Voluntary respirator use is defined as employees choosing to wear a respirator even though workplace conditions do not require one under the Occupational Safety and Health Administration (OSHA) Respiratory Protection Standard [ 29 CFR 1910.134]. It typically occurs when airborne contaminant exposures are below applicable occupational exposure limits, but employees elect to wear respiratory protection for added comfort or peace of mind.
Examples of voluntary use include wearing N95 respirators in an animal care facility to reduce exposure to allergens, while working around nuisance odors from cleaning chemicals (e.g., bleach or ammonia), or during powder handling activities, provided applicable exposure limits are not exceeded.
If employee exposures exceed applicable regulatory limits and feasible engineering or administrative controls cannot adequately reduce those exposures, respirator use becomes mandatory and a respiratory protection program must be implemented. The elements of a mandatory program are described in OSHA’s Respiratory Protection eTool.
Many employers assume that voluntary respirator use carries few or no compliance obligations. However, the Respiratory Protection Standard has specific requirements for voluntary use, which differ depending on the type of respirator used.
Voluntary Use: Filtering Facepiece (Disposable) vs. Elastomeric Respirators
One of the most important distinctions in OSHA’s voluntary-use requirements concerns respirator type. When employees voluntarily wear filtering facepiece respirators, such as N95s, employer obligations are generally limited to ensuring that respirator use itself does not create a hazard and providing Appendix D, Information for Employees Using Respirators When not Required Under the Standard.
Obligations increase when employees voluntarily wear elastomeric half-facepiece or full-facepiece respirators. For this type of equipment, employers must implement certain elements of a respiratory protection program to ensure that respirator use does not itself create a hazard.
The following sections summarize OSHA’s rules for voluntary use of filtering facepiece and elastomeric respirators.
Appendix D Requirements
The information in Appendix D of the Respiratory Protection Standard is intended to ensure that employees understand how to properly select, use, maintain, and store respirators so that voluntary use does not create a health or safety hazard.
Appendix D instructs employees to:
- Follow the manufacturer’s instructions regarding use and maintenance.
- Use a certified respirator appropriate for the hazard, such as one that is NIOSH-approved.
- Avoid using respirators in environments for which they were not designed.
- Track respirators so that other employees’ equipment is not mistakenly used.
OSHA requires employers to provide Appendix D information to employees who voluntarily wear either filtering facepiece or elastomeric respirators. The standard allows for the information to be provided in either written or oral form.
Although OSHA does not prescribe a specific method for documenting that the information was delivered, many organizations choose to use an Appendix D acknowledgment form because it provides clear documentation that the employee:
- Received and reviewed the information.
- Understands that respirator use is voluntary.
While OSHA does not mandate written acknowledgment of Appendix D receipt, maintaining signed acknowledgments can provide useful documentation of compliance during inspections or audits.
Written Respiratory Protection Program Requirements
When elastomeric respirators are used voluntarily, employers must also implement specific elements of a written respiratory protection program. These elements include medical evaluations (described below) and procedures for respirator cleaning, storage, and maintenance. At a minimum, employers should address the following:
- Cleaning and Disinfection: Respirators must be cleaned and disinfected regularly to prevent contamination and ensure hygienic use.
- Inspection and Maintenance: Employees should inspect respirators before use and replace damaged components promptly. If repairs cannot be made by the user, the equipment must not be used until it is either fixed by a qualified person or replaced.
- Proper Storage: Respirators should be protected from dust, sunlight, excessive temperatures, moisture, and physical damage.
In addition to OSHA’s specific requirements, best practice may warrant implementing additional elements of a written program for voluntary respirator use.
Medical Evaluations
For employees who voluntarily wear elastomeric respirators, OSHA requires a medical evaluation to determine whether they can safely wear them. This provision is in place because elastomeric respirators impose a greater physiological burden than filtering facepiece respirators. Pre-existing health conditions, particularly cardiovascular or respiratory conditions, may make respirator use unsafe for some employees.
Medical evaluations help ensure that:
- Employees can safely wear the selected respirator.
- Existing medical conditions are identified.
- Respirator use does not place undue physiological strain on the employee.
Medical evaluations must be paid for by the employer. In addition, associated records must be maintained in compliance with OSHA’s standard on Access to Employee Exposure and Medical Records [29 CFR 1910.1020].
Training Best Practices
Although not specifically required by OSHA, best practice is to provide training to employees who voluntarily wear either filtering facepiece or elastomeric respirators that includes information on:
- Appendix D.
- Hazards associated with respirator use and their limitations.
- Proper inspection procedures, cleaning requirements, and storage/disposal expectations.
Final Thoughts
It is easy to assume that voluntary respirator use requires little oversight, but important compliance obligations still exist. A documented and consistent approach helps organizations maintain compliance, support employee health, and prevent hazards associated with improper respirator use.
For help determining whether respirator use at your facility should be mandatory or voluntary, implementing a respiratory protection program, or conducting the required training, contact us.
This blog was written by Beth Graham, Director of Quality, Research, and Training at Safety Partners.
