OSHA’s Respiratory Protection Standard tells us that identifying the need for respiratory protection is clearly the responsibility of the employer. While some may immediately turn to respirators when faced with airborne contaminant issues, in general, the choice to use respirators should remain the last resort when it comes to controlling airborne hazards in the workplace. Need training for employees who wear and maintain respirators? The Respiratory Protection Online Course trains employees to properly select, fit, and use repirators in the workplace.
Undoubtedly, we have all encountered dusty, nuisance environments both on and off the job. However, when there is a true concern for one’s health in the workplace due to fogs, mists, gases, smoke, and vapors, employers
are the ones held accountable for identifying, quantifying, and controlling such hazards.
OSHA prefers that employers remove the sources of hazards or implement engineering controls (i.e., ventilation systems) before resorting to personal protective equipment such as respirators.
So, what if after doing due diligence and assessing the situation, an employer arrives at the decision to mandate the use of respirators in the workplace? Well, then the employer must implement a written
respiratory protection program that follows applicable OSHA regulations, specifically OSHA’s Respiratory Protection Standard at 29 CFR 1910.134.
One crucial part of the Respiratory Standard is “medical evaluation.” This article will focus on one of the fundamental components of the standard: medical evaluation.
Respirator Medical Evaluation – The Questionnaire
Because the use of a respirator is likely to exert some sort of physiological strain on the wearer, he or she must first be evaluated by a physician or other licensed healthcare professional. The evaluation shall take place PRIOR TO the employee wearing a respirator on the job. To reiterate: The medical evaluation must come first,
the employee is fit-tested on the equipment.
When it comes to the logistics of the medical evaluation, the employer is responsible for covering the cost, which means the employee shall not be held liable for payment.
In addition, the evaluation itself must be offered during the employee’s normal working hours and at a location convenient for the employee.
One of the primary tools the physician or other licensed healthcare professional will use during the medical evaluation is something called the medical questionnaire. OSHA has included a sample questionnaire in Appendi
x C to the Standard. While employers do not have to use this particular questionnaire, OSHA has stipulated that use of this or a similar questionnaire is mandatory
The questionnaire is divided into different parts and sections and focuses primarily on the employee’s overall medical status, health history, past exposures, and conditions of the work environment. Some of the other topics the questionnaire addresses are the type of respirator(s) the employee has been assigned and whether he/she has worn a respirator in the past.
It also asks about additional roles and responsibilities outside the realm of the job title. For instance, does the employee participate on a HAZMAT team? Is he/she involved in any security-related efforts? Ultimately, the physician will need to determine if the employee is able to safely perform all job duties while wearing a respirator; meaning that his/her health is not negatively impacted.
Medical Evaluation – The Medical Professional’s Opinion
The physician or other licensed medical professional administering the exam is responsible for reviewing the employee’s responses. Based upon how the employee answered certain questions, the medical professional may require a follow-up exam. During the follow-up, the physician may choose to run certain tests or diagnostic procedures that will further assist in making a final decision as to whether the employee is medically cleared to wear a respirator on the job.
To assist the physician with the medical evaluation, the employer/employee must provide the medical professional with specific information concerning respirator use. Among the required information is the type and weight of respirator to be worn, the duration and frequency of use, and
any other personal protective equipment that will be used. In addition, the employer is required to provide the medical profession with a copy of the facility’s written respiratory protection program and a copy of the standard.
Medical Evaluation – Passing Medical Information On to the Employer
Hopefully, you get the idea that quite a bit of information is gathered during the medical evaluation stage. Along those same lines, OSHA is very specific about the scope of medical-related information that may be passed onto the employer. Due to privacy laws aimed at the healthcare industry, there are restrictions on the type of information that can pass from the medical professional’s hands to the employer’s. As this relates to respiratory protection, OSHA requires that employers obtain a written recommendation regarding the employee’s ability to use a respirator.
According to OSHA law, the medical professional’s recommendation may only provide information concerning limitations on respirator use. Those limitations may include things related to an individual medical condition and/or conditions present in the workplace. After taking many factors into consideration, the physician must arrive at a decision as to whether the employee is medically cleared to wear a respirator.
In addition, if there is a need for any follow-up medical evaluations, then that too must be documented. Lastly, the physician’s recommendation must include a statement that he/she has given the employee a copy of his/her written recommendation concerning respirator use.
So how long must the medical evaluation process go on? Well, if the employee’s job duties happen to change and he/she is no longer required to wear a respirator, then the medical evaluations may be discontinued at that time. Should an employee wish to receive a follow-up medical evaluation because there are symptoms related to respirator use, he/she shall be permitted to obtain one through the employer. If medical professionals, program administrators, or supervisors recommend a medical follow-up, then they are authorized to do so. If workplace conditions change that may adversely impact the employee’s health, then a reevaluation should be performed. Lastly, if there are any other observations made with respect to respirator use, even during fit testing, then a follow-up needs to take place.
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