['Personal Protective Equipment']
['Respiratory Protection']
12/06/2024
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The short answer is no, not yet. This issue is currently being studied by the National Institute for Occupational Safety and Health (NIOSH). If NIOSH finds that beard bands are effective, it may persuade OSHA to carve an exception within 29 CFR 1910.134 for workers with certain facial hair when bands are worn with a tight-fit respirator.
Facial hair could result in facepiece seal leakage or interfere with respirator valve function. Therefore, OSHA inspectors keep an eye out for worker facial hair (more than one day's growth) between the sealing surface of a tight-fit respirator and the face. When inspectors spot this, they cite the employer under OSHA 29 CFR 1910.134(g)(1)(i)(A). That reads: “Facepiece seal protection … The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have … Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function.”
Per the Respiratory Protection standard at 1910.134, fit testing is required for ALL workers using negative or positive pressure tight-fitting respirators where:
- Such respirators are required by OSHA, or
- The employer requires the use of such a respirator.
Yet, according to a September 14, 2012, OSHA letter of interpretation (LOI): “An employer whose records show a respirator wearer passing a [fit test] with facial hair in the respirator sealing surface area is not considered to be compliant with the standard. The fit that is achieved with a beard or facial hair is unpredictable; it may change daily depending on growth of the hair and position of the hair at the time the fit is tested.”
NIOSH points out that some workers with facial hair cannot shave because of religious, cultural, medical, or other reasons. OSHA’s longstanding answer for employers of these workers has been to offer alternative respirator types, such as a hood- or helmet-type respirator. OSHA admits, however, that these alternative respirator types have limitations. The employer must determine the acceptability of such a respirator in each case. OSHA’s December 16, 2021, LOI explains that labor laws may require employers to provide alternative respirators as a reasonable accommodation to workers who maintain facial hair because of a disability or sincerely held religious beliefs, practices, or observances.
The COVID-19 pandemic highlighted the ongoing need for effective respirators for workers, especially in healthcare. Organizations and interest groups representing workers with facial hair who cannot shave approached NIOSH to conduct research. They suggested that NIOSH investigate fit effectiveness of the respirator when a beard band is used. This is a smooth band placed over the chin and beard while under the respirator sealing surface. It wraps around the head from the chin and secures at the top of the head.
NIOSH has accepted the challenge. NIOSH posted a notice in the July 25, 2024, Federal Register announcing the project, “Fit Testing of Respirators on Those Wearing Beard Bands.” The agency wants to see how well respirators protect workers with facial hair when using a beard band.
This study may help:
- Increase respiratory protective devices available to wearers who cannot shave, and
- Expand respirator adoption by workers with beards, especially in healthcare and public safety.
This project seeks to support the use of respirators for workers with facial hair, including:
- Filtering facepiece respirators,
- Elastomeric half-mask respirators with particulate protections, or
- Full facepiece elastomeric respirators.
Results of this project may:
- Be referred to by NIOSH-approval holders to seek NIOSH approval for the use of beard bands as part of a respirator configuration,
- Provide data to support an OSHA policy regarding the appropriateness of using beard bands with certain respirators,
- Offer employers another means to conform with 1910.134, and
- Increase compliance with 1910.134.
OSHA clarifies that it’s okay if hair is allowed to grow on certain areas of the face like the temples, if it does not protrude under the respirator seal or extend far enough to interfere with the device's function. Acceptable facial hair style examples are listed in the September 14, 2012, LOI. NIOSH too offers a popular infographic from 2017 depicting which of 35 facial hairstyles do and don’t work with filtering facepiece respirators. Find the infographic in NIOSH’s post entitled, “How a Popular Government Infographic About Beards Came to Be.”
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Copyright 2024 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.