By now, everyone is either resigned to them or tired of them. The “them” is filtering facepieces, masks, scarves, neck gaiters, respirators, and other face coverings. Such coverings over the nose and mouth are the most common symbol of the world’s response to the COVID-19 pandemic. However, for the leaders of restoration and cleaning companies, there is a much bigger question about such face coverings that needs to be addressed; are they considered personal protective equipment (PPE)?

Serious Ramifications

Many cleaning and restoration companies have policies in place that require employees to wear different types of respirators (filtering face pieces, half face, full face, etc.) to protect them from the hazards of smoke and soot, black water, mold, spraying of antimicrobial chemicals, and other respiratory hazards typically encountered in the restoration world. These organizations understand the seriousness of the process of protecting their workers. Such companies typically have a written respiratory protection program which includes a hazard assessment, training requirements, medical evaluation of the person who has to wear a respirator, and fit testing. The emphasis of all of these precautionary steps is to keep the restoration worker from inhaling dangerous amounts of hazardous materials. Throwing a respirator at a new team member without going through this detailed process is considered to be a serious violation by Occupational Safety and Health Administration (OSHA) inspectors.

In the early part of 2020, the emergence of a deadly pandemic elicited a number of reactions that are still rippling through the restoration industry today. As the pandemic progressed, shortages of critical equipment for the restoration industry quickly developed. This included disposable suits and respirators typically used for fire, water, and mold restoration projects.

At the same time as the shortages were becoming a reality, the government mandated shut downs and mask wearing by the public. The impetus for the mask requirements was that experts from the Centers for Disease Control and Prevention (CDC) stated wearing a face covering helps prevent the spread of the SARS CoV-2 virus. As a result, OSHA strongly encouraged (or required, if the OSHA state plan has a pandemic emergency rule in place1) that employers provide masks to their employees as part of their COVID protection program at work. 

Clarity or More Confusion?

Since encouragement for masks for employees at work was coming from OSHA, questions quickly arose about whether the face coverings were designed to protect the individual worker or for some other purpose. In other words, were COVID-19 face coverings at work actually personal protective equipment? OSHA tried to address this critical question through a number of their pandemic-related publications. In their document entitled OSHA COVID-19 Frequently Asked Questions, the workplace safety agency offered some explanatory information about the masks being worn in response to the pandemic. They noted face coverings are “simple barriers to help prevent your respiratory droplets or aerosols from reaching others”. That Q&A document was blunt in stating “the main function of wearing the face covering is to protect those around you, in case you are infected but not showing symptoms”. 

In essence, OSHA was confirming COVID masks are not PPE — personal protective equipment; they are really CPE — community protective equipment. In another document on the OSHA website entitled OSHA Fact Sheet - Respiratory Infection Control: Respirators Versus Surgical Masks, the workplace safety agency explained in greater detail why any face covering short of a NIOSH-certified respirator, including hospital grade surgical masks, do not offer substantial protection from the virus for the worker wearing a mask:

Surgical masks are not designed or certified to prevent the inhalation of small airborne contaminants. These particles are not visible to the naked eye but may still be capable of causing infection. Surgical masks are not designed to seal tightly against the user’s face. During inhalation, much of the potentially contaminated air can pass through gaps between the face and the surgical mask and not be pulled through the filter material of the mask.

Despite the common sense from OSHA in explaining the difference between the face coverings and respirators, the CDC was offering somewhat contradictory information at the same time. Despite numerous studies showing that the primary benefit of individuals wearing face coverings over the nose and mouth at work was that they reduced the spray of droplets, the CDC made statements like this:

Although not their primary value, studies also show that face coverings can reduce wearers' risk of infection in certain circumstances, depending upon the face covering.

Of course, that statement from the CDC makes sense if the face covering is a filtering face piece designed to block microscopic contaminants. Early in the pandemic, individuals were wearing N-95, N-99, and even N-100 filtering face pieces like those typically used for mold remediation projects, as those types of protective equipment were available. However, as OSHA noted in their fact sheet, anything less than a properly fitted filtering face piece would probably not offer much protection from the virus to the wearer.

PPE or Not PPE?

Once the CDC put out the general statement about some face coverings reducing wearers risk of infection, a logical follow-up question was not far behind. In fact, the occupational safety agency fielded that type of question so many times it quickly was added to their publication OSHA COVID-19 Frequently Asked Questions. That document summarizes the inquiries as follows:

Since the CDC has determined that some cloth face coverings may both serve as source control and provide some personal protection to the wearer, will OSHA consider them to be personal protective equipment under 29 CFR 1910.132?

The clear answer to that question from OSHA was an emphatic "no". Specifically, their answer summarized some of the CDC information and then explained why face coverings would not be considered as personal protective equipment.

The recent CDC scientific brief shows that some cloth face coverings have the potential to provide personal protective benefits. However, the CDC also noted that additional "research is needed to expand the evidence base for the protective effect of cloth masks… At this time, OSHA does not think enough information is available to determine whether a particular cloth face covering provides sufficient protection from the hazard of COVID-19 to be personal protective equipment under OSHA's standard (29 CFR 1910.132). OSHA has typically considered protective equipment designed and constructed to meet a recognized consensus standard to meet the requirements of its PPE standards.”

PPE? No. Recommended Anyway? Yes.

OSHA’s decision that COVID masks are not personal protective equipment is important for the cleaning and restoration industry. The answer by OSHA confirms companies responding to the pandemic by having workers wear face coverings does not require inclusion of COVID masks into a respiratory protection program. 

Despite the fact that OSHA is not treating face coverings for COVID protection as PPE, the workplace regulatory agency is still a big proponent of their use. Much of their advisory information related to their national emphasis program on COVID violations notes that even without an emergency standard specific to the pandemic, OSHA can write citations for companies under the general duty clause if companies bring workers back without requiring the use of face coverings. The details of using masks were laid out in the guidance publication OSHA Protecting Workers: Guidance on Mitigating and Preventing the Spread of COVID-19 in the Workplace 1/29/21.

• You should wear a face covering even if you do not feel sick. This is because people with COVID-19 who never develop symptoms (asymptomatic) and those who are not yet showing symptoms (pre-symptomatic) can still spread the virus to other people.
   
• It is especially important to wear a face covering when you are unable to stay at least 6 feet apart from others since COVID-19 spreads mainly among people who are in close contact with one another. But wearing a face covering does not eliminate the need for physical distancing or other control measures (e.g., handwashing).
   
• It is important to wear a face covering and remain physically distant from coworkers and customers even if you have been vaccinated because it is not known at this time how vaccination affects transmissibility.

A Final Precaution

Whether it is masks as community protective equipment or respirators as personal protective equipment, cleaning and restoration contractors cannot get complacent. Until the pandemic is officially determined to be ended, face coverings in the workplace, particularly workplaces with significant interaction with the public, will be the norm. 

However, workers who need protection from hazards like soot, mold, or sewage, are not adequately protected just because they are wearing a COVID mask. Any potential exposure to hazardous materials mandates the use of respiratory protection of a higher caliber than that posed by COVID-style face coverings. The essential workers of the cleaning and restoration industry deserve nothing less.

End note:

1. For example, the document entitled COVID-19 Workplace Requirements for All Employers SUMMARY OF MIOSHA EMERGENCY RULES put out by the Michigan Occupational Safety and Health Administration states clearly: 

• The employer shall: Provide non-medical grade face coverings to their employees.