Many program administrators already know that OSHA does not require that medical evaluations be done annually, and many companies take full advantage of this. But all too often, we come across employees wearing respirators that were never medically evaluated and cleared by the PLHCP to wear in the workplace. Here is how this happens…
First, let’s get this out of the way – There is NO annual or periodic requirement for medical reevaluation. The standard lists four conditions that trigger medical reevaluation: an employee reports signs or symptoms related to the ability to wear a respirator; the PLHCP, administrator, or supervisor determines it is necessary; information from the respiratory protection program indicates a need for reevaluation or a change in workplace conditions substantially increases the physiological burden placed on the employee. (FR p.1219-1220)
I took this from OSHA’s Q&A on respirators (p. 22-23). But PLEASE, for the sake of worker safety, remember that OSHA requirements are the absolute minimum requirements. Therefore, we should seriously consider providing our workers with an annual evaluation (my professional opinion).
By doing medical evals each year, we may actually save ourselves an OSHA citation as well. I can not remember a year since I have been consulting (and doing many S&H audits each year) where we did not find multiple employers each year where employees were wearing respirators they had not been medically evaluated to wear. Let me explain…
Employee A works in Department X and, in doing so, is in the Respirator Program as he/she wears a half-mask Air-Purifying Respirator (APR). They are 100% compliant with this half-mask APR as they have a medical eval on file for the half-mask usage and have been fit-tested and trained each year for the half-mask. But one day, Employee A gets promoted to Department Y where they use full-face APRs and SCBAs for specialized tasks. The employee receives training and fit-testing on his/her new respirators but is NOT medically evaluated for these different types of respirators. We come along during an audit, and we see that they are being fit tested on makes, models, types, and styles that do not match their medical eval, which stated they “wear half-mask APR for less than 2hrs/day”. Now, they are wearing “full-face APR and SCBA up to 8-hrs/day”.
Without a doubt, this is a serious compliance risk; the risk to the employee(s) is more concerning. There is a distinct difference in the impact on an employee’s ability to wear a half-mask APR vs. a full-face APR and an SCBA, as well as the time differences in the new department. This should clarify that another medical evaluation should be done on this employee BEFORE they are fit-tested and trained on their new respirators.
When it comes to respirator protection… we must sweat the small stuff!
AUDITORS, PLEASE NOTE: an employee may be medically qualified to wear a respirator BUT may not have a fit test record for this respirator, but this would ONLY apply to respirators worn on a “voluntary basis.” Stated the employee MUST have a medical eval for EACH type of respirator they may wear. The Fit Test records should match up to those respirators listed in the “PLHCP recommendation(s),” and then the training record(s) should match up to these respirators. Any deviations in record keeping should be investigated for program or management deficiencies.
Source:
QUESTIONS AND ANSWERS ON THE RESPIRATORY PROTECTION STANDARD
Note: The page numbers referenced at the end of some of the Questions refer to specific pages in the January 8, 1998, Federal Register, Volume 63, No. 5. (Revised August 17, 1998)