|
| (e)(1) |
| Q. |
Are seasonal or temporary workers exempt from the requirement for medical evaluations? (FR p. 1209-1210) |
| A. |
No. The frequency and duration of respirator use and the worker’s term of employment, does not affect the requirement for medical evaluation. |
| |
| Q. |
Can a fit test for a respirator be performed before the initial medical evaluation has beencompleted? (FR p.1209) |
| A. |
No. The initial medical evaluation must be conducted prior to fit testing to identifyindividuals whose health may be harmed by the limited amount of respirator use associated with fit testing. |
| |
| Q. |
Are employees who use filtering facepiece respirators (dust masks) voluntarily (e.g., for employee comfort) also required to have medical evaluations? (FR p.1190, 1210) |
| A. |
No. If the employer has determined that there is no hazard, and dust mask use is voluntary, then no medical evaluation is required. If employers allow voluntary use of this type of respirator, then they must provide the employee the information contained in Appendix D of the standard, and ensure that such respirator use will not itself create a hazard. |
| |
| Q. |
Are medical evaluations required for positive pressure, as well as negative pressure, respirators? (FR p.1210) |
| A. |
Yes. Clinical studies show that positive pressure respirator use can harm the employee. (e)(2)(i) |
| |
| Q. |
Are physicians the only medical professionals allowed to perform medical evaluations for respirator use? (FR p.1211) |
| A. |
No. A variety of health care professionals may do this depending on the scope of practice permitted by the state’s licensing, registration, or certification agencies. Each employer must check with the state licensing agency to see if other health care professionals under their state law can independently perform this evaluation, or must do so under the direction of a licensed physician. Attached to this document is a phone listing of all the State Licensing Boards in the United States, to assist in determining compliance with this provision. |
| |
| Q. |
Can a nurse who does not meet the qualifications of a PLHCP assess a questionnaire? (FR p. 1212) |
| A. |
A nurse not otherwise qualified to be the PLHCP can perform some tasks, such as distributing the questionnaire, respond to some questions such as providing advice to employees on where they can obtain assistance in understanding or reading the questions, and gathering the completed forms in preparation for delivery to the PLHCP. If the nurse is working under the direction of a physician (or other PLHCP consistent with state law) who will perform the final review of the assessment, then this arrangement is acceptable. |
| Back To Top |
|
| (e)(2)(ii) |
| Q. |
Does the employer have to use the exact language of the questionnaire in Appendix C if they choose to evaluate by medical questionnaire? (FR p. 1212) |
| A. |
The language of Part A , Appendix C is mandatory if the employer chooses to medically evaluate by questionnaire. The employer may choose a medical examination in lieu of the medical questionnaire. |
| |
| Q. |
If the employer chooses to provide physical exams , rather than use the questionnaire, what information must be obtained? |
| A. |
he employer who chooses to skip the questionnaire, and instead go directly to an exam shall ensure that the exam obtains the same information as is found in the questionnaire. |
| |
| Q. |
May the PLHCP add questions to the questionnaire provided in Appendix C? (FR p. 1283) |
| A. |
Yes. Part B of the questionnaire contains 19 optional questions that may be added In addition, the instructions to Part B state that any other questions not listed can be added. |
| |
| Q. |
Why do employees have to answer questions about hearing and vision impairments ? (FR 1214) |
| A. |
Questions 10 through 15 of Appendix C must only be answered by those who will use full facepiece or SCBA respirators. The configuration of these respirators can further reduce hearing and vision |
| |
| Q. |
If an employee will be wearing an SCBA, does a positive response to any of the items in Questions 10 thru 15 of Part A, Section 2 require a medical exam? |
| A. |
Yes. |
| Back To Top |
|
| (e)(3)(i) |
| Q. |
Who determines the scope and form of the medical evaluation if an employee gives a positive response to questions 1 through 8 in Section 2, Part A of the questionnaire? (FR 1214) |
| A. |
The PLHCP makes this determination. The PLHCP is also expected to refer the employee to a physician if warranted. |
| |
| Q. |
If there is a single positive response on the questionnaire, does that automatically require a face-to-face visit with the PLHCP? (FR p. 1214) |
| A. |
