OSHA Releases FAQs about Face Coverings

As businesses begin to reopen and establish safety plans to ensure workers are safe from illness as they perform their daily duties, (See PrUA’s Preparedness and Response Plan Template) many states and local municipalities as well as some businesses are requiring face coverings to be worn upon entrance of the workplace. See a full list of which states are requiring or recommending the usage of face coverings here. The term “face covering” however, is quite broad and there has been confusion as to what types of coverings are acceptable and effective at protecting the spread of COVID-19.

On June 10th, OSHA issued guidance in the form of Frequently Asked Questions to clarify the difference between cloth face coverings, surgical masks, and respirators, and the implications for wearing face coverings in the workplace.

Key take-aways from this guidance are as follows:

What is the Difference Between the Different Types of Face Coverings, and Which is Encouraged?
Cloth Face Coverings
• OSHA confirms that cloth facemasks are worn for the purpose of containing the wearer’s potentially infectious respiratory droplets produced during a cough, sneeze, etc. Cloth facemasks do not protect the wearer against airborne transmissible agents due to their loose fit, lack of sealing around the face, and inadequate filtration.

• Cloth face masks are not considered personal protective equipment (PPE) by OSHA. In some instances, where the face mask may remain damp from breathing for extended periods of time or collect infectious material from the work environment, cloth facemasks may even pose a safety threat to the wearer’s health.

• OSHA advises employers to provide face shields or surgical masks instead of cloth face coverings for the reasons stated above.
If a cloth face covering is worn, OSHA recommends washing the mask following these guidelines from CDC.

Surgical Masks

• According to OSHA’s guidance, surgical masks are used to protect workers against splashes and sprays containing potentially infectious materials, including respiratory droplets. In this capacity, surgical masks are considered PPE.

• However, they are not considered PPE for protecting the wearer from smaller sized airborne transmissible agents due to their loose fit and inadequate filtration. Like cloth face coverings, they do contain the wearers respiratory droplets.

• Unlike the two above listed face coverings, respirators are considered PPE as they prevent the wearer from inhaling small particles, including airborne transmissible or aerosolized infectious agents.

• It is important to note, that any employer who requires employees to wear respirators must provide proper training, fit testing, availability of appropriate medical evaluations and monitoring, cleaning, and oversight by a knowledgeable staff member.

Filtering Facepiece Respirators
• Filtering Facepiece Respirators (FFRs) are also known as Dust Masks.

• Any employer who allows employees to voluntarily use FFRs must provide a copy of Appendix D in OSHA’s Respiratory Protection standard (29 CFR 1910.134) and have the employee sign an Acknowledgement form.

Are Employers Required to Provide Face Coverings to Workers?
Keep in mind that some state and local orders require employers to provide their workers with face coverings in the workplace. Be sure to check with your area’s requirements first.

• OSHA’s existing PPE standards do not require that employers provide cloth face masks specifically. Since they are not PPE, they don’t fall under OSHA’s standard (29 CFR 1910.132), that requires employers to provide any necessary PPE (e.g., gloves, respirators, safety glasses, etc. at no-cost to workers.

• OSHA’s General Duty Clause, Section 5(a)(1), requires that employers provide employees with a “workplace free from recognized hazards likely to cause death or serious physical harm”.

• The Center for Disease Control and Prevention (CDC) recommendations state that employers should encourage workers to wear appropriate face coverings at work.

• It is important to understand that facemasks of any kind do not substitute the necessity of social distancing.

• OSHA released their FAQs to provide clarification regarding how face coverings fall under their regulations and provide recommendation for employers to provide a safe workplace for their employees.

For additional information on OSHA requirements, please contact PRINTING United Alliance’s Government Affairs Department at govtaffairs@sgia.org.