As city facilities and businesses begin to reopen, the
question of whether to require people to wear a mask or allow it to be
voluntary becomes particularly important, as does the difference between
“respirators” and other cloth filter masks.
Because of the short supply of surgical masks and
high-efficiency respirators (N95 and higher), the CDC has recommended using
cloth masks as an alternative to allow for the short supply to go to medical
personnel and first responders. These cloth filter masks are not intended to
replace or be substituted for the other masks, but are the second best option
available to protect the general public.
Commonly asked questions about cloth masks, respirators, and
OSHA
Q1. What does OSHA consider to be a mask or a respirator,
and does this cover simple cloth or surgical masks?
A1. First, OSHA breaks down masks into two categories:
- Respirators:
A respirator is a device that protects employees from inhaling particles or
other dangerous substances. Typically, these are fitted closely to the wearer’s
face and do not allow air to flow between the sides of the mask and the user’s
nose and mouth. Facial hair is not permitted when respirators are required
because it prevents a tight seal from occurring. With these types of masks, any
air movement is required to pass through the filters. When respirators are
mandatory, then all of the OSHA Respiratory Standard requirements must be
followed. Granted, OSHA has made some temporary exceptions to fit testing and
extended use, but these are also just temporary.
- Personal
Protective Equipment (PPE): Loose-fitting masks which are not intended to
filter air are PPE. A surgical mask or the masks that individuals are making at
home in response to COVID-19 are not considered respirators because they do not
filter the air. These loose-fitting masks, however, are still subject to the
OSHA PPE Standard, which requires proper protection if necessary to prevent a
job related injury or impairment.
Q2. Is there a difference if an employer requires employees
to wear a loose-fitting face mask or merely permits employees to wear a
loose-fitting face mask?
A2. Yes – there are significant differences between
requiring employees to wear a mask and permitting an employee to wear a mask,
even if the employer provides the mask to the employees.
Under the OSHA PPE Standard, which applies to all PPE
including loose-fitting cloth face masks, if an employer requires employees to
wear PPE, the employer must perform a hazard assessment, consider other
alternative options to protect employees such as installing a barrier between
workers or workers and customers, identify and provide appropriate PPE for
employees, train employees in the use and care of PPE, clean and replace PPE as
needed, and create a plan that is periodically reviewed. If employees are
considered “medium risk” for COVID-19 exposure because, for example, they have
frequent contact with individuals within six feet, then using a mask may be
required. This decision is based on your own
hazard assessment of the job being
performed.
However, if the employer allows the employees to voluntarily
wear a loose-fitting mask, none of these rules apply. Even if the employer pays
for the masks and provides them to employees, it can still be a voluntary
program. The employer should tell the employees, preferably in writing, that
the masks are not required and that wearing one is voluntary on the part of the
employee.
Q3. What is the actual difference between respirators
identified in the OSHA standard and all the masks and homemade masks that the
CDC is recommending?
A3. First it is important to understand what a cloth filter
mask can and cannot do.
The primary purpose of a cloth face mask is really to limit
the individual from spreading the COVID-19 virus to other people and nearby
surfaces by containing the individual’s coughs and sneezes within the mask.
That is not to say that these do not also provide a basic level of protection
to the wearer if exposed to an individual who has or may have COVID-19, but
that is not their primary function.
These cloth face masks do not function like conventional
respirators because they are not tight fitting, do not prevent leakage, nor are
they designed to filter air. The cloth filter masks, whether commercially
purchased or made at home, do not require any type of medical evaluation or fit
testing to make sure they work for the individual wearer.
To add to this confusion, some of the terminology used in
the OSHA standard can be confusing. A
basic paper dust mask is considered a respirator because it is tight fitting
and by design also filters air.
Q4. But I thought that cloth filter masks are considered an
administrative control and not PPE?
A4. That is partially correct. If you look at OSHA’s
hierarchy of controls, at the base is PPE and the next step in the hierarchy is
administrative. When reading the
description of administrative control, it would appear as though cloth filter
masks could be viewed more as an administrative control because of how they are
being used to help protect the workforce.
But many administrative controls also involve other aspects of the
hierarchy of controls, in this case PPE. Again, this falls back to your hazard
assessment conclusions. If your hazard assessment does not indicate that masks
are needed but you mandate the use of these anyway you will, in all likelihood,
fall under OSHA obligations and will need to comply with those training
requirements. That is one reason some businesses have made wearing cloth filter
masks a voluntary option but are strongly encouraging their employees to wear
them.
Q5. OSHA recommends extended use and only basic cleaning of
a respirator, while you can and should launder cloth filter masks regularly.
Why is that?
A5. Regular respirators have a lot of components. Any
excessive cleaning can damage the straps, the molded seals around the edge of
the respirator etc., which in turn can negatively impact the air filtering
capabilities of the respirator to form a tight seal. That is why you cannot
have facial hair if wearing a respirator with few exceptions. But these still
require some very basic cleaning, disinfecting, and storage practices which
should be followed as outlined in your respiratory protection program.
Cloth filter masks, by contrast, do not have many of these
components and by design are not tight fitting, so washing these will not
create any deformation or negative consequences. Quite the opposite applies
here. The wearer may have unknowingly contacted the COVID-19 virus at some
point in time during the day — proper cleaning removes the contaminant.
There are several very good YouTube videos dealing with how
to properly clean cloth filter masks. In reality, many of these masks require
nothing more than a simple laundering. The key thought is to not just continue
to reuse a cloth mask without laundering or using another disinfecting option
as shown.
REMINDER: These types of face coverings supplement other
preventive measures, they are not intended as a substitute. They provide an
added layer of protection on top of social distancing, good personal hygiene,
and other precautions that could be taken.
Q6. I want to mandate the use of cloth filter masks for my
employees returning to work. Do I need to comply with all the OSHA requirements
concerning fit testing, medical screenings, etc.?
A6. The direct answer to your question is no. Cloth filter
masks do not fall into OSHA’s definition of what a respirator is. Therefore,
they do not have the same medical screening and fit testing requirements. There still is a level of training and
general information sharing which is outlined in the OSHA standard.
We all understand that the intent of cloth filter masks is
to really protect the general public more than just the wearer.
Recent studies
have shown that a significant portion of individuals with coronavirus lack
symptoms (“asymptomatic”) and that even those who eventually develop symptoms
(“pre-symptomatic”) can transmit the virus to others before showing symptoms.
This is why the CDC recommends wearing cloth face coverings in public settings,
at work, and during activities when social distancing measures are difficult to
maintain.
Most cloth filter masks and any homemade masks are not
regulated by the FDA. Remember the CDC has come up with these alternatives in
response to a shortage of available respirators and surgical cloth masks, but
these alternatives were never intended as a replacement if and when those other
forms of PPE are available. If you are requiring these as part of your return
to work program, they would then be considered an administrative control and as
such, it is reasonable to think that you will need to provide information on
the safe use, storage, cleaning, etc. of these masks that is part of the OSHA
standards.
As the employer, when using them as a form of administrative
control you would still have obligations
to ensure employees use them safely and understand that
these types of masks do not prevent particles from passing through any openings
in the mask that occur with or without any facial hair.
If you are purchasing commercially manufactured cloth filter
masks, make sure to read the labels. While the vast majority of these are not
designed to be “tight fitting,” some are being designed or advertised as such
and even have warning labels on the packaging as to who can and cannot wear
them without medical screenings.
Submitted by: Joel Muller, Field Loss Control Manager