No, the scope of the medical evaluation is left to the discretion and professional judgment of the PLHCP. There may be occasions where all that is needed is clarification of an issue by telephone. |
| Back To Top |
|
| (e)(3)(ii) |
| Q. |
If a PLHCPs scope of practice is limited to questionnaire evaluation or a basic physical exam, can that PLHCP still be used even though further testing and decision making may be necessary? (FR p.1214) |
| A. |
Yes. In some cases where medical issues arise that are beyond the scope of the PLHCP’s license, the remainder of the evaluation will need to involve a physician or other authorized health care professional (for example, conducted under the direction of a physician). |
| |
| Q. |
Can an employee decline to be medically evaluated for the use of a respirator? (FR p.1220-1221) |
| A. |
Paragraph (e)(1) requires the employer to provide a medical evaluation to an employee before the employee uses a respirator in the work place. Therefore, an employee cannot refuse to undergo medical evaluation and continue to use a respirator. |
| Back To Top |
|
| (e)(4)(i) |
| Q. |
Who pays for the medical evaluation and any subsequent exams? (FR 1214) |
| A. |
The employer must pay for the medical evaluation and any related expenses incurred by the employee during the evaluation, including travel costs. |
| |
| Q. |
Does the medical questionnaire have to be administered by a PLHCP? (FR 1214-1215) |
| A. |
While the employee must be able to discuss the results of the questionnaire with the PLHCP, the standard does not specify the qualifications of the individual who administers the medical questionnaire. |
| |
| Q. |
How does an employer ensure the employee understands the questions on the medical questionnaire if the employee only speaks and/or reads a language other than English? (FR p. 1215) |
| A. |
Under these circumstances, the PLHCP can assist the employee in filling out the questionnaire, with the aid of an employer-provided interpreter. The interpreter need not be a professional and can be a bilingual employee, family member, or friend who is fluent in the native language of the person answering the questionnaire. The employer may also have the questionnaire translated into the appropriate language. |
| |
| Q. |
What happens if an employee has difficulty reading or understanding the questionnaire? (FR p.1215) |
| A. |
The employer must take action to ensure the employee understands the questionnaire. The employer may have the PLHCP assist the employee in filling out the medical questionnaire or go directly to a physical examination. |
| |
| Q. |
Why does the questionnaire in Appendix C begin with the question “can you read”? (FR p.1215 & 1282) |
| A. |
This question is included to remind those who are responsible for administering and reviewing the questionnaire that employees who cannot read may need additional assistance in completing the questionnaire. |
| Back To Top |
|
| (e)(4)(ii) |
| Q. |
How can an employer ensure the employee understands the medical questionnaire while still meeting the requirements of confidentiality? (FR p.1215) |
| A. |
Since the medical questionnaire provided in the standard was designed to be easily understood, oversight should not generally be necessary. When employees have questions about the questionnaire, they must be provided with the opportunity to discuss the questions with the PLHCP. |
| |
| Q. |
What procedures should be used to maintain confidentiality if the questionnaire is administered by the employer? (FR p.1215 & 1282) |
| A. |
The directions to the employee for answering the medical questionnaire state that the employer must not look at or review their answers. The employee must be instructed on how to deliver or send the completed questionnaire to the PLHCP who will review it. One method for accomplishing this task is for the employer to provide the employee with a stamped envelope addressed to the PLHCP at the time the questionnaire is administered. |
| Back To Top |
|
| (e)(5)(i) |
| Q. |
Why does supplemental information need to be provided to the PLHCP? (FR p.1216- 1217) |
| A. |
When evaluating an employee’s medical limitations, the PLHCP may need to consider other workplace variables that may increase pulmonary and cardiovascular stress during respirator use. |
| |
| Q. |
Why is there no specific requirement to give the PLHCP a list of substances the employee may be exposed to? (FR 1215-1216) |
| A. |
The company’s written respiratory program already specifies the exposure conditions that require the use of a respirator. A copy of the written program must be provided to the PLHCP instead. The program will provide the necessary information to the PLHCP without imposing an additional paperwork burden on employers. |
| |
