OSHA weighs in on use of face coverings, including non-PPE, in the workplace
On June 10, 2020, OSHA issued a series of questions and answers regarding the use of face coverings in the workplace. The guidance, which also clarifies the difference between the various types of face coverings and offers recommendations as to their applicability in the workplace, can be found here.
Cloth face coverings
OSHA stated that cloth face coverings are those face coverings that are worn in public over the nose and mouth to contain the wearer’s potentially infectious respiratory droplets produced when an infected person coughs, sneezes or talks, and to limit the spread of COVID-19 to others. OSHA clarified that cloth face coverings are not considered personal protective equipment (PPE) and will not protect the wearer against airborne transmissible infectious agents due to their loose fit and lack of seal or inadequate filtration. OSHA further stated that cloth face coverings “may be used by almost any worker, although those who have trouble breathing or are otherwise unable to put on or remove a mask without assistance should not wear one.” Because cloth face coverings are not PPE, employers are not required to provide them to employees. If employees are using cloth face masks, OSHA underscored the importance of properly and regularly cleaning the cloth face masks.
Surgical face masks are used to protect workers against splashes and sprays (i.e., droplets) containing potentially infectious materials. In this capacity, surgical masks are considered PPE and must be provided at no cost to the employee. Surgical masks may also be worn to contain the wearer’s respiratory droplets; however, surgical masks will not protect the wearer against airborne transmissible infectious agents due to their loose fit and lack of seal or inadequate filtration. OSHA stated that surgical masks may be used by almost anyone.
Respirators (like N95 masks), on the other hand, are used to prevent workers from inhaling small particles, including airborne transmissible or aerosolized infectious agents. Respirators must be provided and used in accordance with OSHA’s Respiratory Protection standard. Employers requiring respirators must provide proper training, fit testing, availability of appropriate medical evaluations, and monitoring, cleaning, and oversight by a knowledgeable staff member. Further, if respirators are necessary to protect workers, employers must have a respiratory protection program.
Additional OSHA recommendations
OSHA reminded employers that the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act, requires employers to furnish their workers a place of employment that is free from recognized hazards that are causing or are likely to cause death or serious physical harm. Control measures may include a combination of engineering and administrative controls, safe work practices such as social distancing, and PPE. However, employers may choose to ensure that cloth face coverings are worn as a feasible means of abatement in a control plan designed to address hazards from COVID-19. Employers may choose to use cloth face coverings as a means of source control where the risk of transmission cannot be controlled through engineering or administrative controls, including social distancing.
OSHA further stated that it generally recommends that employers encourage workers to wear face coverings at work. Face coverings are intended to prevent wearers who have COVID-19 without knowing it (i.e., those who are asymptomatic or pre-symptomatic) from spreading potentially infectious respiratory droplets to others. This is known as source control. Nevertheless, wearing face masks is not a substitute for practicing other control measures, such as social distancing.
OSHA clarified that there may be specific circumstances present at the worksite where the wearing of a cloth face coverings presents or exacerbates a hazard. For example, cloth face coverings could 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. Workers may also need to use PPE (for example, an N95 respirator) that is incompatible with the use of a cloth face covering.
OSHA stated that where cloth face coverings are not appropriate in the work environment or while performing certain job tasks (for example, because they could exacerbate heat illness or become contaminated), employers can provide PPE, such as face shields and/or surgical masks, instead of encouraging workers to wear cloth face coverings. Like cloth face coverings, surgical masks and face shields can help contain the wearer’s potentially infectious respiratory droplets and can help limit spread of COVID-19 to others. OSHA reminds employers that cloth face coverings cannot be used in place of respirators when respirators are otherwise required.