January 1998, the revised Standard for Respiratory Protection was
signed as an OSHA regulation. The new federal standard replaces the
respiratory protection standards adopted by federal OSHA in 1971. It is
a revision and strengthening of the original standard that requires
employers to establish and maintain a respiratory protection program to
protect their respirator-wearing employees. Most importantly, the
standard specifically addresses the use of respirators in immediately
dangerous to life or health (IDLH) atmospheres, including interior
structural fire fighting. It also simplifies respirator requirements
for employers by deleting respirator requirements in other OSHA health
standards that duplicate those in this new standard. The standard
provides requirements for:
Respirator use (including the 2-in/2-out provisions)
Respirator cleaning, maintenance and repair
following summarizes the requirements of the respiratory protection
program and details the medical requirements. It is based on the text
of the regulation itself (29 C.F.R. 1910.134) and an OSHA
interpretation memorandum dated August 3, 1998. The employer must
develop a written respiratory protection program.
The program must include at least:
Procedures for selecting respirators.
Medical evaluation procedures of employees who will wear respirators.
Fit testing procedures for tight-fitting respirators (e.g. SCBA)
Procedures for the proper use of respirators.
and schedules for the cleaning, disinfecting, storing, inspecting,
repairing, discarding, and otherwise maintaining respirators.
Procedures to ensure adequate air quality, quantity, and flow of breathing air for atmosphere supplying respirators (e.g. SCBA).
Training of employees in the respiratory hazards to which they will potentially be exposed.
Training of employees in proper use of respirators, including donning, doffing, limitations in use, and their maintenance.
Procedures for regularly evaluating the effectiveness of the respiratory protection program.
employer must identify a physician or other licensed health care
professional (PLHCP) who will perform the medical evaluation. Licensed
health care professionals may only perform medical evaluations for
respirator use if it is within the scope of practice permitted by the
state’s licensing, registration, or certification agencies.
identified PLHCP must be provided with the following information prior
to making recommendations regarding an employee’s ability to use a
A copy of the employer’s written respiratory protection program.
The type and weight of the respirator to be used by the employee.
The duration and frequency of the respirator use.
The expected physical work effort.
Additional protective clothing and equipment to be worn with the respirator.
Temperature or humidity extremes that may be encountered.
A copy of the respiratory protection standard (29 C.F.R. 1910.134).
employer must provide a medical evaluation to all employees required to
use a respirator during their job. The employer must provide the
medical evaluation prior to the fit testing of the employee and before
the employee uses the respirator in the workplace. The medical
evaluation must be administered by the PLHCP in order to obtain the
information requested by the mandatory questionnaire in Sections 1 and
2, Part A of Appendix C of 29 C.F.R. 1910.134. Alternatively, the PLHCP
may provide an initial medical examination that obtains, at a minimum,
the same information requested by the questionnaire. The PLHCP may
request additional information if, in their professional judgment, the
information would assist in determining the employee’s ability to use
employer must ensure that a follow-up medical examination is provided
to all employees whose questionnaire or initial medical evaluation
indicates such a need. Follow-up medical examinations must include any
medical tests, consultations, or diagnostic procedures deemed necessary
by the PLHCP to make a final determination on an employee’s ability to
use a respirator. The employer must provide the employee with the
opportunity to discuss the questionnaire and medical evaluation results
with the PLHCP. The
questionnaire and medical evaluations must be administered
confidentially during the employee’s normal working hours or at a time
and place of convenience to the employee. The employer must pay for all
costs associated with the administration of the questionnaire and the
medical evaluation. These costs include related expenses incurred by
the employee during the medical evaluation, including travel costs. The
employer may not maintain a copy of the employee’s completed medical
evaluation questionnaire. The employer may only maintain the PLHCP’s
written recommendation on an employee’s ability to wear a respirator.
The completed questionnaire and the PLHCP’s finding and diagnosis are
strictly confidential and must not be maintained on file by the
employer. The sole exception to the above restriction is when the
employer maintains a health (medical) office that is administratively
separate from the employer’s central administration offices. The
handling of all medical documents by the health (medical) office must
be in strict accordance with the medical confidentiality provisions of
this regulation and the Americans with Disabilities Act. The employer
is required to obtain a written recommendation from the PLHCP regarding
an employee’s ability to use the respirator.
The PLHCP’s written recommendation must only include:
A statement of the employee’s ability to use the respirator.
limitations on respirator use related to either the medical condition
of the employee or the workplace conditions in which the respirator
will be used.
The need, if any, for follow-up medical evaluation of the employee.
A statement the PLHCP has provided the employee with a copy of his written recommendations.
The employer must provide additional medical evaluations in the following circumstances:
The employee reports medical signs or symptoms that are related to their ability to use a respirator.
PLHCP, supervisor, or the respiratory protection program administrator
informs the employer that an employee needs to be reevaluated.
from the respiratory protection program, including observations made
during fit testing, indicates and employee’s need for reevaluation.
A change in the workplace, or protective clothing, increase the physiological burden placed upon employee.