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The rules seem otherwise silent on the matter, but I would rule that it's an outlier because it requires spending an action, and it gives you a bonus to the inhaled poison saving throw as a result, because you're attempting to avoid inhaling the poison.
To me, everyone will subconsciously hold their breath if they are aware of being thrust into a situation where breathing isn't feasible (such as jumping into water). The above situation is about pre-emptively avoiding it, and as such is why the "action for a bonus" clause is in place.
The rules for swimming are equally vague and only really relevant underwater, unless you have to spend an action to hold your breath and if you don't, and you critically fail a swim check you immediately begin drowning.
The rules seem to be vague in many instances, e.g. holding and not holding your breath while paralyzed.
Considering various monster ability like Engulf or Swallow whole, which all require you to hold your breath, I think the above is an outlier as else you would be reduced to just one action per turn by having to hold your breath while already slowed 1.
It could also be a remnant of the playtest where there was an action to hold your breath. You only had to do it once, so it wasn't like Slowed 1, and doing so started the countdown on your air.
I believe it may have given you a larger supply of air that if I recall was pretty much what the default is now, so Paizo may have done away with that as extraneous realism. Except sometimes, like w/ the inhaled poisons example, one wants to explicitly hold their breath.
I suppose the question might be, "When can't you hold, or have begun holding, your breath?"
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Similarly, can we completely close our eyes, not just avert them?
Having run a lot of Medusa encounters, my ruling is "yes, and it isn't an action, but you need to do it at the start of your turn and and maintain it for the entire round." So no attacking and then shutting your eyes at the end of your turn. Combat isn't as sequential as rounds suggest, and if you look at the monster, you look at the monster.
So far you've reiterated my post, so I guess we're in agreement.
My question now:
Should we consider this an outlier to be ignored, or are you requiring your players to always spend an action to go from "breathing" to "holding your breath"?
Which are you using? A or B?
Cheers
In the specific case of inhalation poison, it seems like part of whatever action you took to notice the poison probably should have included the action cost to enter the holding your breath state. Is there anywhere in the rules that talks about how one becomes aware that the alchemical item just used created a cloud of poison and not any other effect? What is the DC for that?
As a house rule, I will probably say that transitioning into holding your breath is a free action as long as you are aware of the circumstances that necessitate it (so jumping or even falling into the sea should be free, because the alternative is that you immediately fall unconscious) otherwise it can be a part of the action to investigate or seek the circumstance requiring it, but if you don't notice it, you have spent the action and can't hold your breath.
I will need to think about it, but I might also add a 1 action version of "deep breath" that you have to take to get the full 5+con rounds of holding your breath, and otherwise you just get your con mod or 1+con mod if you don't take an action.
SO maybe a modified B?