There are some situations in which employees may want to use respirators even though respirator use is not required by the silica standard. If employees use respirators when respirator use is not required by the standard, does such respirator use count toward the 30-day trigger for medical surveillance?

No. The standard only requires employers to make medical surveillance available to employees who will be required by the silica standard to use a respirator for 30 or more days per year. See 29 C.F.R. § 1926.1153(h)(1)(i). See the Small Entity Compliance Guide for the Respiratory Protection Standard (https://www.osha.gov/Publications/3384small-entity-for-respiratory- protection-standard-rev.pdf) for additional information about respirator requirements.