I recently worked with a client on their emergency response efforts, and we continue to find businesses that do not understand the different requirements of qualifying a worker to use a respirator under CONTROLLED workplace exposures vs. UNCONTROLLED emergency response exposures. So, I wanted to write this article to make it as straightforward as possible…
Employee A is hired into a job that requires him/her to wear a Full-Face Air-Purifying Respirator (APR). For the employee to enter into the Respiratory Protection Program, we must FIRST have the employee medically evaluated by our Professional Licensed Health Care Professional (PLHCP).
The evaluation can be as simple as using OSHA’s Questionnaire (Appendix C) or a similar document. Alternatively, we can go above and beyond the OSHA Questionnaire and have Employee A undergo a more rigorous examination developed by a Licensed Healthcare Professional, preferably one with an Occupational background. Still, the BARE MINIMUM for OSHA compliance uses the OSHA Questionnaire (Appendix C). Once we have received medical clearance from the PLHCP stating that Employee A is approved to wear their respirator(s) under the indicated work conditions, Employee A can proceed to the next level – Fit Testing. But make 100% certain that we have the PLHCP approval BEFORE proceeding to the Fit Testing phase. See my article earlier this year about using the Occupational Health trailers where everything is done simultaneously!
Regarding fit testing, we have a couple of options at this stage of Employee A’s work. We can use a Qualitative Method to test his/her fit for the Make, Model, Style, and size face piece they will be provided. However, please remember that if they wear different facepieces, each one must be fit-tested.
Now the employee is reading for their training on the respirators they will be using in the workplace, and EACH type of respirator MUST be covered as the limitations of each type MUST be communicated to the user, as well as all the other topics in 1910.134(k).
At some later date, Employee A is needed on the Emergency Response Team (ERT), a HAZMAT team in this example. For this to happen, the employee MUST enter into an advanced (as compared to the basic respirator medical eval as stated above) medical surveillance program as required by 1910.120(f)(2)(iv).
This medical surveillance program is more extensive and is REQUIRED at the following stages:
1910.120(f)(3)(i)(A) Prior to assignment;
1910.120(f)(3)(i)(B) At least once every twelve months for each employee covered unless the attending physician believes a longer interval (not greater than biennially) is appropriate;
1910.120(f)(3)(i)(C) At the termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months
And it could be more frequent if the examining physician determines that an increased examination frequency is medically necessary. 1910.120(f)(3)(i)(E)
These REQUIRED medical examinations MUST include a medical and work history (or updated history if one is in the employee’s file) with particular emphasis on symptoms related to the handling of hazardous substances and health hazards and to fitness for duty, including the ability to wear any required PPE under conditions (i.e., temperature extremes) that may be expected at the work site. The attending physician MUST determine the content of these medical examinations; however, the guidelines in the Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (See Appendix D, reference # 10) should be consulted.
Under this ERT medical surveillance program, the employer is REQUIRED to provide more information to the attending physician than what was provided under the Respirator Program medical eval:
1) one copy of this standard and its appendices
2) description of the employee’s duties as they relate to the employee’s exposures,
3) employee’s exposure levels or anticipated exposure levels
4) description of any personal protective equipment used or to be used
5) previous medical examinations of the employee
6) information required by §1910.134
SPECIAL NOTE: Once Employee A becomes a member of the ERT, their ERT physical will replace their respirator evaluation. There is NO need to have them do both, as LONG AS the ERT evaluation is done correctly. Also, although it is a best practice, OSHA does NOT require the respirator medical eval to be done annually, BUT the ERT medical eval is REQUIRED ANNUALLY.
BOTTOM LINE: An essential medical evaluation for using an APR done under 1910.134 is NOT adequate for a member of a HAZMAT Team (as defined in 1910.120).
I have had medical evaluations for maintenance personnel come darn near what the ERT members get as we had maintenance personnel wearing SCBA’s and Full Encapsulating suits for some line break activities, and the PLHCP determined (rightfully so) that this usage was “EXTREME,” and therefore this maintenance personnel were required to do more than the basic medical questionnaire. This would often include a Pulmonary Function Test (PFT) or some other testing. But again, the FREQUENCY of these respirator evaluations are NOT required to be annual unless the PLHCP requires it, whereas the ERT physicals are REQUIRED by OSHA to be annual.
For those looking to have an on-site ERT and are wondering what type of “physical” OSHA is looking for, we can get a flavor from the Guidance Manual for Hazardous Waste Site Activities, Chapter 5 – Medical Program, where OSHA and EPA offer guidance on setting up a medical surveillance program. (Source: https://www.osha.gov/Publications/complinks/OSHG-HazWaste/all-in-one.pdf)