OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 11, 1984

Mr. Mathew C. Kurzius
IBEW, Local 1673
235 Columbia Street
Dunellen, N.J. 08812

Dear Mr. Kurzius:

This is in response to your letter of September 29, 1984 concerning facial hair and the wearing of respirators. We are providing the following answers to your questions.

1. A copy of the pertinent section of the respirator standard that applies, [29 CFR 1910.134(g)(1)(i-iii)], is enclosed. It states that respirators shall not be worn when conditions prevent a good face seal. Such conditions may be a growth of beard, sideburns, a skull cap that projects under the facepiece, or temple pieces on glasses. This regulation does not ban facial hair on respirator users, per se, from the workplace.

However, when a respirator must be worn to protect employees from airborne contaminants, it has to fit correctly, and this will require the wearer's face to be clean-shaven where the respirator seals against it.

OSHA requires respirators to be used when they are necessary to protect employees against overexposure to air contaminants. When administrative or engineering controls have not kept workplace exposure to air, contaminants within OSHA's established permissible limits, then appropriate respirators must be worn by the exposed employees. The standard ([1910.134(g)(1)(i-iii)]) only applies to those employees who need the protection of a tight-fitting facepiece respirator, either routinely or in emergencies, because of such overexposure.

It does not matter if hair is allowed to grow on other areas of the face if it does not protrude under the respirator seal. Accordingly, mustaches, sideburns, and small goatees that are trimmed so that no hair underlies the seal of the respirator present no hazard and do not violate [1910.134(g)(1)(i)(A)].

2. The use of a self-contained breathing apparatus (SCBA), such as the Scott Air Pac, is not acceptable for bearded employees under emergency conditions. Since the SCBA is used in unknown concentrations for unspecified lengths of time, maximum protection must be achieved when the SCBAs are worn. The beard growth can significantly reduce the service life of the air cylinder on the SCBA which could restrict the performance in the emergency operation. The SCBA wearer can "overbreathe" when moderately heavy to heavy workloads are performed. If there is a leak caused by the beard, the air contaminant could be pulled inside the facepiece. Furthermore, the beard can interfere with the sealing of the exhalation valve and shortening the service life of the air supply. For emergency use, there is an escape hood with a continuous flow of air and a fifteen-minute service life which usually can be worn by bearded employees. Respirators of this type that have been approved by the National Institute for Occupational Safety and Health are available on the market.

3. The employer would be in violation of [1910.134(g)(1)(i)(A)] if a bearded employee wore a SCBA under a true emergency situation.

We hope this information is helpful. If we can be of further assistance, please let us know.

Sincerely,

Cathie M. Mannion
Assistant Regional Administrator
for Technical Support