Mandatory vs. Voluntary Respirator Use in the Lab: Where Is the Line?

If your labs rely on engineering controls to control employee exposures to hazardous laboratory materials, you may have a compliance blind spot. When engineering controls, such as chemical fume hoods, glove boxes, local exhaust ventilation systems, and biosafety cabinets, operate correctly, additional respiratory protection is often unnecessary. However, assuming that respiratory protection requirements don’t apply to your laboratory operations can lead to missing the conditions that trigger the requirement for either an OSHA-compliant Voluntary Respirator Use Program or a full Respiratory Protection Program (RPP).

The Three Most Common Scenarios

If your laboratory is covered under the OSHA Laboratory Standard (it is a research, development or academic laboratory where hazardous chemicals are used in laboratory-scale quantities) it falls into one of three categories:

1. No RPP Required: Engineering controls are in place and function as designed, keeping employee exposures below occupational exposure limits.
2. Voluntary Respirator Use: Employees choose to wear respirators for added comfort or peace of mind, such as wearing an N95 during tasks that generate nuisance dust. No full RPP is required, but employers are required to provide employees with Appendix D of OSHA’s Respiratory Protection Standard (29 CFR 1910.134) and ensure the respirator itself does not create a hazard.
3. Mandatory Full RPP Required: A full, OSHA-compliant RPP is required whenever respirators are needed to protect employees from airborne hazards. This may occur when exposure assessments indicate occupational exposure levels could be exceeded, engineering controls are unavailable or inadequate, or OSHA standards require additional respiratory protection.

“Recommending, But Not Requiring” Respirator Use Can Create Compliance Risk

Sometimes organizations unintentionally create safety and compliance concerns by telling employees that respirator use is “recommended but not required”.

This type of recommendation blurs the distinction between mandatory and voluntary use. If employees believe the respirator is necessary to do their work safely, an exposure assessment may be needed to determine if a hazard actually exists. If use of a respirator occurs in a laboratory that is not covered under an RPP, EHS professionals should take the following steps.

1. Observe: Identify who is wearing any form of respiratory protection, including dust masks, disposable filtering facepieces (N95s), half-mask elastomers, or Powered Air-Purifying Respirator (PAPRs).
2. Engage & Evaluate: Interview the user(s). Determine whether respiratory protection is worn strictly for comfort, nuisance odors, or out of concern regarding potential chemical exposures.
3. Verify: Evaluate whether engineering and other controls are in place and function properly.
4. Confirm: Determine if respirator use is truly voluntary. If that cannot be clearly demonstrated, additional evaluation may be necessary. This could include review of industrial hygiene monitoring results, assessing recent objective exposure data or conducting exposure assessments.

From Exposure Monitoring to Program Development: How We Help

Whether you need to conduct exposure monitoring to verify chemical safety, evaluate voluntary use scenarios, or build a fully compliant Respiratory Protection Program, our team can help. Our EHS professionals understand the regulatory nuances of lab environments and deliver tailored solutions to keep your team protected. Don’t let unexamined respirator use turn into an unexpected OSHA compliance issue. Contact our EHS experts today to discuss your program.

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