COVID-19: Mask Use and OSHA’s Role

By Mary Jones, Manager of Implementation & Delivery, and Veronica Marrero, Regulatory Compliance Specialist

The Data

COVID-19 appears to primarily be spread through respiratory droplets and aerosols. In non-medical or occupational environments, both the Centers for Disease Control and Prevention (CDC) and World Health Organization (WHO) recommend wearing cloth masks to prevent the spread of COVID-19. Additional research has shown that wearing facemasks helps to reduce community transmission of COVID-19, and respiratory viruses in general, especially when used in conjunction with other infection prevention practices such as social distancing and hand washing. According to the CDC, starting February 2, 2021 travel into, within, or out of the United States on planes, trains buses, or any other public transportation mode requires the use of face masks.

Choosing a Mask

When choosing a non-medical mask, the CDC recommends masks with 2 or more layers of breathable fabric. Recent studies have also shown masks made from tightly woven, high thread count, 100% cotton are good choices for non-medical use. Masks made from two outer layers of flexible, tightly woven, material and an inner filter layer can effectively filter 70-90% of particles and further protect both the wearer and community. Optimally, masks should fit closely to the face so there are no gaps between the mask and the wearer.

The CDC cautions against wearing masks with exhalation valves or masks made from materials hard to breathe through. Reusable masks should be washed daily or when visibly dirty (CDC, 2020). Click here to find the CDC’s recommendations on how to wash masks.

Additionally, the WHO outlines basic considerations on how to wear a mask, including washing your hands before and after removing your mask as well as before putting your mask on, and ensuring the mask covers your nose and mouth.

OSHA’s Guidance

In March of last year, the Occupational Safety and Health Administration (OSHA) issued guidance for workplaces on how to prepare for COVID-19. The guidance can be found here: Guidance on Preparing Workplaces for COVID-19. In this guidance, OSHA presents recommendations on the appropriate steps an employer could take in preventing the spread of COVID-19 including the use of face masks. Like the CDC and WHO, OSHA maintains that wearing a face mask prevents the spread of “respiratory secretions at the source (i.e., the person’s nose and mouth).”

Existing OSHA standards are outlined in the guidance as potential ways to protect workers from exposure to and infection with the virus since, to date, there is no specific OSHA standard for COVID-19. The existing regulations referenced are 29 CFR 1910 Subpart I (OSHA’s Personal Protective Equipment (PPE) regulation in the general industry), with an added reference to the respiratory protection standard applicable to workplaces where respirators are necessary (29 CFR 1910.134(c)), and 29 USC 654(a)(1) (a “General Duty Clause” that is intended to protect workers from recognized hazards that are causing or can cause serious harm). In its guidance, OSHA also goes through specific recommendations based on the group – whether your workplace falls within a very high, high, medium, or lower exposure risk.

On January 29, 2021, OSHA published a news release stating that it has issued updated guidance that offers stronger worker safety recommendations. Aside from affirming that employers should provide face coverings to workers (unless the work requires respirators), additional suggestions concerning face masks include when masks should be replaced, what to do in the event of other safety concerns from wearing a mask, and asserts that the need for physical distancing is still necessary when wearing a mask.

OSHA’s guidance is not an official workplace standard or regulation and therefore remains optional. Some states have taken it upon themselves to implement safety protection standards via executive orders to protect workers from COVID-19 in the workplace. These states include Oregon, Virginia, and more.

On March 12, 2021, OSHA introduced the National Emphasis Program (NEP), which is aimed at protecting employees from COVID-19 in high-hazard industries with focused enforcement on these companies.