What is voluntary respirator use under OSHA 1910.134 Appendix D?

Short answer: Voluntary respirator use is when an employee wears a respirator even though exposures are below OSHA limits and the standard or employer does not require one. Under OSHA 29 CFR 1910.134(c)(2), the employer must still determine that wearing the respirator will not itself create a hazard and must give each voluntary user the advisory information in Appendix D. For voluntary N95 filtering facepieces the burden is light — Appendix D only — but voluntary elastomeric (reusable) respirators still require a medical evaluation and proper cleaning, storage, and maintenance.

Voluntary respirator use: OSHA 1910.134 Appendix D explained (2026 Guide)

Voluntary respirator use sits in a gray zone that catches many employers: a worker is below every OSHA exposure limit, no rule forces a respirator, yet the employee wants one for comfort or extra assurance. The controlling rule is OSHA 29 CFR 1910.134(c)(2), and it makes clear that even permissive, comfort-driven respirator use is not consequence-free for the employer. Before allowing voluntary use, the employer must determine that the respirator itself will not create a hazard, and must provide the user with the one-page advisory in Appendix D. You can stock the actual hardware from our respiratory protection range, but the paperwork and medical duties are what keep voluntary use compliant.

The single most-missed point is that voluntary respirator use is not one rule but two. A voluntary N95 filtering facepiece triggers almost nothing beyond Appendix D. A voluntary elastomeric half-mask or full-face respirator still triggers a medical evaluation and the cleaning, storage, and maintenance elements of a written program. This guide decodes 1910.134(c)(2) and Appendix D, lays out that N95-versus-elastomeric split in a table, and walks a worked example of building a compliant voluntary-use program.

Why this matters.
Treating all voluntary respirator use as a no-paperwork freebie is the error that draws citations. OSHA can cite an employer under 29 CFR 1910.134 for failing to provide Appendix D to voluntary users, and for failing to medically evaluate a worker who voluntarily wears an elastomeric respirator — even when the air is clean and no rule required the respirator in the first place. Because a tight-fitting reusable respirator adds breathing resistance and, in some workers, a cardiopulmonary load, the medical evaluation exists to confirm the respirator will not itself create a hazard, which is exactly the determination 1910.134(c)(2)(i) requires the employer to make.

Part 1 — What 'voluntary use' actually means

Voluntary respirator use is defined by what is absent: there is no overexposure and no mandate. Exposures are below OSHA permissible exposure limits, the respiratory protection standard does not require a respirator for the task, and the employer is not requiring one either. The worker simply wants a respirator for comfort or peace of mind, and the employer permits it. That is the entire trigger for 1910.134(c)(2).

Below the limit, not relied upon for compliance

The defining feature is that the respirator is not being used to keep the worker below an exposure limit — the air is already acceptable. Because of that, voluntary use is never counted toward compliance, and the assigned protection factors that govern required full-face respirator use do not apply. If a respirator is needed to control a real exposure, the use is required, not voluntary, and the full standard applies.

Common voluntary-use scenarios

Typical examples include a worker who wants a disposable respirator against a faint nuisance odor that is well below any limit, a maintenance employee who prefers a dust mask while sweeping, or a hobby woodworker reaching for a dust mask for woodworking on light sanding. In each case the employer should confirm the exposure truly is below the limit before classifying the use as voluntary.

Part 2 — The employer's two duties under 1910.134(c)(2)

Even when use is voluntary, 1910.134(c)(2)(i) imposes two baseline duties on the employer. First, determine that respirator use will not in itself create a hazard to the user. Second, provide each voluntary user with the information contained in Appendix D. These duties apply across every respirator type, including the lightest N95.

Duty one: confirm the respirator will not create a hazard

A respirator adds breathing resistance, can trap heat, and may strain some users medically. The employer must judge that wearing it is not itself hazardous to that worker. For a tight-fitting reusable respirator this judgment is formalized through a medical evaluation; for an N95 it is a more general determination. Our respirator medical evaluation requirements reference explains how that evaluation works.

Duty two: provide Appendix D

Appendix D is a short, mandatory advisory the employer must hand to every voluntary user. It is not optional even for a single disposable mask. Failing to provide it is the most common voluntary-use violation, because employers assume that an unrequired respirator carries no paperwork at all.

