OSHA and CDC requirements for Respirators and Masks during Roofing Work

With the issues related to the COVID-19 virus, much attention and discussion has been focused on respirators and masks. Unfortunately, confusion has resulted regarding what is a respirator versus a mask and whether the Occupational Safety and Health Administration respiratory protection regulations are triggered by their use.

Information has circulated from a variety of sources about surgical masks, dust masks, masks you can make yourself, and the N-95 mask. In this list, only the N-95 mask meets the authoritative definition of a respirator. The National Institute for Occupational Safety and Health is responsible for testing and certifying masks before they enter the market to determine whether they meet the minimum construction, performance and respiratory protection standards to be sold and used as a respirator. NIOSH maintains a Certified Equipment List on its website where you can check for approved respirators by manufacturer, type and model number.

NIOSH defines a respirator as “a personal protective device that is worn on the face, covers at least the nose and mouth, and is used to reduce the wearer’s risk of inhaling hazardous airborne particles (including dust particles and infectious agents), gases or vapors.” There are two main types of respirators: air-purifying respirators like those described above and air-supplying respirators. An air-purifying respirator removes particles in the air by a cloth- or cotton-like filtering material and some also have filtering cartridges that remove certain harmful fumes, gases or vapors. An air-supplying respirator protects the user by supplying air from an uncontaminated source such as a self-contained tank or a remote, clean intake.

In contrast, according to NIOSH, a “surgical mask is a loose-fitting, disposable device that prevents the release of potential contaminants from the user into their immediate environment.” The U.S. Food and Drug Administration is charged with approving surgical masks for marketing by manufacturers; however, the FDA does not independently evaluate the filtering performance of surgical masks. NIOSH states particle collection efficiency of surgical masks is significantly lower than NIOSH-certified respirators. There also are surgical N-95 NIOSH-certified respirators designed for health care applications that are fluid-resistant and offer the enhanced respiratory protection of an N-95 filter.

Dust masks are included under OSHA’s regulatory definition of filtering facepiece respirators suitable for use in the workplace. A dust mask can be an N-95 filtering facepiece respirator, but not all dust masks are tested and approved by NIOSH. An N-95 respirator is a respiratory protective device designed to form a tighter seal around the nose and mouth to filter out airborne contaminants unlike surgical masks and some dust mask models. One significant obstacle to all respirator effectiveness is facial hair, which can obstruct the seal of the respirator against the skin and allow air to bypass the filtering medium. Additionally, according to OSHA, an N-95 filtering facepiece respirator is a disposable respirator that must be discarded after use or when it is damaged or soiled.

NIOSH rates respirators as N-95 if the respirator collects 95 percent of airborne particulate contaminants; an N-99 respirator filters 99 percent; and an N-100 filters at least 99.97 percent. N respirators are not resistant to oil, but respirators with similar filtering capabilities with P or R prefixes are somewhat resistant to oil or oilproof, respectively.

A NIOSH-tested, approved and certified respirator will be marked with the following information by the manufacturer:

Dust masks similar to the one pictured below may appear to be filtering facepiece respirators but have not been evaluated, approved and certified by NIOSH and are not suitable for employer-required respiratory protection of workers. Note that no required printed information regarding a NIOSH approval number appears on the dust mask.

Another type of air-purifying respirator is the half-mask filtering facepiece or elastomeric, tight-fitting respirator. It generally uses prefilters like an N-95, N-99 or N-100 to filter out airborne particulates and also is matched with various filtering cartridges to filter out gases, fumes or vapors that may be harmful if inhaled. A more protective version--the full facepiece respirator—offers similar filtering efficiency combined with full eye protection.

The role OSHA regulations play in respirator selection and use can get complicated. Generally, a roofing contractor has the duty to assess the workplace environment and tasks to determine whether workers will have an inhalation exposure to hazardous dusts, vapors, gases or mists. Then, engineering controls must be applied to eliminate or reduce the exposure.

Respirator use is required if those exposures cannot be brought to a level low enough to protect workers after application of engineering controls. OSHA rules require a written respiratory protection program be in place when an employer mandates respirator use by workers, including NIOSH-certified filtering facepiece respirators. Some key program elements include:

  • Respirator selection procedures
  • Medical evaluations of workers to determine whether they are physically able to wear a respirator without adverse health consequences
  • Fit-testing to ensure no contaminated air bypasses the filter elements
  • Procedures for the proper use of the respirators

The COVID-19 pandemic has required some loosening of OSHA enforcement of respiratory protection requirements because of shortages of N-95 respirators. OSHA has stated if extended use or reuse of N95 filtering facepiece respirators becomes necessary, the user may be allowed to extend use of or reuse a respirator as long as the respirator maintains its structural and functional integrity and the filter material is not physically damaged; soiled; or contaminated with blood, oil, paint or other material. An employer must have a written protocol that directs workers as to when—without regard to the extended use or reuse order—a respirator must be disposed of and not used further.

When roofers are exposed to hazardous gases, vapors, fumes, dusts and mists, OSHA‘s respiratory requirements are triggered including the use of, at a minimum, an N-95 NIOSH-certified filtering facepiece respirator. However, these scenarios aside, roofing workers fall into OSHA’s low to medium risk category of occupations for COVID-19 exposure—meaning required use of N-95 respirators is likely unwarranted. Shortages of N-95 respirators (and surgical masks) resulting from the pandemic have caused the Centers for Disease Control and Prevention to recommend wearing cloth face coverings in public settings where other social distancing measures are difficult to maintain—especially in areas of significant community-based transmission.

A person with COVID-19, who may not exhibit symptoms, can nonetheless spread it to others by exhalation of respiratory droplets. CDC recommends face coverings as a means of protecting others from the virus by containing these droplets. It is worth noting that cloth face coverings are not designated as NIOSH-approved respirators, so the OSHA respiratory regulations, which protect the wearer, are not triggered. This CDC recommendation may act to contain the virus and have application to roofing workplaces where N-95 respirator use is not deemed required by the employer, when N-95s are not available because of shortages, in public settings, or, more importantly, on roofing job sites where maintaining social distancing is difficult to maintain.


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