May surgical masks be provided and worn on a voluntary basis when respiratory protection is not required?

OSHA says the short answer is yes. An employer may provide and allow the voluntary use of surgical masks even where an exposure assessment shows respirator use is not required.

On the flip side, a surgical mask may not be used in lieu of a required respirator because surgical masks are not considered respirators by OSHA and, as such, are not covered by 29 CFR 1910.134. In fact, surgical masks do not seal tightly to the face, nor do they provide a reliable level of protection from inhaling smaller airborne particles. Source: 12/20/2017 OSHA letter of interpretation, “Voluntary use of surgical masks.”