Review your medical evaluation of staffers who will wear respirators
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May 1, 2019
OSHA is reminding employers that a medical evaluation of each employee is required if that worker needs to ever wear a respirator on the job.
“Respirators can make breathing more difficult and not everyone is able to wear a respirator,” says OSHA information found on its website (see links in Resources). Some conditions can prevent an employee from using a respirator, including “heart conditions, lung disease, and psychological conditions like claustrophobia.”
The medical evaluation, which starts with a mandatory set of questions outlined by OSHA, must occur before the employee uses a respirator or is fit-tested. OSHA has a form for employees to fill out that is available for download online but will accept another form as long as all the questions are answered and given to the physician or other licensed healthcare professional (PLHCP) conducting the evaluation.
Don’t expect to see the answers. “The medical questionnaire and examinations must be administered confidentially during the employee’s normal working hours or at a time and place convenient to the employee and in a manner that ensures that he or she understands its content. The employer must not review the employee’s responses, and the questionnaire must be provided directly to the PLHCP.”
The mandatory questions can be found in OSHA’s standards on respiratory protection, in Appendix C to Section 1910.134 of the regulation.
Here’s what you can expect from the written recommendation you’ll receive from that PLHCP once the medical evaluation is completed, according to information from EHS Daily Advisor, a partner publication to Environment of Care Leader (see link below):
The written recommendation
After the PLHCP has completed the medical evaluation, both the employee and the employer should receive a written copy of the PLHCP’s conclusions. The employee’s copy may include additional information—for example, evidence of other health problems that were found during the evaluation—but the employer’s copy must include only:
- Any limitations on respirator use related to the employee’s medical condition or related to the workplace conditions in which the respirator will be used, including whether the employee is medically able to use the respirator
- The need, if any, for follow-up medical evaluations
- A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation.
Some workers may be found medically unable to wear negative-pressure respirators, which create a higher physiological burden than positive-pressure types, but medically able to wear less-demanding positive-pressure types of respirators. If this happens, the employer must provide a powered air-purifying (positive-pressure or pressure-demand) respirator. The employee can be reevaluated later for his or her fitness to wear negative-pressure respirators; if the employee is found fit, the employer is no longer required to provide the positive-pressure respirator.
A worker’s physical condition can change, and workplace conditions can, too. You may need to reevaluate a worker’s medical fitness to wear a respirator if:
- The employee reports medical signs or symptoms that are related to the ability to use a respirator (such as difficulty breathing).
- A PLHCP, a supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated.
- Information from the respiratory protection program, including observations made during fit-testing and program evaluation, indicates that employee reevaluation is needed.
- A change occurs in workplace conditions (such as physical work effort, protective clothing, or temperature) that might cause a substantial increase in the physiological burden placed on an employee.
Other OSHA information
In other information available on OSHA’s website, employers must specifically provide the following to the PLHCP on how the employee is going to use the respirator at work:
- the type and weight of the respirator;
- how long and how often the employee will be wearing the respirator;
- how hard the employee will be working and how much effort will be involved;
- other protective clothing or equipment that will be worn during respirator use;
- temperature and humidity extremes at work; along with
- a copy of the OSHA Respiratory Protection Standard and the employer's written respiratory protection program.
“The physician or licensed healthcare professional needs this information to properly evaluate” an employee’s ability to use the respirator, says OSHA.