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Never Forget 343
Gave It All On
 9-11-2001

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OSHA Related Information

SCBA Fit Testing and Facial Hair


Lately we have seen a tremendous increase of firefighters participating in training using SCBA while they have "facial hair".  Wearing facial hair that interferes with facepiece seal violates the MN-OSHA 1910.134 and the use of SCBA. When asked if the firefighter is aware of the OSHA 1910.134 rules about using SCBA with facial hair, the common response is that “we have been told that if you can't see the hair sticking out from under the SCBA facepiece seal area it is ok”.  This is totally wrong!!
 
Remember 1910.134 Facepiece seal protection. 1910.134(g)(1) The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have: 1910.134(g)(1)(i)(A) Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or 1910.134(g)(1)(i)(B) Any condition that interferes with the face-to-facepiece seal or valve function.
 
Standard Interpretations
08/18/1986 - Hair where the mask edges meet the skin is not permitted for wearers of 30 minute positive pressure SCBA respirators.
11/26/1985 - Facial hair in the face sealing area is unacceptable.
10/11/1984 - Facial hair in the face sealing area is unacceptable.
01/18/1984 - Workers cannot sign a release so they can wear a respirator with a beard.

The standard states that the employer cannot permit respirators with tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face, or that interferes with valve function.

While the standard does not ban beards per se, it does require employers to ensure that bearded employees who are required to wear tight-fitting facepieces trim their beards so that they do not interfere with the sealing surface of the respirator or are not so large that they could interfere with valve function.


On November 1, 1998, the Minnesota State Colleges and Universities implemented a policy requiring all participants of Minnesota State Colleges and Universities training programs utilizing Self-Contained Breathing Apparatus to be fit-tested and to meet the requirements of the Federal OSHA Respiratory Standard 1910.134 as adopted by the Minnesota Department of Labor. This policy requires all participants of Fire Fighter training, Live Fire Training, and courses that includes the use of SCBA, to be “clean shaven” and fit-tested into the SCBA face piece. Since that time, the Minnesota State Colleges and Universities has taught a large number of fit testing classes.

Since implementing that policy, the fire service has embraced the concept as a positive step toward improving fire fighter safety. Although we have seen disagreement with the concept of fit testing diminish over time, we still see confusion and encounter fire fighters wanting to participate in training and certification testing with beards and/or no fit testing documentation.

We can site court cases that support the requirements for fit testing; we can justify our policy with protection against liabilities; but the most logical and meaningful justification is IT’S THE RIGHT THING TO DO. It’s the right thing to do, not for our program, but FOR YOUR PERSONAL SAFETY! All the reputable research ever done on face piece seals clearly states that you cannot obtain an adequate face piece seal with facial hair in the area of the face piece seal. Seriously degrading of the seal area can even take place on a one-day growth (stubble) of facial hair.
 
With onset of WMD and all of the toxic gases that we know are present in smoke and in hazardous materials incidents, the question remains, why does our fire service leaders allow anyone to operate in an SCBA with a beard?  For that matter why would you as a firefighter wish to gamble with your life? The risks of exposure to a life ending inhalants is just not acceptable. Fire fighters make enough personal sacrifices in the service. Why are we so reluctant to sacrifice facial hair for our own safety?
 
The decision to have a beard is yours, but you must be prepared for the consequences of our decisions. In my opinion wearing facial hair that interferes with SCBA facepiece seal just send a message to other of your attitude towards safety. If your department has a policy banning facial hair, and the fire department administration allows you to have a beard that interferes with the seal and use SCBA, no doubt there will be consequences for that decision.
 
If you come to an Minnesota State Colleges and Universities training session that requires the use of SCBA, the consequences will be that you will be given two options; shave or not participate.

The bottom line of this issue is that beyond the “it’s the right thing to do” justification is the reality that in our modern world, the Minnesota State Colleges and Universities simply cannot bear the liability of allowing you to knowingly violate federal and state standards. If you have a beard, please shave before coming to the class. If you do not plan to shave, please don’t come. If you come, we’ll be polite, we’ll be professional and treat you with complete respect; however, we will not allow you to participate.


Respiratory Protection. - 1910.134

1910.134(g)(1)
Facepiece seal protection.
1910.134(g)(1)(i)
The employer shall not permit respirators with tight-fitting facepieces to be worn by employees who have:
1910.134(g)(1)(i)(A)
Facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function; or
1910.134(g)(1)(i)(B)
Any condition that interferes with the face-to-facepiece seal or valve function.
1910.134(g)(1)(ii)
If an employee wears corrective glasses or goggles or other personal protective equipment, the employer shall ensure that such equipment is worn in a manner that does not interfere with the seal of the facepiece to the face of the user.
1910.134(g)(1)(iii)
For all tight-fitting respirators, the employer shall ensure that employees perform a user seal check each time they put on the respirator using the procedures in Appendix B-1 or procedures recommended by the respirator manufacturer that the employer demonstrates are as effective as those in Appendix B-1 of this section.



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Last Updated: May, 2005