Another aspect of a “respiratory protection program” often times will include a PFT as part of the “medical evaluation”. For the most part, these PFTs are done by the location where the PLHP resides and most of the time they are done by “trained” personnel – but how many of us actually audit the service provider to ensure they hold the proper certifications? OSHA’s newly revised silica standards specifically require that PFT’s, as required under the silica standards, be administered by a technician who holds a current certificate from a National Institute for Occupational Safety and Health (NIOSH)-approved spirometry course.
1910.1053(i)(2) Initial examination. The employer shall make available an initial (baseline) medical examination within 30 days after initial assignment, unless the employee has received a medical examination that meets the requirements of this section within the last three years. The examination shall consist of:
…
1910.1053(i)(2)(iv) A pulmonary function test to include forced vital capacity (FVC) and forced expiratory volume in one second (FEV1) and FEV1/FVC ratio, administered by a spirometry technician with a current certificate from a NIOSH approved spirometry course;
So the question is…
If we are utilizing the PFT as part of our “respiratory protection program” medical evaluation, should we adopt this requirement for our program EVEN though we are NOT required to do so (unless we have employees who fall under the Silica std)?
It sure would provide some assurances that the testing is being done properly and we are getting our money’s worth. We have found, more times than you’d think, where the PFT was administered by an untrained person using an uncalibrated machine and thus the Doctor was signing off on bad tests. These tests are not cheap and they take time away from normal work duties for employees to undergo them, so for me, it is a no brainer that we take an hour or so one day and visit the clinic/provider to audit their procedures/protocols to ensure we are receiving the quality of service we need to ensure our employees are properly protected.
For more information about NIOSH-approved spirometry training programs, please visit NIOSH’s spirometry website: https://www.cdc.gov/niosh/topics/spirometry/.