A model equating the growth rate of tungsten fuzz on a plasma-exposed surface to the erosion rate of the fuzzy surface is developed to predict the likelihood of tungsten fuzz formation in the steady-state environment of toroidal confinement devices. To date this question has not been answered because the operational conditions in existing magnetic confinement machines do not necessarily replicate those expected in future fusion reactors (i.e. high-fluence operation, high temperature plasma-facing materials and edge plasma relatively free of condensable impurities). The model developed is validated by performing plasma exposure experiments at different incident ion energies (thereby varying the erosion rate) and measuring the resultant fuzz layer thickness. The results indicate that if the conditions exist for fuzz development in a steady-state plasma (surface temperature and energetic helium flux), then the erosion rate will determine the equilibrium thickness of the surface fuzz layer.