Personal Protective Equipment for Bearded Personnel – COVID-19

Date: June 11, 2020

Classification: Unclassified

Branch/Agency: RCMP

Issue: The Royal Canadian Mounted Police does not currently have approved tight-fitting respirators for use by bearded personnel in the performance of front-line duties and interactions with the public.

Proposed Response:

Officer safety, and the provision of dedicated and professional policing services, will remain key priorities for the Royal Canadian Mounted Police.

Background:

In relation to personal protective equipment (PPE) for RCMP personnel, at this time, there are no tight-fitting respirators that meet legislative and regulatory requirements, are suitable for a frontline policing environment, and can be worn by a person with a beard.

The RCMP, as a federal employer, is required to follow the requirements established in the Canadian Occupational Health and Safety Regulations (COSHR), particularly, Section 12.13 which identifies the requirement to provide respiratory protection to employees that appears on the National Institute of Occupational Health and Safety (NIOSH) Certified Equipment List and to ensure compliance with the requirements outlined in the CSA Standard Z94.4. To this end, respirator users must be clean shaven in order to wear a tight fitting respirator. No exemption to this regulation exist, though accommodations can be provided on a case-by-case basis under the Duty to Accommodate (see below).

The RCMP’s Occupational Health and Safety section evaluated a possible option that was submitted by the National Police Federation, but it was not on the NIOSH Certified Equipment List and therefore did not meet legal requirements. The RCMP remains open to new options and will continue to seek out adequate Personal Protective Equipment based on unique circumstances at any given time.

RCMP national direction was disseminated to RCMP personnel indicating that the facial hair provisions of the Uniform and Dress Manual were suspended in the context of the COVID-19 pandemic, due to the need to ensure front-line members can be properly protected with PPE. Instructions were also provided for members to seek exemptions on religious or health grounds, as necessary. Lastly, RCMP policy and the Duty to Accommodate those with exemptions were outlined, along with the fact that the various available respiratory PPE requires users to be cleanly shaven to ensure a proper seal for their protection.

Regular members with beards who require respirators to stay safe in the context of COVID-19 and require a workplace accommodation due to any prohibited ground of discrimination found in the Canadian Human Rights Act (CHRA), are accommodated on a case-by-case basis by ensuring their health and safety in a way that does not require them to shave (e.g. offered duties away from the front-line and other duties that may expose them to COVID-19 related calls for service.) Guidance has been provided on individual assessment of the need for accommodation.

Contacts:

Prepared by: Konrad Roberts, C&IP Strategic Policy, RCMP; 343-542-2628

Approved by: Brian Brennan, Deputy Commissioner, Contract and Indigenous Policing, RCMP; 613-843-4632

Date modified: