Firstly apologies for the length of the post !!! It is clear to me that if a risk is controlled by RPE (Whether that be short-term or long term) that the employees who are expected to wear the masks (in this case) need to undergo face fit testing (completed by a competent person) and training etc. My query/question is, if following a full site wide dust sampling survey (COSHH assessment/dust level assessment) it shows that levels are significantly below the W.E.L. And therefore RPE is not required to control the risk, should the site provide or legally do they need to provide face fit testing to an employee who requests to still wear a mask? Legally we do not need to provide RPE for any tasks (Engineering controls now in place) so we could just remove them (clearly have a small amount kept of site to deal with any emergency spillages etc), but we have a large number of employees requesting that they still have the option to wear them. There is work we still need to do on and around communication to the workforce on the reason RPE is no longer required (LEV now in place) and show the findings of the survey to validate this, but just would like some advice/suggestion of question of face fit testing for occasion use.

Thank you for taking the time to post a reply Kate, the areas where we have the risk of spillages (Dry powders such as flour) we will continue to provide face fit testing and training for employees in this area. I guess a second question is if employees request RPE in areas where they are not required (highest readings are less the 5mg/m3) do we need to provide them? As if we do, then will need to provide face fit testing for these employees, which if some do want them but other don't will be difficult to manage. I would say we don't and need to manage this internal PR issue to explain why the RPE is not required. I am right in this assumption? Or is there a section is COSHH or PPE reg's that's states we do?

If RPE isn't required then you don't need to provide it. And if it isn't required but is used anyway outside of your requirements, then no need to fit test it. Although you would need to be able to explain if challenged (1) that RPE isn't required which is why you aren't fit testing and (2) why you are providing RPE that isn't required! One approach you could take is to provide a basic disposable dust mask that can be used if people want it, on the basis that it's provided for comfort and not for health and using it is entirely optional and not one of your COSHH control measures. However if people are asking for RPE you should ask why! Do they believe there is a risk that the assessment has failed to identify? Might they know something that you don't? This is where the requirement to consult workers about risk assessments comes in.

Suitable and sufficient for what? Normally the answer would be suitable and sufficient for protecting health by preventing inhalation. If the mask isn't meant to protect health as there is no health risk, there's nothing that it needs to be suitable and sufficient for. If it's genuinely not required, then it's not a control measure and it's only the things that are provided as control measures that you have to check, maintain etc. (Have a look at the text of COSHH.) So for example if you provided respirators for a fancy dress party, there's be no need to fit test them.

To back up Kate On one of my chemical plants - RPE was worn as the chemical didn't 'smell nice', levels well below the WEL and RPE not required in risk assessment. The chemical also had a high health risk and people liked to wear RPE as an additional 'safety blanket' In my opinion no need to fit test in these situations,

Does the fact that there could be exposure to flour, a known sensitiser, change the situation? LB