For those of you who are SAFTENG members and manage a Respiratory Protection program, this is NOT news to you, as we have discussed this many times before, and if you have been to my 1.5 Day Respiratory Protection Administrator course, you got this beat into your head! But for those less fortunate, here is the official OSHA position…
The respirator program MEDICAL evaluation is indeed a MEDICAL record that falls under 1910.1020, Access to employee exposure and medical records
Some of these questions that are sent to OSHA for clarification amaze me – it is almost like the teen asking Mom if they can do something and not liking the response, so they go ask Dad, hoping for a different response. Nonetheless, they do provide us with a lot of insight as to how OSHA views its standards and enforcement positions. BUT PLEASE KEEP in mind… the OSHA position is the LOWEST SAFETY BAR we MUST be above! Nonetheless, it does provide us with a clear floor from which to build. Here is what OSHA says about the Respiratory Protection Program Mecial Evaluation medical records…
PLEASE NOTE: This document speaks specifically to spirometry test results, but this test is NOT required for all respirator users. but ALL respirator users are required to be medically evaluated, and these results are indeed MEDICAL RECORDS.