Facial Hair & Face Fit Testing
Published date: Monday, October 24, 2016
The Equality and Human Rights Commission has just published new
guidance on religion and belief in the workplace. It's a good
starting point if you need further information.
Unless facial hair is a mandatory requirement of an employee's
religion or faith, e.g. a Sikh's beard, you have every right to
impose a clean-shaven rule on male staff via a dress and appearance
policy. However, it must be consistently applied - you can't come
down hard on one breach yet turn a blind eye to another.
As a general rule, you are perfectly entitled to specify the
standards of dress, appearance and personal hygiene in your
workplace and dismiss those employees who unreasonably fail, or
routinely refuse, to comply with your stated requirements. However,
any such standards, or rules, that you seek to impose must always
- appropriate to the role performed by an employee.
- consistently applied and enforced (you can't come down hard on
one employee's breach yet ignore another's); and
Health and safety legislation requires that employers must
protect the health, safety and welfare at work of all their
employees, as far as is reasonably practicable; it also states that
employees have a duty to take care of their own health and safety
and that of others who may be affected by their actions at
Employees must co-operate with employers and co-workers and
comply with reasonable requests made by them, to help everyone meet
their legal requirements.
Where RPE has been identified as a control measure, for any
task, it is important that the RPE is adequate and suitable.
To ensure that the selected RPE provides adequate protection for
individual wearers, the Approved Codes of Practice supporting the
Control of Substances Hazardous to Health Regulations and the
Control of Asbestos Regulations stipulate that tight-fitting RPE
must be 'fit tested'.
This helps to ensure that inadequately fitting face pieces are
not used. Ill-fitting face pieces can create inward leakages of
Individual face fit tests are required to ensure that the
appropriate RPE is available.
The tests require individuals to be clean shaven as this affects
the seal of the mask to the face and its ability to perform
Once individuals have had their face fit test, they must ensure
that whenever the task that they are doing requires the use of a
close fitting mask, they are clean shaven so that the mask performs
If a member of staff is found wearing a mask and is not clean
shaven, for their own safety they will be stopped from working
until they have shaved.
In accordance with Health and Safety legislation and guidance,
provision has been made for those who for either religious or
medical reasons are unable to wear close fitting masks and we have
even extended this to those people who have had a substantial beard
for a number of years. This is done by way of powered hood
It is in all our interests to ensure that we comply with all
relevant Health and Safety Legislation and regulations.
Your fit test doesn't last forever - after your initial fit test
it is good practice to regularly repeat fit testing. 282/28 is not
prescriptive on the re-test period, although it guides those doing
licensed asbestos removal to re-test annually. The only
stipulations are that you should be re-tested when you 'lose or
gain weight', 'undergo substantial dental work' or 'develop any
facial changes. However, because it can be difficult to accurately
measure these changes, industry best practise is to re-test
regularly, usually at 2 year intervals, dependant on the risk of
exposure and frequency that RPE is worn.
The one question that nearly always comes up is in relation to
What do I do if I have an employee with facial hair?
Can I fit test them with facial hair and just see if they
The answer is very simple - close fitting RPE that must be fit
tested for cannot be worn with facial hair of more than 24 hour's
growth. That means clean shaven whenwornas well astested. You can't
just turn up for your fit test clean shaven, pass the fit test and
then decide next week you will wear it with a beard. You have to
wear your mask clean-shaven for it to be effective and to be
What can you do then if you have facial hair or persons working
with you have facial hair, and Respiratory Protection is
You have one of two choices.
First option you have is to change your or your employees job
scope. Find a job that doesn't require the use of RPE or engineer
something into the task that removes the requirement for
Second is to use a loose fitting powered air hood, a quick example
would be something like
this. Here the system protects the user by providing a
clean air flow into a loose fitting hood, rather than relying on a
seal to the face. We will cover in more detail the use of Powered
Air systems in our upcoming article.
The one thing that you absolutely cannot do is potentially
expose you or your staff to respiratory hazards.