U.S. Nuclear Regulatory Commission
OSHA Interpretation: Beards and Tight-Fitting Respirators
Title: OSHA Interpretation: Beards and Tight-Fitting
See the memorandum from R. L. Baer to R. R. Bellamy (and
others) dated November 2, 1984. OSHA's position is that no
bearded individual can achieve a consistent and
satisfactory fit when any tight-fitting respirator is worn.
Qualitative fit tests are highly subjective and errors with
this type of testing are generally high. HPPOS-094
contains a related topic.
In response to a request by Region III for technical
assistance in April 1983, OIE issued a memorandum providing
a broad technical basis to support the position for
prohibiting bearded users from wearing SCBA's. However, at
that time, a strict legal reading of NRC regulations led to
the conclusion that as long as no respirator protection
factor was assumed, a bearded individual could not be
prohibited from wearing a respirator.
The controversy over bearded fire brigade members at a
Region III facility continued and an OSHA written
interpretation on the subject surfaced (see enclosures to
memorandum). This OSHA interpretation is clear and direct
- OSHA's 29 CFR 1910.134 (e) (5) (i) prohibits facial hair
in the seal area. It is also OSHA's position that:
1. The employer is in violation of the standard if
employees are allowed to wear respirators over facial hair
at the sealing surface of the respirator.
2. Qualitative fit tests are highly subjective and the
errors associated with this type of testing are generally
3. Based on the information available, no bearded
individual can achieve a consistent and satisfactory fit
when any tight-fitting respirator is worn.
OIE recommends that if recalcitrant licensees continue to
allow bearded Emergency Response / fire brigade individuals
to wear tight-fitting respirators after being informed of
OSHA's interpretation and position, the region should refer
this nonradiological respiratory problem to the appropriate
OSHA authorities, in accordance with Chapter 1007 of the IE
Manual (Interfacing Activities Between Regional Offices and
By separate correspondence to RES, we plan to recommend RES
change the regulations to expressly forbid facial hair in
the seal area of tight-fitting respirators.
Regulatory references: 10 CFR 20.103, 10 CFR 20.1703
Subject codes: 8.10, 12.13