What is the Respirator Medical Evaluation Questionnaire?
Respirator Medical Evaluation Questionnaire
In an earlier article, we addressed employer respiratory protection compliance requirements.
Throughout the United States, millions of workers in various industries are required to wear respirators. Respirators protect workers against insufficient oxygen environments, harmful dusts, fogs, smokes, mists, gases, vapors, and sprays. These hazards may cause cancer, lung impairment, diseases, or death.
Within OSHA’s 29 CFR 1910 General Industry regulations, under Subpart I- Personal Protective Equipment, resides the Respirary Protection Standard. Failure to comply with the OSHA Respiratory Protection Standard causes hundreds of deaths and thousands of illnesses annually.
Respirators, like all Personal Protective Equipment (PPE), require employers to ensure that employees not only use the PPE when required, but also provide training on criteria such as selection, proper donning and doffing, limitations of the PPE, inspection, cleaning, care, maintenance and storage. This should all be part of an effective employer PPE program.
Respiratory Protection Program
Once it is determined that respirators are required to be used by any employee, the employer is responsible to establish and maintain a written and effective respiratory protection program. Simply providing employees with respirators does meet compliance. How do you know if your employees are even able to wear a respirator? Some employees could have medical conditions which may affect their ability to wear a respirator. Using a respirator may also place a physiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee.
Medical Evaluation Procedures
Outlined in 1910.134(e) of the standard, employers must conduct medical evaluations for any employee required to wear a respirator by a physician or other licensed health care professional (PLHCP) to determine the employee’s ability to use one. This is a critical first step in an employer’s respiratory protection program that is commonly overlooked or misunderstood. Accordingly, the employer shall provide a medical evaluation to determine the employee's ability to use a respirator before the employee is fit tested or required to use the respirator in the worn.
This section outlines the delicate and confidential steps between the employee and PLHCP designated by the employer, and the use of the medical questionnaire:
- The employer shall identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.
- The employer must allow employees to answer this questionnaire during normal working hours, or at a time and place that is convenient to them.
- To maintain confidentiality, the employer or supervisor must not look at or review the employee’s answers, and the employer must tell the employee how to deliver or send the questionnaire to the health care professional who will review it.
- The medical questionnaire shall be administered in a manner that ensures that the employee understands its content.
- The employer shall provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP.
Medical Evaluation Questionnaire
The medical evaluation shall obtain the information requested by the questionnaire in Sections 1 and 2, Part A of Appendix C of this section.
The questionnaire is comprised of three main parts:
Part A Section 1- These are basic questions about yourself such as name, age, height, weight and your job title as well as contact info.
Part A Section 2- These are direct questions about your health and medical history. These obviously have direct impact on the employee’s ability to use a respirator.
Part B- These are questions about the overall nature of your job, specifically about conditions that require the use of a respirator such as your exposure to hazardous chemicals. It is also required of the employer to provide the designated licensed health care professional with supplemental information about the specific respirator the employee will be expected to use, along with other supporting factors.
Follow-up Medical Examination
The employer shall ensure that a follow-up medical examination is provided for an employee who gives a positive response to any question among questions 1 through 8 in Section 2, Part A of Appendix C, or whose initial medical examination demonstrates the need for a follow-up medical examination.
The follow-up medical examination shall include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.
In determining the employee's ability to use a respirator, the employer shall:
- Obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP. The recommendation shall provide only the following information:
- Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;
- The need, if any, for follow-up medical evaluations; and
- A statement that the PLHCP has provided the employee with a copy of the PLHCP's written recommendation.
Employers are encouraged to thoroughly review the OSHA Respiratory Protection Standard for more information. There is also a helpful OSHA Safety & Health Topic page.