Over the past several years we have seen an increase in the use of mobile test units for respiratory medical clearances and fit testing. Most safety professionals have seen these type of mobile units. When done correctly, these mobile units can save a lot of time and thus save the employer a lot of money; unfortunately, most of these mobile units create serious compliance issues in their attempt to save their client(s) money. Let’s start with Compliance Issue #1:
1910.134(e)(1) General. The employer shall provide a medical evaluation to determine the employee’s ability to use a respirator, before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee’s medical evaluations when the employee is no longer required to use a respirator.
These mobile units are designed to improve the efficiency of getting an employee through the process of being qualified to wear a respirator, thus almost all of the ones I have seen operated much like an assembly line. Employees enter the end of the trailer and their first stage is to fill out their medical questionnaire. Once they have completed their questionnaire, they usually move on to stage #2 which is usually either a pulmonary function test (PFT) or their fit-test. And just like that, we have Compliance Issue #1.
Most of these mobile units are staffed with “technicians” who may be qualified to perform fit tests and perform PFTs, but in order to save money, they are almost never staffed with a physician or other licensed health care professional (PLHCP). And this is a serious problem as it means that employees are NOT being medically cleared BEFORE they are fit tested.
Compliance Issue #2:
So not only are employees being fit tested before passing their medical evaluation, this error also brings about the fact that the employer is not receiving their “written recommendation regarding the employee’s ability to use the respirator from the PLHCP” until weeks, sometimes months, later.
1910.134(e)(6) Medical determination. In determining the employee’s ability to use a respirator, the employer shall:
1910.134(e)(6)(i) Obtain a written recommendation regarding the employee’s ability to use the respirator from the PLHCP. The recommendation shall provide only the following information:
1910.134(e)(6)(i)(A) Any limitations on respirator use related to the medical condition of the employee, or relating to the workplace conditions in which the respirator will be used, including whether or not the employee is medically able to use the respirator;
1910.134(e)(6)(i)(B) The need, if any, for follow-up medical evaluations; and
1910.134(e)(6)(i)(C) A statement that the PLHCP has provided the employee with a copy of the PLHCP’s written recommendation.
Ever how minor some may believe these matters are, rest assured that OSHA would issue “serious citations” regarding either/both of these matters. The solution to these matters is to simply require that the mobile unit be staffed with a physician or other licensed health care professional (PLHCP) who will “clear” the employee before they proceed on through the mobile unit. This way, when the employee(s) step out of the mobile unit they are as we intended… FULLY capable of wearing their respirator – albeit some may still need training.