The Occupational Safety and Health Administration (OSHA) (29 CFR 1910.134) requires a respirator fit test to confirm the fit of any respirator that forms a tight seal on the wear’s face before it is to be used in the workplace.
What is a respirator fit test?
A fit test is a test protocol conducted to verify that a respirator is both comfortable and correctly fits the user. Fit testing uses a test agent, either qualitatively detected by the wearer’s sense of taste, smell, or involuntary cough (irritant smoke) or quantitatively measured by an instrument, to verify the respirator’s fit.
Medical Evaluations for Respirator Usage
Wearing a respirator can put an extra burden on the body. People with underlying medical conditions may put themselves at risk if they work while wearing one. So the Occupational Safety and Health Administration (OSHA) requires medical evaluation before any employee can even be fit-tested for — let alone wear — a respirator.
If respirators aren’t required in your workplace but employees wear them voluntarily, OSHA says you still have to perform a medical evaluation. The sole exception is if the only type of respirator voluntarily worn is a filtering facepiece respirator, though 3M still highly recommends evaluations in those circumstances.
The medical evaluation is a questionnaire located in Appendix C of the OSHA respiratory protection standard that the employee completes. A physician or licensed health care professional (PLHCP) must review it to assess whether:
- A follow-up exam with a physician is required for that worker.
- The worker is cleared for respirator use with no restrictions.
- The worker is cleared with restrictions. That may mean they can’t use a negative pressure respirator on the job but could consider a positive pressure respirator instead.
- The worker isn’t cleared for any respirator usage.
In order to complete the assessment, the PLHCP must know the type of respirator you plan to use, the nature of the work and the conditions in which the work will be done. OSHA regulations require that you provide time during normal working hours for employees to complete the questionnaire, at no cost to the workers.
Fast Facts About Medical Evaluations for Respirator Usage
Medical evaluations are a vital part of a respiratory protection program and are required by the U.S. Occupational Safety and Health Administration (OSHA). Here are some facts you should know about this part of your respiratory protection program.
Workers cannot be fit-tested until they obtain clearance on their medical evaluation.
Respirators can put extra stress on the wearer’s body and underlying medical conditions may make this risk worse. It’s critical to get confirmation that the wearer is physically capable of wearing the respirator, with a medical evaluation.
Medical evaluations are required even for voluntary respirator usage in the workplace.
The only exception is for voluntary use of disposable filtering facepiece respirators – in which case 3M still recommends having workers undergo the medical evaluation.
The standard medical evaluation is a questionnaire.
Many people are cleared based on their answers to the questionnaire alone and don’t require a physical visit to a doctor.
OSHA requires periodic re-evaluation of every worker.
However, OSHA doesn’t specify how often medical evaluations must be performed.
Certain hazards have special medical evaluation requirements.
For example, asbestos workers must complete a different questionnaire and have a pulmonary function test (PFT) prior to being fit-tested. Read the OSHA regulations regarding asbestos (link below). Several other substances have their own OSHA standards and/or special medical evaluation requirements. Check the summary (link below) to see if your workplace’s hazardous substance is one of them.
All completed questionnaires have to be reviewed and cleared by a physician or licensed health care professional (PLHCP).
The PLHCP can require a follow-up with a physician based on the information provided.
There are multiple levels of clearance on the medical evaluation.
Depending on the PLHCP’s findings, workers may be:
- Cleared with no restrictions, meaning they are clear to perform required work duties while wearing a respirator.
- Cleared with restrictions — for example, a worker may not be able to wear a negative pressure respirator but could be cleared to wear a positive pressure respirator.
- Not cleared for any respirator usage.
If a worker isn’t cleared to wear a negative pressure respirator, a positive pressure respirator may be a solution.
A positive pressure respirator can be a Powered Air Purifying Respirator (PAPR) or a Supplied Air Respirator (SAR). A PAPR relies on a battery and a motor to pull air through the filer into the breathing zone, and a Supplied Air Respirator uses an airline and a valve to deliver breathing quality air to the wearer. Neither of these respirators rely on the wearer’s lungs to pull air through the filtering device so they may be an option if a negative pressure respirator is not.
You can meet the medical evaluation requirement in multiple ways.
You can print the OSHA Respirator Medical Evaluation Questionnaire (link below) directly from OSHA’s website to be completed, reviewed and mailed to a PLHCP for clearance. Or have employees complete and submit an online questionnaire directly to a PLHCP for review. 3M offers an online evaluation (link below) that meets the OSHA criteria and can be submitted, reviewed and processed typically within hours. The 3M evaluation also allows you to track multiple employees’ clearance status.
Information provided in medical evaluations is confidential.
Workers must be able to complete the questionnaire confidentially. Employers will get a clearance letter, but not employee answers and information disclosed in the questionnaire.
Employers must retain records for the duration of a worker’s employment plus 30 years.
Read more (link below) about the OSHA regulations on medical evaluation record keeping; 1910.1020(d)(1)(i) contains this specific rule.
Employers must allow time during work for completion of medical evaluations.
In addition, they must be provided at no cost to employees.