Introduction To OSHA Required Medical Evaluations For Workers Who Use Respirators
The use of respirators in the workplace is carefully regulated, and medical evaluations are integral to the process.
Respirators are often a critical component to a safe and healthy workplace. More importantly, the proper use of respirators is key to preventing cancer, lung disease, and even death. Although many workers might be inclined to consider the use of a respirator as something anyone can do, in reality, the use of a respirator involves regulated obligations by both the employer and the employee. In the United States, the federal Occupational Safety and Health Administration (OSHA) and state OSHA agencies provide employers with regulated respiratory protection standards. OSHA also requires all employers to provide medical evaluations to workers who are required to wear respirators at no cost to the employee. Employers who offer respirators without following the regulations set out by OSHA are at risk of being out of compliance and subject to penalty.
Respirators Are Not For Everyone
Respirators may cause breathing difficulty, and prior medical conditions including those related to heart conditions, lung disease or psychological issues may prevent some employees from using one. It is the employer’s responsibility to provide a licensed healthcare professional (HCP) to determine whether or not a worker is medically able to wear a respirator to perform their job effectively.
All employers must provide their employees with the OHSA Respirator Medical Evaluation Questionnaire to help determine any pre-existing medical conditions that may prevent an employee from wearing a respirator. The questionnaire must be provided to the employee in a manner that ensures they understand its content and purpose. The employee is required to complete the questionnaire to the best of their ability. All answers are confidential and are not shared with the employer. The HCP will then use the completed questionnaire to evaluate the suitability of the worker for wearing the equipment. Evaluations can be done by a review of the questionnaire alone, as part of an in-person medical assessment, or in conjunction with a follow-up in-person medical assessment. In some cases, the in-person medical evaluation may be used by the HCP to complete the questionnaire itself. Questionnaire completion, medical examinations, and any follow-up assessments or tests will take place during the course of regular working hours.
Employers will also provide the HCP with information about the particular respirator and how it will be used by the employee, including:
- Technical specifications of the respirator
- Frequency and duration of use
- Nature of the work performed
- Working conditions including temperature and humidity.
- Documentation that includes the company’s respiratory protection program and a copy of the OSHA Respiratory Protection Standard
Employers are also responsible for the cost of any follow-up medical examinations and associated tests. All medical evaluations must take place before the employee is fit-tested for a respirator. (Learn more in Why Fit Testing Is Important For Workers Wearing Personal Protective Equipment)
Once the questionnaire is reviewed by the HCP, and any necessary medical examinations are concluded, the employer and employee will be provided with a written recommendation that includes the following:
• A verdict as to whether or not the employee can wear a respirator
• An outline of any necessary follow-up evaluations
• A statement that the HCP has provided the employee with a written copy of the recommendation.
The inclusion of any confidential medical information about the employee’s health is prohibited.
Note that in some situations, more evaluations may be required. Re-evaluation by an HCP is required when there is a change in the employee’s medical condition or work environment. This will happen when:
- The employee reports symptoms of a medical condition
- A re-assessment is requested by an HCP, supervisor, or OHS administrator
- There are changes to other protective clothing or equipment
- There are changes to workplace conditions that affect the nature of the work or work environment
Training And Retraining
OSHA requires employers to provide workers who wear respirators with both initial and annual training. After training, workers are responsible for having a sound understanding of respirator use, maintenance, storage, any equipment limitations, malfunction procedures, removal and use of seals, medical symptoms that may prevent usage, and general knowledge of the OSHA respiratory protection regulations. It is important to note that OHSA standards vary depending on whether the worn respirator is for:
- Mandatory use (including emergency use)
- Voluntary use – dust mask
- Voluntary use – other than a dusk mask
Employers and employees must be knowledgeable about these categories and how they are applied to the equipment used in their workplace. Specific details are provided in the OSHA Standard 1910.134 Summary Sheet.
When all other engineered controls have been exhausted, respirators provide a last line of defense against a threatening external environment. Both employers and employees have a responsibility to be familiar with OSHA regulations and to make sure that respirators are used correctly. Medical evaluations are an integral part of the process, ensuring that those who are required to wear respirators are medically able to do so.