Are pulmonary function tests (PFT) an OSHA Requirement? – SAFTENG

3/8/2021 UPDATE:

Of course, someone finds an LOI that says otherwise to my position and totally blows me away – not because the LOI says a PFT is not required, but that in the LOI OSHA states that personnel who are trained to the Operations Level are not HAZMAT responders and therefore do not need to have a PFT. I am sorry, but that is nonsense and I can not defend such rubbish – follow it if you will, but I think even OSHA would say “that’s not what we meant to say”. The LOI states:

“The emergency response paragraph (q) of the HAZWOPER standard requires physical examinations for HAZMAT team members and hazardous materials specialists. Employees trained to perform at the first responder operations level are not in one of these categories.”

Operations Level response is indeed covered by 1910.120 and in some cases, a defensive operation may be in a level of PPE that a Tech level response may use, so to claim that a person trained to the Operations Level will somehow be at a lesser stress level than a Tech responder is just nonsense!

This is one of the top questions we get regarding respiratory protection programs and unfortunately, the answer has many hurdles. In a BASIC respiratory program, the medical evaluation requirements can be FULLY met by using the OSHA Medical Questionaire. It is ONLY when the attending Physician or other licensed healthcare professional (PLHCP) sees an issue in the employee’s questionnaire and orders additional testing such as a Pulmonary Function Test (PFT). However, if the facility has an EMERGENCY RESPONSE TEAM or falls under an OSHA standard that has a medical surveillance program requirement requiring a PFT, then an annual PFT will be required. It is the Emergency Response team member’s PFT requirements I wish to discuss…

I have tried to make it clear for decades now that a Respirator Medical Evaluation using a medical questionnaire is ENTIRELY INADEQUATE to count as a Medical Evaluation for an Emergency Responder. Yes, a responders medical evaluation will by most accounts INCLUDE the respirator medical questionnaire, but the questionnaire alone is NOT wholly adequate for responders’ medical surveillance needs. OSHA makes has this clear in

1910.120(f)(4) Content of medical examinations and consultations…

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