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.

July 27, 1993

Mr. John Rosenberg
Vice President
Siegwerk, Inc.
Post Office Box 10064
Lynchburg, VA 24506-0064

Dear Mr. Rosenberg:

This is in response to the question in your letter of April 26, concerning the use of the Racal "Breath-Easy 6" powered air purifying respirator (PAPR) for the protection of employees with beards.

In response to your question, it appears that the visor for the respirator is equipped with a bib containing an elastomeric band running along the edge. When the visor is lowered, the bib is intended to be drawn back under the lower jaw so the elastomeric edge forms a line running from ear to ear under the lower jaw. The purpose of the elastomeric band is to draw the edge of the bib snugly against the skin. If your company used this respirator to protect an employee with a beard containing hair growing or extending under the elastomeric edge of the bib, then your company would violate the stipulation in [29 CFR 1910.134(g)(1)(i)] of the respiratory protection standard that reads, "Respirators shall not be worn when conditions prevent a good face seal."

(Correction 03/29/99)

[(1) Facepiece seal protection.
(i) The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:
(A) Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or
(B) Any condition that interferes with the face-to-facepiece seal or valve function.]
A suitable respirator for bearded individuals would be one that did not rely on a face-face piece seal, e.g., a hood type respirator.

We appreciate the opportunity to clarify this matter for you.

Sincerely,

Ruth McCully, Director
Office of Compliance Assistance



May 20, 1993

Mr. John Rosenberg
Vice President
Siegwerk, Inc.
Post Office Box 10064
Lynchberg, Virginia 24506-0064

Dear Mr. Rosenberg:

This is in response to your inquiry of April 26 concerning the Racal "Breathe-Easy 6" powered air-purifying respirator (PAPR).

The answers to your questions follow:

1. The Racal "Breathe-Easy 6" has been approved by the Factory Mutual for use in Class I, Division I hazardous areas (copy of Racal letter enclosed).

2. Your second question involves a standard interpretation concerning the Occupational Safety and Health Administration's (OSHA's) acceptability of this respirator when the user has a growth of beard. I have forwarded your letter to the Office of Health Compliance Assistance for response. Their address and phone number follows:

Ms. Ruth McCully
Director Office of Health Compliance Assistance
Occupational Safety and Health Administration
Room N-3469
200 Constitution Avenue N.W. Washington, D.C. 20210
Telephone: (202)219-8036

Sincerely,

Patricia K. Clark Director
Directorate of Technical Support




April 26, 1993

Ms. Patricia K. Clark Director
Directorate of Technical Support
Occupational Safety
and Health Administration
N3653 200 Constitution Avenue, N.W.
Washington, D.C. 20210

Re: Racal Health and Safety, Inc. "Breathe Easy 6" Respirator.

Dear Ms. Clark:

We are considering the use of the Racal "Breathe Easy 6" respirator. The literature concerning the respirator is attached.

Would you please state in writing whether OSHA approves the respirator for use:

1. in a Class 1 Division 1 area, and

2. by employees with beards to meet the Respiratory Protection Standard [29 CFR 1910.134(g)(1)(i)(A)].

Sincerely yours,

John Rosenberg
Vice President