U.S. Nuclear Regulatory Commission

OSHA Interpretation: Beards and Tight-Fitting Respirators

HPPOS-116 PDR-9111210272

Title: OSHA Interpretation: Beards and Tight-Fitting

Respirators

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

high.

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

OSHA).

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

Applicability: All