OSHA Issues New FAQs Regarding Face Coverings Amidst Employees’ Return to the Workplace

On June 10, 2020, the Occupational Safety and Health Administration (OSHA) published a series of frequently asked questions and answers (FAQs) regarding the recommended use of surgical masks, cloth face coverings, and respirators in the workplace in the wake of ongoing health concerns arising from the continued spread of COVID-19. The new guidelines recognize that as many workers begin to return to their places of employment throughout the United States, some may be wearing masks in the workplace for the first time. The FAQs embody the most recent guidance from OSHA addressing protective measures for the workplace during the coronavirus pandemic.

At the outset, OSHA’s new FAQs define the differences among various types of face coverings, as follows:

Cloth Face Coverings

OSHA emphasizes that “cloth face coverings” include items made from garments, scarves, or other fabrics that help contain the wearer’s potentially infectious respiratory droplets in order to limit the spread of COVID-19. In contrast to surgical masks and respirators, cloth face coverings are not considered personal protective equipment (PPE) and are not appropriate substitutes for PPE such as respirators including N95 respirators or medical face masks. According to the new guidelines, cloth face coverings will not protect the wearer against airborne transmissible infectious agents because of their loose fit and the lack of a seal or inadequate filtration. While there are limitations to cloth face coverings, they may be used by almost any worker, except those who have trouble breathing or are otherwise unable to put on or remove a mask without assistance.

Surgical Masks

OSHA cautions that not all devices that look like surgical masks are actually medical-grade masks or cleared to be used as a medical device by the FDA. Because the primary function of an actual surgical mask is to protect workers against splashes, sprays, and droplets that may contain potentially infectious materials, OSHA considers surgical masks to be PPE. OSHA therefore reminds employers that under OSHA’s PPE standard (29 CFR 1910.132), employers must provide any necessary PPE at no cost to workers. Therefore, if surgical masks “are being used only as source control — not to protect workers” against droplets containing potentially infectious materials — then OSHA’s PPE standards do not require employers to provide them to workers. OSHA also explains that surgical masks alone will not protect the wearer against airborne transmissible infectious agents for reasons similar to the limitations of a cloth face covering. OSHA further recommends that surgical masks should be disposed of after use.

Respirators

OSHA explains that respirators are used to prevent workers from inhaling small particles, including airborne transmissible or aerosolized infectious agents. Use of respirators in the workplace must comport with OSHA’s Respiratory Protection standard (29 CFR 1910.134). The use of a respirator requires proper training, fit testing, availability of appropriate medical evaluations and monitoring, cleaning, and oversight by a knowledgeable staff member. OSHA further instructs that when respirators are necessary to protect workers, the employer must have a respiratory protection program compliant with OSHA’s standard. Under the new guidance, however, workers are at liberty to use “filtering facepiece respirators” (FFRs) if approved by their employer. If an employer does allow the voluntary employee use of FFRs, then the employer must provide its employees with the reference materials contained at Appendix D of OSHA’s Respiratory Protection Standard.

Specific Worksite Hazards

OSHA’s new FAQs provide further guidance to employers for the use of face coverings in regard to the specific types of respiratory hazards and circumstances that may be encountered at the workplace, particularly if wearing cloth face coverings presents or exacerbates a hazard. For example, cloth face coverings may become contaminated with chemicals used in the work environment, causing workers to inhale the chemicals that collect on the face covering. Over the duration of a work shift, cloth face coverings might also become damp (from workers breathing) or collect infectious material from the work environment (e.g., droplets of other peoples’ infectious respiratory secretions). Workers may also need to use PPE that is incompatible with the use of a cloth face covering (e.g., an N95 filtering facepiece respirator). Employers may decide to use a combination of engineering controls, administrative controls, as well as safe work practices such as social distancing and cloth face coverings (when actual PPE is not required for the particular working conditions).

When respirators are necessary in a particular workplace, employers should not use surgical masks or cloth face coverings as a substitute. OSHA reminds employers that it has issued temporary guidance regarding enforcement discretion around the use of respirators, including extending the use or reuse of certain respirators, and/or using respirators that have been certified under the standards of other countries or jurisdictions.

In light of OSHA’s latest FAQs, it is critical that employers understand the meaningful differences among face coverings and carefully evaluate the appropriateness of cloth face coverings for the particular conditions that are present in their worksites.

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