The Respiratory Protection (RP) standard medical questionnaire for 1910.134 will NOT satisfy the HAZWOPER medical surveillance requirement. The intent and requirements for medical surveillance under HAZWOPER are very different from those required by the Respiratory Protection standard. The intent of the HAZWOPER medical surveillance requirements are two-fold:
- to determine fitness-for-duty, including the ability to work while wearing PPE (e.g., respirators), and
- to establish baseline data for comparison with future medical data.
The Respiratory Protection standard, however, requires a medical evaluation for the sole purpose of establishing an employee’s ability to use a respirator while performing assigned work tasks with the added psychological and/or physiological burden of wearing the protective equipment.
Source: HAZWOPER CPL (Pages 57-58)