Part 3 — What Appendix D says

Appendix D — 'Information for Employees Using Respirators When Not Required Under the Standard' — is a one-page set of plain-language cautions. The employer must convey its content to voluntary users so they understand a respirator only helps if it is the right device, used correctly.

The five core messages

Appendix D tells voluntary users to: (1) read and follow all manufacturer instructions on use, maintenance, cleaning, and warnings; (2) understand the respirator can protect you only if it is used and maintained properly; (3) wear only a respirator that is NIOSH-certified for and capable of protecting against the contaminant present; (4) keep track of your respirator so you do not mistakenly use someone else's; and (5) never wear it into atmospheres that are more hazardous than it is designed for.

How to deliver it

The standard does not prescribe a single format. Employers commonly distribute the Appendix D text as a printed handout, an acknowledgment form, or a slide in onboarding, and keep a record that each voluntary user received it. Pairing it with a NIOSH-certified N95 respirator at issue is a clean way to document compliance.

Part 4 — The reduced-burden exception (and its limit)

OSHA wrote a deliberate carve-out so that handing out dust masks does not force a full respiratory-protection program. But the carve-out is narrow: it applies only to filtering facepieces. The moment the voluntary respirator is an elastomeric (reusable) device, more of the standard switches back on.

Filtering facepieces (N95): Appendix D only

For voluntary use of filtering facepiece respirators such as N95 dust masks, the employer is not required to include those users in a written respiratory-protection program and is not required to provide a medical evaluation. The only mandatory step is providing Appendix D. This is why a workplace can offer N95s during smoke events with minimal administrative load.

Elastomeric respirators: medical evaluation still required

For voluntary use of elastomeric half-mask or full-face respirators, the exception does not fully apply. The employer must still provide a medical evaluation and must establish those elements of a written program needed to ensure the respirator is cleaned, stored, and maintained so it does not create a hazard to the user. Appendix D still applies on top of this.

Part 5 — Voluntary use versus required use

The bright line is the exposure. If a respirator is being relied on to keep a worker safe from a real airborne hazard, the use is required and the entire 1910.134 program applies: a written program, medical evaluation, fit testing, training, and selection by assigned protection factor. Voluntary use is the opposite case — clean air, no mandate — and only the lighter duties attach.

What required use adds

Required use brings obligations voluntary use does not, including annual fit testing for tight-fitting respirators and respirator selection tied to the assigned protection factor. Our respirator fit testing guide covers the fit-test methods that required use demands and that voluntary N95 use does not.

Do not let voluntary use mask a real exposure

The most dangerous mistake is labeling use 'voluntary' to avoid the program when an exposure actually exists. If monitoring or a hazard assessment shows the worker could be overexposed, the respirator is required, and treating it as voluntary is a compliance and safety failure. When in doubt, assess the exposure first using the framework in OSHA 1910.132 PPE requirements.

Source: OSHA 29 CFR 1910.134(c)(2) and Appendix D. The elastomeric row carries the commonly-missed obligations.

Part 6 — Choosing respirators for voluntary use

Because voluntary use does not rely on the respirator for compliance, selection is driven by comfort, fit, and the worker's preference rather than an assigned protection factor. A valved 3M disposable respirator eases heat and breathing resistance during light tasks, and a 3M 1860S small N95 respirator suits workers who need a smaller facepiece. A reusable 3M 6000 Series half-mask respirator suits workers who want a longer-lived device, provided you remember the medical evaluation that reusable choice triggers. For light particulate filtering on a reusable facepiece, pair it with a NIOSH filter such as a 3M 2091 P100 respirator filter.

Part 7 — Recordkeeping and program hygiene

Voluntary use generates light but real records. Keep proof that each voluntary user received Appendix D, and for elastomeric voluntary users keep the medical-evaluation determination and a cleaning and storage procedure. Document that you confirmed exposures were below the limit so the 'voluntary' classification is defensible. These records are what an OSHA compliance officer asks for first, and they convert a vague good-faith practice into demonstrable compliance with 1910.134(c)(2).

