“Does OSHA consider an N95 mask to be a respirator?” This is one of the most common questions asked by many companies and safety professionals. Afterall… they look like a dust mask, right? Fortunately, OSHA has provided clarity for this question through multiple Letters of Interpretation they’ve published, the latest being June 12, 2002. In those letters of interpretation OSHA calls N95 masks “filtering facepiece respirators”, confirming that they are in-deed respirators and fall under their 1910.134 standard. The reason is because the air is drawn through a filter that is either attached to the outside of the mask or made as an integral part of the mask.
So, what does this mean for businesses? It means that all companies that REQUIRE one or more employees to use an N95 respirator must have a written Respiratory Protection Program that is compliant with 1910.134(c)(1). It also means all employees who are REQUIRED to wear an N95 respirator must be medically evaluated before initial use, fit tested annually, and trained annually. Those employees must inspect, don/doff, use, maintain and store N95 respirators the same as all other respirators. The only requirement that is a little different for N95 respirators involves cleaning. Since N95 respirators cannot be cleaned, they should be discarded when if they become damaged or soiled.
With all of this said, if N95 respirators are only given to employees to wear on a VOLUNTARY basis and not required, the list of employer responsibilities is drastically reduced. Employers who provide these respirators for VOLUNTARY use are only required to give effected employee the information found in 1910.134 Appendix D and make sure the respirators do not pose a hazard (i.e. they are kept clean). That’s it! A written program, medical evaluations, fit testing, and training are not required. In fact, employees who wear respirators on a voluntary basis are not even required to be clean shaven.
If you would like to check-out some of the Letters of Interpretation that discuss how OSHA’s 1910.134 standard applies to “N95 masks”, click here (https://www.osha.gov/laws-regs/standardinterpretations/publicationdate) and look at the publications dated 3/4/96 – 6/12/02 – 2/6/06 – 11/22/2011 – 4/24/18.
We hope this information provides some clarity for employers that were unsure about this question. If you need help with your Respiratory Protection Program, or other safety efforts, please let us know!
-Tammy Hines; RMS Senior Safety Advisor
