THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 6  Issue 3, Article 2.  August, 2004

We are often asked questions from our clients about what are the medical requirements for the use of respiratory protection in the workplace. Cal/OSHA regulations require a medical evaluation before the employee is fit tested or is required to use the respirator in the workplace. The only exception for the medical evaluation requirement is during the voluntary use of filtering facepieces (a.k.a. dust masks). Voluntary use of respiratory protection has been discussed in previous Current Issues. This article focuses on the medical evaluation requirements.

Medical evaluations must be performed on all individuals required to wear respirators. This must be provided at no cost to the employee and conducted in a confidential manner by a physician or other licensed health care professional (PLHCP). The employer must obtain a written statement from the PLHCP regarding whether/or not the employee is medically able to wear a respirator. The recommendation from the PLHCP must identify any limitations on the employee's use of a respirator, such as use of a respirator for personal egress/emergency evacuation situations only, or preclusion of the use of respiratory equipment under conditions of extreme temperatures or under heavy exertion/prolonged time periods. In addition, the PLHCP must identify the need for any follow-up evaluations. The employee must also receive a copy of the PLHCP's written statement.

Since the Cal/OSHA respiratory protection standard (California Code of Regulations, Section 5144) was revised in 1998, annual medical evaluations are no longer required. Frequency of medical evaluations will be determined by the PLHCP at the time of the initial evaluation. Additional medical evaluation or reevaluation generally will be provided if any of the below conditions exist:

· The employee reports signs and symptoms that are related to the employee's ability to wear a respirator, such as asthma and other respiratory ailments, claustrophobia, difficulty detecting odors, visual or               auditory difficulties, cardiovascular problems (for example, hypertension, chest pain and shortness of breath), neurological issues (for example, a prior history of stroke), and any problems the employee may have experienced with prior respirator use.
· If a medical problem is observed during fit testing of the respirator.
· Change occurs in workplace conditions (physical work effort, type of respirator used, temperature, etc.).

Additionally, a direct physical examination is no longer required unless the employee indicates that he/she wants to see the PLHCP, or the PLHCP indicates that he/she wants to see the employee (that is, the employee may not need to be seen by the PLHCP).

The medical evaluations can be performed by administering a questionnaire or by a direct medical examination that provides the same information. Initial medical evaluations are typically conducted with a health screening questionnaire. Though the questionnaire is not required, most health care providers use it. The medical evaluation must obtain the information requested by the questionnaire, as provided in Appendix C, Part A, Sections 1 and 2 of the Cal/OSHA respiratory protection standard.

If a positive response is given to any of questions 1 through 8 in Section 2, Part A of the questionnaire, a follow-up medical examination is typically provided, unless a verbal explanation clarifies any potential misunderstanding. Part A of Section 2 asks specific questions relating to pulmonary or cardiovascular problems. The follow-up examination will include any medical tests, consultations, or diagnostic procedures that the PLHCP deems necessary to make a final determination.

If the questionnaire is used, it must be administered confidentially. When is it completed, the employer should request the employee to seal the completed questionnaire in an envelope and sent it to the medical provider or to hand carry it to the clinic.

There are also responsibilities on the employer for completion of the medical evaluation. For example, the following information must be provided by the employer to the PLHCP before a written recommendation is made concerning an employee's ability to use a respirator:

· Duration and frequency of respirator use.
· Expected work effort, i.e., the conditions under which the respirator will be worn.
· Additional protective clothing and equipment to be worn.
· Temperature and humidity extremes encountered.
· Provide a copy of your respiratory protection program to the PLHCP.

Questionnaires and medical evaluations are typically retained by the PLHCP. However, information regarding PLHCP recommendations, fit-testing and the respirator program must be maintained by the employer. Medical evaluations must be made available to the employee. If the employer replaces the PLHCP, the employer must ensure that the new PLHCP receives the medical evaluations, questionnaires, etc.

Employers faced with choosing a PLHCP to perform Respiratory evaluations for their employees should consider the following factors;

1) The PLHCP’s mastery and working knowledge of OSHA requirements for respirator use,
2) The PLHCP’s experience with performing such evaluations and familiarity with the respiratory protection medical history questionnaire utilized for this purpose,
3) The PLHCP’s ability to determine if a physical examination and further focused testing is required for an employee based on interpretation of the Respiratory questionnaire,
4) The PLHCP’s proficiency in performing a directed physical examination when indicated, and
5) The adeptness with which the PLHCP sets limitations on an employee’s ability to use respiratory equipment so that the well being of the employee is always preserved.

Some suggestions for making the Respiratory evaluation process as expeditious and simple as possible include;

1) The employee may complete the Respiratory medical history questionnaire on his/her own, with the prior instruction that any positive answers would most likely require a physical examination by a PLHCP,
2) The employee should be prepared to address all positive questionnaire responses with either a clear explanation of problem resolution, or a letter of explanation from his/her private Physician, and
3) The employee should alert the PLHCP of any outstanding medical conditions that are of concern to him/her, so that the health care provider can safely assess the ability of the employee to use respiratory equipment.

If you have any questions regarding the administration of medical evaluations for respiratory protection please contact The Cohen Group or U.S. Health Works.

Note: The Cohen Group wishes to acknowledge the contribution of Dr. Meredith Saunders, Area Medical Director for U.S. Healthworks.