| Q. |
Does the PLHCP have to visit the worksite to perform a medical evaluation? (FR p.1217) |
| A. |
While it might be helpful for the PLHCP to visit the site, there is no requirement to do so under the standard. The supplemental information required to be provided to the PLHCP by the standard is sufficient for the PLHCP to make a valid recommendation on the employee’s ability to wear a respirator. |
| Back To Top |
|
| (e)(5)(ii) |
| Q. |
How often must supplemental information be provided to the PLHCP? (FR p.1217) |
| A. |
It need only be provided once, unless there are changes in the supplemental information; in that case updated information must be provided to the PLHCP. If you change PLHCP’s, then the employer must assure that all the information has been transferred or that new documents are provided to the new PLHCP. |
| |
| Q. |
Can an employer choose to let each employee use their own personal physician to provide a medical evaluation rather than using the employer’s PLHCP? (FR p.1217) |
| A. |
Yes. This may be a workable system where few employees are involved. The employer will have to contact each of these PLHCPs and provide them with a copy of the Respiratory Protection standard and other required supplemental information, as well as updates when required. The employer shall bear the costs of the evaluation. It is not acceptable for an employee to use their health insurance for this purpose, unless the employer pays 100% of the insurance premiums. |
| Back To Top |
|
| (e)(6)(i) |
| Q. |
Who is responsible for determining an employee’s ability to use a respirator? (FR p.1218) |
| A. |
The responsibility rests with the employer. The PLHCP’s opinion regarding the employee’s medical ability to wear a respirator is an important element in making the final determination. |
| |
| Q. |
Does the PLHCP’s opinion on the employee’s medical ability to use a respirator have to be in writing? (FR p. 1218) |
| A. |
Yes. |
| |
| Q. |
If the PLHCP discovers that the employee uses drugs, does the PLHCP have an obligation to tell the employer? (FR p.1218) |
| A. |
No. The PLHCP must maintain strict confidentiality on specific medical findings unrelated to the ability to wear a respirator. Information regarding pregnancy, genetic susceptibility, mental health problems, and drug use are not to be revealed to the employer when they result from the medical evaluation process. These findings must remain confidential. How specific medical information is addressed between the employee and PLHCP should be determined by the legal, professional, and ethical standards that govern the PLHCP’s practice. |
| |
| Q. |
Can the employer maintain a copy of the employee’s completed medical questionnaire? (FR p.1218 & 1282) |
| A. |
No. The employer must maintain only the PLHCP’s written recommendation on an employee’s eligibility to wear a respirator. The completed questionnaire and PLHCP’s documented findings or diagnosis are confidential and must not be maintained by the employer. An exception is made when the employer’s health office is administratively separate from the employer’s central administration offices. |
| |
| Q. |
How does the PLHCP’s opinion affect periodic medical evaluation? (FR p. 1218) |
| A. |
The final standard does not automatically require periodic medical reevaluation. It is critical, however, that the PLHCP address this issue in their medical opinion. If there is an underlying medical concern that requires periodic medical reevaluation, it must be included in the written medical opinion so that the employee can be monitored in the future by the PLHCP. |
| Q. |
How can the employee obtain a copy of their medical evaluation or the medical questionnaire? (FR p.1218) |
| A. |
The employer is required to provide a copy of the written opinion to the employee. The written opinion should be provided by the PLHCP but can be provided by the employer. Requests for copies of the questionnaire should be made to the PLHCP consistent with the requirements of 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records”. |
| Back To Top |
|
| (e)(6)(ii) |
| Q. |
Does the employer have to provide a powered air-purifying respirator (PAPR) to an employee who can’t wear a negative pressure respirator? (FR p.1218-1219) |
| A. |
The employer must provide a PAPR if the PLHCP determines that the use of a negative pressure respirator would place the employee at increased risk for adverse health effects and the PLHCP finds that the employee can use a PAPR. If a subsequent medica evaluation finds that the employee is able to use a negative pressure respirator, a PAPR need no longer be provided. |
| Back To Top |
|
| (e)(7) |
| Q. |
