Respiratory Protection: Medical Evaluations
Who needs an initial medical evaluation
An initial medical evaluation is required for all employees who wear respirators. The only exception is for voluntary use of filtering facepiece respirators or FFRs (also known as disposable particulate respirators or dust masks). The evaluation must be conducted before the employee is fit tested or uses the respirator.
Purpose of the evaluation
Respirators can be heavy, difficult to breathe through, or otherwise place a burden on the worker’s health. A medical evaluation determines whether the employee is able to wear the respirator and perform the required work without endangering his or her health.
Conducting the initial evaluation
You can choose to do the initial evaluation by having the employees complete a questionnaire, which is then sent to a physician or other licensed healthcare professional (PLHCP) for evaluation, or by sending the employees directly to the PLHCP for a medical examination that obtains the same information as the questionnaire. The questionnaire is found in Appendix C of the Cal/OSHA respiratory protection regulation.
In some cases, the PLHCP may be able to determine that the employee can wear a respirator while performing his or her assigned job duties based on the responses to the questionnaire alone. In other cases, the PLHCP may need to conduct a follow-up examination. The contents of the follow-up examination are determined by the PLHCP.
If a questionnaire is used, it must be administered in such a way that the employee understands the contents. The employee must be provided with the opportunity to discuss the questions with the PLHCP, and only the PLHCP may review the answers so as to maintain confidentiality.
Both the questionnaire and the examination must be administered at no cost to the employee and during normal working hours or at a time and place convenient to the employee.
Finding a PLHCP to conduct the medical evaluation
If you already have an occupational health clinic that you use for work-related issues, contact the clinic to discuss medical evaluations. You can also use State Fund’s MEDFinder to locate a PLHCP near your facility. Even though workers’ compensation does not pay for these medical evaluations, this tool can help you with your search. If you choose to use the MEDfinder, the best place to start is by selecting the occupational medicine specialty. Although the PLHCP is not required to be a specialist in occupational medicine, these healthcare professionals are typically already familiar with Cal/OSHA regulations and factors that affect an employee’s ability to use a respirator. There are also vendors that provide medical evaluations using an online questionnaire.
Information that must be provided to the PLHCP
The following information must be provided to the PLHCP:
- The type and weight of the respirator to be used by the employee
- The duration and frequency of respirator use (including use for rescue and escape)
- The expected physical effort
- Additional protective clothing and equipment to be worn
- Temperature and humidity extremes that may be encountered
- A copy of the employer’s written respiratory protection program
- A copy of the Cal/OSHA respiratory protection regulation
Information that the PLHCP provides to the employer
The PLHCP provides the employer with the following information:
- Whether the employee is medically able to use the respirator
- Any limitations on respirator use
- A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation
- The need, if any, for a follow-up medical evaluation
In some cases, the PLHCP may determine that the employee cannot (for medical reasons) wear a negative pressure respirator but can wear a powered air-purifying respirator (PAPR). In such cases, the employer must provide a PAPR for the employee.
Additional medical evaluations
An annual medical evaluation is not required. However, once the initial medical determination has been made, additional medical evaluations are required in the following circumstances:
- The employee reports symptoms related to his or her ability to use a respirator
- The PLHCP, respiratory protection program administrator, or supervisor determines that a medical reevaluation is necessary
- Information from the respiratory protection program (such as observations made during fit testing or program evaluation) indicates a need for medical reevaluation
- A change occurs in workplace conditions (e.g., physical work effort, protective clothing, or temperature) that may substantially increase the physiological stress on the employee
Recordkeeping
Records of medical evaluations must be kept and made available to employees in accordance with Title 8, California Code of Regulations, §3204, Access to Employee Exposure and Medical Records.
Resources
The Cal/OSHA regulation for respiratory protection: www.dir.ca.gov/Title8/5144.html
All Cal/OSHA regulations: www.dir.ca.gov/samples/search/query.htm
State Fund’s MEDFinder: www.scif.com
The above evaluations and/or recommendations are for general guidance only and should not be relied
upon for legal compliance purposes. They are based solely on the information provided to us and relate
only to those conditions specifically discussed. We do not make any warranty, expressed or implied, that your workplace is safe or healthful or that it complies with all laws, regulations or standards.
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