on fit testing and medical evaluation. Voluntary use of any type of filtering facepiece (“dust mask”) respirator (including the N95) only requires the employer to provide the employee with a copy of Appendix D of the respiratory protection standard, 29 CFR 1910.134. There is no requirement for fit testing or medical evaluation for voluntary use during which there is no hazard exposure. If however, the employer, as a precautionary measure, requires employees to wear any type of respirator, the employer must implement a written respiratory protection program under 1910.134, including fit testing and medical evaluation.

It should be noted that employers are under no obligation to medically qualify employees who voluntarily wear a disposable respirator such as the N-95.  However, if the wearer should experience a medical event as a result of wearing PPE in the work environment, under the OSHA recordkeeping standard at 1904.5(a), the event would be considered “work related” and must be evaluated as such to determine if it should be recorded on the OSHA 300 Log.

If you have any questions regarding respirator usage or other safety-related concerns during or after the COVID-19 Pandemic, please reach out to Bill Taylor, Principal Safety Scientist with The EI Group, Inc., at (919) 593-2145 or btaylor@ei1.com.