Does the employer have to medically reevaluate the employee’s ability to wear a respirator on an annual basis? (FR 1219) |
| A. |
No. There is no annual or periodic requirement for medical reevaluation. The standard lists four conditions that trigger medical reevaluation: an employee reports signs or symptoms related to the ability to wear a respirator; the PLHCP, administrator or supervisor determine it is necessary; information from the respiratory protection program indicates a need for reevaluation; or a change in workplace conditions substantially increases the physiological burden placed on the employee.(FR p.1219-1220) |
| |
| Q. |
Is there a medical removal provision in this standard for persons medically unable to wear a respirator? (FR p.1220) |
| A. |
No. The final standard does not include a medical removal provision. |
| Back To Top |
|
|
| (f)(1) |
| Q. |
Do all tight-fitting respirators which are required by the employer or by OSHA have to be fit tested? (FR p. 1188, 1189, 1191, 1222) |
| A. |
Yes. Both negative pressure and positive pressure tight-fitting respirators must be fit tested. |
| Back To Top |
|
| (f)(1) |
| Q. |
Does a Self-Contained Breathing Apparatus (SCBA) require fit testing? (FR p. 1223, 1224) |
| A. |
Yes, SCBAs require a fit test. Most workplace use of positive pressure atmosphere-supplying respirators occurs in high hazard atmospheres where a high degree of certainty is required that the respirator is maximally effective. Fit testing of tight-fitting positive pressure facepieces is appropriate to reduce the chance of leakage into the facepiece. |
| Back To Top |
|
| (f)(1) |
| Q. |
Do tight-fitting negative pressure respirators that are worn voluntarily require a fit test? (FR p. 1222) |
| A. |
No, respirators worn when not required by OSHA or the employer do not require a fit test. |
| Back To Top |
|
| (f)(1) |
| Q. |
Do loose-fitting respirators require a fit test? (FR p. 1222) |
| A. |
No, loose-fitting respirators do not require a qualitative or quantitative fit test. (FR p.1222) |
| Back To Top |
|
| (f)(2) |
| Q. |
Which respirator use requires fit testing? (FR p. 1222, 1223, 1225) |
| A. |
Fit testing is required when OSHA or the employer requires employees to wear tight-fitting respirators. The employee must pass a fit test prior to the initial use of the respirator. Additional fit tests are required whenever the employee reports, or the employer, PLHCP, Supervisor or Program Administrator observes changes in the employee’s physical condition that could affect respirator fit. If the employee changes to a different fitting facepiece a new fit test is required. An annual fit test is required after the initial fit test. |
| Back To Top |
|
| (f)(4) |
| Q. |
When would the fit of a respirator be unacceptable? (FR p. 1225) |
| A. |
A respirator may be unacceptable if it causes irritation or pain to an employee, if the employee is unable because of discomfort to wear the respirator for the time required, or if the employee is unable to maintain proper seal. |
| Back To Top |
|
| (f)(5) |
| Q. |
Can an employer use any method of fit testing? (FR p. 1223,1226) |
| A. |
No. The employer must use one of the OSHA-accepted qualitative or in some cases quantitative fit test protocol. OSHA-accepted protocols are found in Appendix A of the 29 CFR 1910.134 Respiratory Protection Standard. |
| Back To Top |
|
| (f)(5) |
| Q. |
Can an employer develop its own fit testing method?(FR p. 1228) |
| A. |
Any new fit testing methods must first meet the acceptance requirements of Section II of Appendix A, before it can be used. |
| Back To Top |
|
| (f)(5) |
| Q. |
Does a “user seal check” qualify as a fit test? (FR p. 1188) |
| A. |
No, a User Seal Check is a procedure the employee performs each time they don the respirator. The purpose of the User Seal Check is to ensure the respirator is properly seated to the user's face. It is not a substitute for a fit test of a particular type, model, and size of a respirator. |
|
|
| Q. |
Can a qualitatively fit-tested tight fitting negative pressure air-purifying respirator be used in an atmosphere greater than 10 times the PEL? (FR p. 1227) |
| A. |
No. A qualitatively fit-tested tight fitting negative pressure air-purifying respirator can only be used in an atmosphere less than or equal to 10 times the PEL. |
| Back To Top |
|
| (f)(5) |
| Q. |
Will OSHA establish a mechanism to evaluate and approve new fit testing methods? |
| A. |
The mechanism is already described in Part II of Appendix A of the standard. Parties with a new fit testing method must supply a detailed description of the method as well as data from an independent government research laboratory or from a study published in a peer reviewed industrial hygiene journal supporting the new method’s performance. Upon receipt of this information, OSHA will initiate rulemaking to add this method to Appendix A of the Respirator Standard.(FR p. 1221) |
