Medical Evaluation
3M Center for Respiratory Protection
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.
What’s Involved
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.
The Virtual Option
Online medical evaluations are a convenient way to fulfill this requirement, since employees can complete them without having to travel to see a physician (unless a follow-up is necessary). 3M offers an online medical evaluation that meets the OSHA criteria. It can be completed at work and processed typically within hours, providing fast notification of results and clearance letters from a PLHCP via fax or email.
Other Requirements
Some hazardous substances have additional requirements beyond the standard medical evaluation. For example, workers wearing respirators for exposure to asbestos must complete a separate questionnaire, as well as get a pulmonary function test (PFT) and periodic chest X-rays. Other substances may also trigger the need for PFTs and/or chest X-rays, or in-person annual exams.
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.
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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.
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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.
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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.
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OSHA requires periodic re-evaluation of every worker.
However, OSHA doesn’t specify how often medical evaluations must be performed.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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Employers must allow time during work for completion of medical evaluations.
In addition, they must be provided at no cost to employees.
FAQ
Since the initial evaluation depends on your workers providing complete and honest information, it’s crucial that they understand why the evaluation is required and take it seriously. Here are some questions they may have, along with information to help you answer them.
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Q: What is a medical evaluation?
A: The standard evaluation is a questionnaire. See the OSHA questionnaire (link below). A physical visit with a doctor isn’t necessary unless a PLHCP requires it based on responses to certain questions. Follow-up visits could include medical tests, consultations or diagnostic procedures.
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Q: Do employees have to pay for their medical evaluation?
A: No. The employer must cover the cost of the initial medical evaluation, in addition to the cost of any necessary follow-up visits.
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Q: When are medical evaluations required?
A: Before employees can be fit-tested for a respirator and use it on the job, they must get medical clearance indicating that they’re able to wear respiratory protection.
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Q: How do employees know if they’re cleared to wear a respirator?
A: The PLHCP who reviews the questionnaire and/or conducts the follow-up exam will provide both the worker and employer with a medical clearance letter stating:
- Whether the employee is cleared to wear the respirator.
- If so, whether there are restrictions.
- Whether a follow-up exam is needed.
The letter will not contain any confidential medical information about the employee.
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Q: What if a worker voluntarily wears respiratory protection?
A: Voluntary usage still requires medical evaluation. The only exception OSHA makes is for voluntary usage of filtering facepiece respirators. If that’s the only type of respirator your employee wears, and it’s voluntary, then you don’t need to perform a medical evaluation (although 3M still highly recommends it).
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Q: Why are medical evaluations required?
A: Wearing a respirator can put an extra burden on the body. Employees with certain medical conditions affecting the heart or lungs could risk injury or death if they wear a respirator on the job. The medical evaluation questionnaire helps identify at-risk employees who may need an in-person visit with a physician to determine their ability to safely wear a respirator while working. The questionnaire also helps identify other conditions that may affect workers’ ability to wear a respirator, such as claustrophobia and migraines.
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Q: What information does the employer provide to the PLHCP about the worker?
A: To assess the employee’s ability to use a respirator, the PLHCP needs you to provide information about how respirators are expected to be used in the workplace, including:
- The type and weight of the respirator.
- How long and how often the employee will likely wear the respirator.
- The physical demands of the work and amount of effort involved.
- What other protective clothing or equipment will also be worn during respirator use.
- Temperature and humidity extremes at work.
- A copy of both the OSHA Respiratory Protection Standard and your written respiratory program.
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Q: Does the employer see the completed questionnaire?
A: No. The employer isn’t allowed to review the responses, and must advise the employee where to send the questionnaire as well as provide the name of the PLHCP who will be reviewing it, in case the worker has questions.
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Q: When and why is a Pulmonary Function Test (PFT) required?
A: Some OSHA substance specific standards require diagnostic tests to monitor lung function. For example, workers wearing respirators for asbestos exposure must complete a different medical questionnaire to gain a deeper understanding of respiratory health. They also must complete an annual PFT as well as periodic chest X-rays, to monitor for asbestos related lung disease. PFTs and chest X-rays aren’t part of the standard medical evaluation for most workers.
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Q: What if employees want to use their own doctor?
A: If an employee chose to use his/her own doctor instead of the PLHCP designated by your company, the employee would be responsible for the cost of the evaluation and any associated medical tests.
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Q: What records need to be kept and by whom?
A: You must keep a copy of the medical clearance letter in the employee’s confidential medical file for the duration of employment plus 30 years, per OSHA.
Medical Evaluation Resources
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