Part 8 — Worked example: setting up a compliant voluntary-use program

Here is how a safety manager stands up a compliant voluntary respirator program for a facility where some workers want N95s for nuisance dust and a few want reusable half-masks, none of them overexposed:

1. Confirm the use is genuinely voluntary. Verify through monitoring or a documented hazard assessment that exposures are below OSHA limits and that no rule or employer policy requires a respirator. If an exposure exists, stop — the use is required, not voluntary, and the full standard applies. Document the below-limit finding.
2. Decide which device types you will permit. List the respirators you will allow. If you stay with NIOSH-certified N95 filtering facepieces, you keep the lightest burden. If you also permit reusable half-mask respirators, plan for the added medical-evaluation and cleaning duties.
3. Distribute Appendix D to every voluntary user. Give each voluntary user the Appendix D advisory and record receipt. Reinforce its five points: follow manufacturer instructions, use and maintain the respirator properly, wear only a NIOSH-certified device for the contaminant, do not share respirators, and never enter a more hazardous atmosphere than the respirator is rated for.
4. Add medical evaluation for the elastomeric users. For anyone voluntarily wearing an elastomeric half- or full-face respirator, provide a medical evaluation before use, following the process in our respirator medical evaluation requirements reference. Filtering-facepiece-only users do not need this step.
5. Write the limited maintenance procedure for reusables. For elastomeric voluntary users, document how respirators are cleaned, stored, and maintained so a reused mask cannot itself create a hazard — dirty filters, degraded straps, or fouled facepieces. Issue replacement filters such as a 3M 2091 P100 respirator filter on a defined schedule.
6. Keep the records and review annually. Retain the below-limit determination, Appendix D acknowledgments, and elastomeric medical evaluations. Re-check exposures if the process changes, since a new exposure can flip voluntary use into required use overnight.

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The same logic scales from a handful of voluntary N95 users to a mixed fleet of reusable respirators. Build your program against the controlling rule in our OSHA 29 CFR 1910.134 respiratory protection standard reference, and outfit voluntary users from the respiratory protection catalog.

Frequently asked questions

What is voluntary respirator use under OSHA?

Voluntary respirator use is when an employee wears a respirator even though exposures are below OSHA permissible exposure limits and neither the standard nor the employer requires one. It is governed by 29 CFR 1910.134(c)(2). Even though the air is acceptable, the employer must confirm the respirator will not create a hazard and must provide the user with Appendix D. Hardware is available in our respiratory protection range.

What is OSHA 1910.134 Appendix D?

Appendix D is a mandatory one-page advisory titled 'Information for Employees Using Respirators When Not Required Under the Standard.' The employer must give it to every voluntary respirator user. It explains that a respirator only protects when it is the right NIOSH-certified device, used and maintained correctly. See the full 1910.134 standard reference for context.

Do I need a medical evaluation for voluntary N95 use?

No. For voluntary use of an N95 or other filtering facepiece respirator, OSHA does not require a medical evaluation, and the user need not be in a written program. The only mandatory step is providing Appendix D. This light burden is what lets employers offer N95 respirators easily during dust or smoke events.

Do voluntary elastomeric respirator users need a medical evaluation?

Yes. The reduced-burden exception applies only to filtering facepieces. For voluntary use of an elastomeric half-mask or full-face respirator, the employer must still provide a medical evaluation and ensure the respirator is cleaned, stored, and maintained. Our medical evaluation requirements reference explains the process.

What is the difference between voluntary N95 and voluntary elastomeric obligations?

A voluntary N95 filtering facepiece requires only Appendix D — no medical evaluation and no written program. A voluntary elastomeric (reusable) respirator requires Appendix D plus a medical evaluation plus the cleaning, storage, and maintenance elements of a written program. The device material, not the wearer's intent, decides the obligations.

Why does an elastomeric respirator trigger more requirements than an N95?

A reusable elastomeric respirator is worn repeatedly and must be cleaned, stored, and maintained, and it places more breathing resistance and load on the user than a single-use mask. OSHA therefore keeps the medical evaluation and the maintenance elements in place even for voluntary use, to ensure the respirator does not itself become a hazard. A reusable full-face respirator carries the same voluntary-use duties as an elastomeric half-mask.

Does voluntary respirator use require fit testing?

