Do I need to use the OSHA questionnaire?’

Common questions about medical evaluations

When the U.S. Occupational Safety and Health Administration (OSHA) revoked the TB-specific respirator standard Dec. 31, 2003, hospitals began scrambling to make sure they comply with the General Industry Respiratory Protection Standard (1910.134).

One important aspect of that standard involves medical evaluation of employees to determine if they can wear a respirator. Craig Moulton, an OSHA industrial hygienist, answers some common questions about the requirements of the medical evaluation:

Question: Do you need to give employees the medical evaluation questionnaire (Appendix C) every year before their fit-testing?

Answer: An initial medical evaluation must be conducted for every employee who is required to wear a respirator, but it does not have to be administered annually.

There are four circumstances that trigger an additional medical evaluation:

  • An employee reports medical signs or symptoms that are related to the ability to use a respirator.
  • A physician or other licensed health care professional (PLHCP), supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated.
  • Information from the respiratory protection program, including observations made during fit-testing and program evaluation, indicates a need for employee reevaluation.
  • A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.

A brief discussion with employees at the time of fit-testing can determine whether any of these circumstances exist. Or you can create a shortened version of the questionnaire to ask about signs and symptoms or changes in the workplace conditions.

A PLHCP may recommend that some employees, such as those with asthma, undergo a medical evaluation each year.

Question: Is it OK to provide the questionnaire during the pre-placement exam for new employees?

Answer: Yes. The medical evaluation can be included in the pre-placement process, followed by fit-testing. The PLHCP would need to know the type of respirator the employee was assigned to use and the work environment (such as possible exposure to tuberculosis). The PLHCP must provide a written statement regarding the ability of the employee to use a respirator.

Question: What if current employees have been fit-tested but not provided the medical evaluation questionnaire?

Answer: All employees required to wear respirators must have a medical evaluation, so you will need to administer Appendix C or conduct physicals/medical exams before July 2, 2004. This would include current employees who have not satisfied the requirement for a medical evaluation.

Question: Can we use an alternate questionnaire that covers the respiratory system and exposures similarly to the Appendix C?

Answer: If you use an alternate questionnaire, you can add questions, but you must include the "mandatory" questions from Appendix C. The only way around Appendix C is to do physicals/medical exams, which would incorporate similar questions as in Appendix C.

Question: Can we implement 1910.134 by administering the questionnaire to each employee, along with a fit test and PPD, on their annual review date?

Answer: Yes, as long as everyone required to use a respirator has been covered by July 2. If they will wear a respirator and their annual review date falls beyond July 2, this year they will need the evaluation and fit-testing earlier. If the employee will not wear a respirator until after July 2, the evaluation and fit-testing can be delayed. They must comply with the standard before donning the respirator.

(Editor’s note: A summary of the major requirements of 1910.134 is available on-line at www.osha.gov/Training/major-req-RPS-1910_134.pdf.)