Respiratory Protection: Highlighting Medical Requirements

OSHA's revised Respiratory Protection Standard 29 CFR1910.134, introduced last April, is far more detailed and specific than the previous version. Designed by OSHA to protect the lives of respirator users, the revised standard is a lot more specific especially with regard to medical requirements. All employers, for example, who may require their employees to wear a respirator need to comply with the medical requirements of the Occupational Safety and Health Administration's (OSHA) Respiratory Protection Standard. All employees, on the other hand, who may be required to wear respirators must be medically cleared by a physician or other licensed health care professional.

Choose a licensed health care professional

Employers are required to identify a qualified physician or other licensed health care professional to perform a medical evaluation of each respirator user. A physician or other licensed health care professional (PLHCP) is defined by OSHA as an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide, or be delegated the responsibility to provide, some or all of the health care services required by paragraph (e) of 29 CFR 1910.134. Once the employer chooses a qualified PLHCP, it must provide him or her with the following documents to perform their assigned duties more efficiently:

A copy of OSHA's Respiratory Protection Standard 29 CFR 1910.134. This can be found on the Internet at www.osha-slc.gov/OshStd_data/1910_0134.html.

A copy of the organization's written Respiratory Protection Program.

The type and weight of the respirator to be worn by the employee.

The estimated frequency and amount of time the employee will be wearing a respirator.

The level of physical effort that the employee would be exerting while wearing the respirator.

The amount and weight of additional personal protective equipment (PPE) or clothing that the employee may be required to wear.

The temperature and humidity extremes that the employee may encounter.

Fill out a medical questionnaire

Before sending an employee to the company's PLHCP, the employee must fill out a medical questionnaire, which would be hand-delivered by the employee to the PLHCP. The medical questionnaire has been designed to identify medical conditions that might place the respirator user at risk for serious medical consequences. (A copy of the medical questionnaire can be downloaded from www.osha-slc.gov/OshStd_data/1910_0134.html). The language of the medical questionnaire may not be altered by the employer or the PLHCP. The PLHCP will determine whether or not Part B of the questionnaire needs to be administered to the employee. The PLHCP may alter the questions in Part B to provide the best care and evaluation to the employee. All medical evaluations and questionnaires are considered confidential and should be dealt with accordingly by the PLHCP. Employers must also inform employees that the PLHCP is available to discuss the results of their medical evaluations.

Once the questionnaire and medical evaluation are complete, the Respiratory Protection Standard requires employers to obtain a recommendation from the PLHCP about the employee's ability to use a respirator. The PLHCP's recommendation must be in writing and must include the following items:

a determination of whether or not the employee is medically fit to wear a respirator;

any limitations while using a respirator, related to the medical condition of the employee or to the working conditions;

the need, if any, for a follow-up medical evaluation;

a statement that the PLHCP has provided a copy of the written recommendation to the employee.