| Back To Top |
|
| (f)(6) |
| Q. |
What negative-pressure respirators may be fit tested with a QLFT? |
| A. |
Negative-pressure air purifying respirators that will be worn in concentrations that are equal to or less than ten times the Permissible Exposure Level may be fit tested using QLFT. The limitation on the air contaminant concentration is discussed in (f)(7) below. |
| Back To Top |
|
| (f)(6) |
| Q. |
Can QLFT be used to test the fit of a full facepiece negative pressure air purifying respirator? (FR p. 1222) |
| A. |
The factor that limits the use of QLFT is the concentration of the air contaminant in which it is being worn. If the full facepiece respirator is only being worn in air contaminant concentrations that are equal to or less than ten times the PEL, then QLFT can be used. However, it cannot be used in air concentrations greater than ten times the PEL unless it is fit tested using a Quantitative Fit Test (QNFT). |
| Back To Top |
|
| (f)(6) |
| Q. |
How will OSHA deal with an application for a QLFT protocol that measures fit factors greater than 100? |
| A. |
If new methods are developed that permit QLFT use for higher fit factors, OSHA may, as part of the acceptance process for these new methods (described in the explanation for (f)(5) above), adjust the present language in (f)(6) appropriately. |
| Back To Top |
|
| (f)(7) |
| Q. |
Since the standard does not define the term "assigned protection factor" can an employee wear tight fitting air purifying respirators to concentrations of 100 times the PEL for half facepiece respirators and 500 times the PEL for full facepiece respirators if they are quantitatively fit tested? |
| A. |
No. The fit factors of 100 and 500 only define what fit factor is necessary to pass the fit test. The preamble states that the standard incorporates a safety factor of ten because protection factors in the workplace tend to be much lower than the fit factors achieved during fit testing. The use of a safety factor is a standard practice supported by most experts to offset this limitation. The use of safety factors of ten is recommended by a number of experts and is included in the ANSI standard for respiratory protection. |
| Back To Top |
|
| (f)(7) |
| Q. |
What are acceptable fit factors for tight-fitting half facepieces and tight-fitting full facepieces respirators that are fit tested using QNFT? |
| A. |
The acceptable fit factors are explained in section (f)(7): 100 for a half facepiece and 500 for a full facepiece. |
| Back To Top |
|
| (f)(8) |
| Q. |
Does this paragraph require fit testing of positive pressure respirators such as SCBAs, PAPRs, and Supplied Air Respirators (SARs) ? (FR p. 1226) |
| A. |
Yes. The standard requires fit testing of the facepiece to check for leakage. The standard allows the employer to conduct the test by using a negative pressure respirator with a facepiece of the same make, model and size as the positive pressure facepiece, or by temporarily converting the facepiece for the positive pressure apparatus to a negative pressure device and performing the fit test. |
| Back To Top |
|
| (f)(8) |
| Q. |
Can a tight fitting PAPR be tested simply by not turning the fan motor on? |
| A. |
Yes. By not turning on the fan motor, a PAPR would be operating in the negative pressure mode. |
| Back To Top |
|
| (f)(8) |
| Q. |
Is there a frequency of use below which fit testing would not be required for atmosphere supplying respirators? Often, emergency SCBAs are available for fire brigade or hazardous substance emergency response personnel, but these personnel may not use the equipment in a hazardous atmosphere for several years.(FR p. 1226) |
| A. |
The standard’s requirement of annual fit testing applies to emergency response personnel who wear respirators to protect against hazardous atmospheres. Proper fit is especially necessary for emergency personnel. These people may only wear the equipment infrequently, but when they do use the equipment, they often use it in very dangerous atmospheres. |
| Back To Top |
|
| (f)(8)(iii) |
| Q. |
Can a probe hole be drilled in a facepiece to perform QNFT and then the probe hole be sealed so the facepiece can be used on the respirator? |
| A. |
No. As the second sentence of section (f)(8)(ii) says, the permanently probed respirator only serves as a surrogate for testing purposes. A face piece with a probe hole drilled in it cannot be restored to its NIOSH-approved configuration. |
|
|
| Q. |
For quantitative fit testing, must employers still perform three fit tests? |
| A. |
No. |
| Back To Top |
|