Obligations and options for respirator medical evaluations

While it is true employers are obligated to provide medical evaluations to workers before they can use or be fit-tested for a respirator, the process has mechanisms to potentially reduce the burden and associated costs. Per the respirator standard, each employer must select a physician or other licensed healthcare professional (PLHCP), such as a registered nurse or physician's assistant, to perform the medical evaluation. Employee interaction with the PLHCP can take two different paths depending on how you design your respirator protection program.

Medical evaluation options

As a first option, the PLHCP would perform “an initial medical examination” during which they would obtain information about the employee’s medical history and current conditions. This first step can be more costly for the employer but is less cumbersome to the worker and can expedite the process by eliminating the questionnaire step (explained next).

As a second option, employers can have workers complete the medical evaluation questionnaire in §1910.134 Appendix C, which is then provided to the PLCHP for review. If you choose to start with the questionnaire, the PLHCP reviews the questionnaire and determines next steps. In some cases, the PLHCP can approve the employee’s use of the respirator based solely on the questionnaire, meaning you may not need to provide and pay for any follow-up medical examinations or tests. When it works out, this option allows you to meet your obligation through the lowest cost option. Note that, as specified in the questionnaire instructions, the employer may not look at or review the employee’s answers to the questionnaire. The worker is to send the completed questionnaire directly to the PLHCP.

After the medical evaluation

Whether you use the questionnaire or send the employee in for an initial medical examination, it is up the PLHCP to determine what, if any, medical tests (such as a pulmonary function test or x-ray) must be done before the employee can be approved to use a respirator. Unlike fit tests, OSHA doesn’t require annual medical evaluations, but the PLHCP might recommend future examinations. The PLHCP has the responsibility to determine the frequency of these future evaluations. Lastly, don’t forget, you must also “provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP” (§1910.134(e)(4)(ii)).

Beyond establishing a process for medical evaluations, employers have an obligation to provide the PLHCP other information, including:

• supplemental information about the workplace and job to be performed by the worker being evaluated (§1910.134(e)(5)).
• a copy of the written respiratory protection program, and
• a copy of the respiratory program section of OSHA standards.

Using the questionnaire can simplify the medical evaluation and potentially reduce costs, but certainly doesn’t eliminate the responsibility or expense for employers. The employee still has the right to discuss the information with a PLHCP, and medical tests could still be necessary. Conversely, using the initial medical exam can be most costly, but often proves faster. The key is picking that option that best suits each workplace and their employees.