Understand options for respirator medical evaluations

Date Posted: 11/01/2021

Respirators can make breathing difficult, and some health issues such as heart conditions or lung disease could prevent an employee from safely using a respirator. Employees must therefore have a medical evaluation before they can use (or be fit-tested for) a respirator.

The 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. You may either use the questionnaire in Appendix C to 1910.134, or have the PLHCP perform an exam that obtains the same information as the questionnaire.

Questions and exams

In some cases, the PLHCP can approve an employee’s use of the respirator based solely on the questionnaire, without any medical examinations or tests.

If you have the worker complete the questionnaire, you may not look at or review the answers. The worker sends the completed questionnaire directly to the PLHCP, who determines if the worker answered “yes” to any of questions 1 through 8 in Section 2, Part A. If so, the PLHCP will let you know that the worker needs to come in for a follow-up medical examination.

If the employee needs an examination (or if you skip the questionnaire and simply schedule an exam), the PLHCP determines what, if any, medical tests must be done (such as a pulmonary function test or x-ray) before approving the employee’s use of a respirator.

The PLHCP will also determine the frequency of any evaluations or examinations. Although OSHA does not require annual evaluations, follow-up examinations are required under certain conditions outlined at §1910.134(e)(7), such as a PLHCP’s recommendation.

You must provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP. In addition, you must provide the PLHCP with the supplemental information outlined at §1910.134(e)(5), such as the type of respirator, the duration and frequency of use, and other required information.

If an employee does not qualify to wear a negative pressure respirator, ask the PLHCP if the employee can use a powered air-purifying respirator (PAPR). A letter of interpretation dated October 21, 2004, noted that if the PLHCP determines that an employee could wear a PAPR, then the employer must provide one. If the employee cannot wear a PAPR either, you cannot assign the employee to a position that would require wearing a respirator.

How Safety Management Suite Can Help

If any employees use respirators, you need a written respiratory protection plan. To help you quickly create and maintain your plan, check out the Plans & Policies tool in the J. J. Keller® SAFETY MANAGEMENT SUITE. You’ll find a template for a respiratory protection plan along with many other written plan outlines.

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