No. Fit testing is a required-use obligation for tight-fitting respirators, not a voluntary-use one. Voluntary users are not fit tested under the standard, although a good fit still improves comfort and effectiveness. Our fit testing guide covers the methods required use demands.

Does voluntary use require a written respiratory protection program?

For voluntary N95 filtering facepiece use, no — those users need not be in a written program. For voluntary elastomeric use, the employer must establish the parts of a program needed for cleaning, storage, and maintenance, but not the full program required for required use. Required use, by contrast, demands a complete written program.

How should an employer deliver Appendix D?

OSHA does not mandate a format. Employers commonly distribute Appendix D as a printed handout, an acknowledgment form, or onboarding material, and keep a record that each voluntary user received it. Issuing it alongside a NIOSH-certified respirator such as a 3M 1860S N95 creates a clean compliance record.

Can an employer just hand out N95s without any paperwork?

Not entirely. Even for voluntary N95 use the employer must provide Appendix D and confirm the respirator will not create a hazard for the user. There is no medical evaluation or written program for N95 voluntary use, but Appendix D is mandatory. Skipping it is the most common voluntary-use citation.

What happens if a worker is actually overexposed?

Then the use is not voluntary — it is required, and the full 1910.134 program applies, including a written program, medical evaluation, fit testing, and selection by assigned protection factor. Labeling use 'voluntary' to avoid the program when an exposure exists is a compliance and safety failure. A silica task, for example, calls for a required silica dust respirator, not a voluntary one.

What must Appendix D tell employees?

Appendix D directs users to read and follow all manufacturer instructions, understand the respirator protects only when used and maintained properly, wear only a NIOSH-certified respirator suited to the contaminant, keep track of their own respirator so they do not use someone else's, and never enter an atmosphere more hazardous than the respirator is designed for. All five points must be conveyed to voluntary users.

Does the assigned protection factor matter for voluntary use?

No. Assigned protection factors govern respirator selection for required use, where the respirator is relied on to control a real exposure. In voluntary use the air is already below the limit, so the respirator is not relied on for compliance and the APF does not apply. APFs do govern full-face respirator selection in required-use settings.

Can a worker choose any respirator for voluntary use?

They should wear only a NIOSH-certified respirator appropriate for the contaminant present, as Appendix D requires, and never one rated for a different or lesser hazard. Within that limit, voluntary selection is driven by comfort and fit rather than an APF. For background on matching 3M respirators and filters to a task, see our 3M respiratory protection complete guide.

Is voluntary respirator use the same as PPE under 1910.132?

They overlap but are not identical. 1910.132 is the general PPE rule that frames hazard assessment, while 1910.134(c)(2) and Appendix D set the specific duties for permitting respirator use when not required. Use the hazard assessment under 1910.132 to confirm a respirator is truly voluntary before applying the Appendix D duties.

What records should we keep for voluntary respirator use?

Keep proof that each voluntary user received Appendix D, the determination that exposures are below the limit, and for elastomeric voluntary users the medical-evaluation result and a cleaning and maintenance procedure. These are the first records an OSHA officer requests, and they make the 'voluntary' classification defensible under 1910.134(c)(2).

Where can employers buy compliant respirators for voluntary use?

NIOSH-certified respirators for voluntary use are available across our respiratory protection catalog, including N95 filtering facepieces for the lightest burden and reusable half-mask respirators for workers who prefer a longer-lived device. Match the device type to the obligations it triggers before issuing it.

Further reading on this site

• OSHA 29 CFR 1910.134 respiratory protection standard — the controlling standard that defines voluntary use and Appendix D.
• Respirator medical evaluation requirements — the evaluation voluntary elastomeric users still must receive.
• Respirator fit testing guide — the fit-test step required use adds that voluntary N95 use does not.
• OSHA 1910.132 PPE requirements — the hazard-assessment framework for confirming exposures are below the limit.
• N95 respirators — NIOSH-certified filtering facepieces for the lightest voluntary-use burden.
• Half-mask respirators — reusable elastomerics that trigger the medical-evaluation duty.
• Disposable respirators — filtering facepieces for nuisance-level voluntary use.
• Respiratory protection — the full catalog across filtering facepiece and elastomeric respirators.