While OSHA could probably find a few reasons to cite Santa’s North Pole facility, his beard likely wouldn’t be one because his occupation doesn’t require him to wear a facemask.
Goaltenders are required to wear facemasks in their place of employment, but the nature of their work doesn’t require the mask to provide an air-tight seal, so they are permitted to grow a beard underneath it.
Unfortunately, if your occupation does require you to wear a tight-fitting respirator mask, you will have to forego the beard.
Clean shaven is the rule to protect employees from unsafe working conditions and protect the companies from possible OSHA citations and liability concerns.
Here is a look at why facial hair – even when it is closely-trimmed and well-groomed – is problematic for Fit Tests as well as some other factors that can affect the Fit Testing process.
Fit Test Requirements
First, OMY only conducts Fit Tests on companies where OMY is already conducting Pulmonary Function Testing. This is to ensure that we are only administering Fit Tests to employees who have already been medically cleared to wear the required respirator.
Additionally, OMY can only conduct Fit Tests on employees who are clean shaven, and this is something that we have to be very firm about.
Sometimes employees will try to argue for exceptions for facial hair such as sideburns, goatees and moustaches that don’t directly interfere with the area where the mask meets the face. However, this is problematic because:
- The Fit Test is only valid for your facial appearance on the day of the testing.
- Facial hair is constantly growing and changing, so it’s possible that a facial hairstyle that passes the Fit Test today could be problematic tomorrow.
- Clean shaven is the only facial hair style that is consistent day after day.
Remember: We are talking about an air-tight seal – not just a close fit. If anything gets through the seal, the situation is unsafe.
Fit Test Process
OMY conducts Fit Tests at your site – ensuring compliance and reducing downtime – and we can conduct one respirator test every 15 minutes.
When an employee enters the testing area, we will ask them to put on their respirator as they typically would, and then we place a hood over their heads.
The hood is then aspirated with saccharine or bittrex vapor, and if the employee is able to detect the sweet or bitter “taste” of the vapor, then we can conclude that the respirator mask is not properly fitted.
Because Fit Tests require employees to wear their own masks as they normally would, they are practical demonstrations of the employee’s level of protection at that moment. But as we mentioned above, people are always changing and the testing process needs to account for that.
Facial hair growth is the most common change that can affect Fit Test results, but it’s not the only one.
Situations that Require a Re-Test
Employees and employers need to be vigilant for changes that could potentially affect the ability of the respirator mask to create an air-tight seal. These changes can include (but aren’t limited to):
- Facial scarring, dental changes, cosmetic surgery
- Obvious changes in body weight
- Medical conditions that interfere with face-to-facepiece seal or valve function
- Corrective glasses and protective goggles
- Other personal protective equipment
If any of these changes occurs after the initial Fit Test, a re-test might be required to maintain employee safety and company compliance.
Fit Test Recordkeeping
Recordkeeping is a large part of maintaining OSHA compliance.
Safety managers are required to establish and retain written information regarding medical evaluations, fit testing, and the respirator program.
Storing these records helps to facilitate employee involvement in the respirator program, which, in turn, ensures that no one is skipped or overlooked while keeping employees actively engaged and committed to safety.
Maintaining these records will also assist in auditing the adequacy of the program and provide a record of compliance determinations by OSHA, which will be beneficial during inspections.
Additionally, accurate Fit Test records will include the detailed information for each employee including name/identification, type of Fit Test performed, and the specific make, model, style and size of the respirator tested.
If you have employees that need Respirator Clearances and Fit Tests, contact us today to discuss how we can meet your OSHA-mandated testing needs.
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