The Respiratory Protection Standard 29 CFR 1910.134
While trying to simplify the Respirator Standard, OSHA has again made things a bit more complicated.If you haven’t yet seen the Medical Evaluation Questionnaire (appendix C to Sec. 1910.134) you’re in for a treat:
The very first question ‘reads,’Can you read? (circle one): Yes / No
Add to this the fact that the employer must not look at or review the employee’s answers and you’ll see we have a problem right from the start!This is a long and detailed form.
This article will address the Medical Evaluation portion of the new standard.The new medical questionnaire must be given during work hours, and the employer must not see it and will not receive a copy of it.The only documentation that an employer may now receive is proof that the employee has had a respirator clearance.This document should tell you what type of medical evaluation the employee has had and whether they have a full clearance, a pending clearance, a clearance for emergency use only, or are not approved for respirator use.Confidentiality is a major issue with this new standard. Some examples of information that the employee must be able to list are; what type of respirator they use, what type of work load they have (explained in kcal per hour), altitude in which they work (if over 5000 feet), and hazardous solvents or airborne chemicals that they are exposed to.This is not a questionnaire for the faint of heart.Which brings us to the medical portion of the form. Employees answering yes to any questions in Part A. Section 2 (Mandatory) must be given a follow-up medical examination. (if only the questionnaire or a pulmonary function test was done initially)This follow-up shall include any medical tests, consultations, or diagnostic procedures that the Physician or Licensed Health Care Professional (PLHCP) deems necessary.Some of the questions in this section include “Do you currently or have you smoked tobacco in the last month?”“Have you ever had pneumonia, chest injuries, asthma, etc….”As you can see, you will probably have some medical referrals. OSHA allows you to use only the medical questionnaire to gain a respiratory clearance for an employee.This will be fine if you can find a licensed health care professional to provide you with a clearance based simply upon an employee filling out a form. What health care professional would give a written clearance for an employee to wear a device that places a substantial physiological burden on its’ wearer, without having seen that employee or done any type of test on him?Employees can write anything they want on that questionnaire, and it’s your liability on the line when they put on that respirator!Any physician or licensed health care professional worth his or her license would, at a minimum, want that employee to have a pulmonary function test (PFT), a blood pressure, and the questionnaire filled out.Better yet, have a physical examination,PFT, blood pressure, and the questionnaire done.
OMY likes to do an initial full respirator physical, including the PFT on an employee.Then, in the following years, a PFT, blood pressure, and the medical questionnaire will suffice.Periodic exams are a good idea because our health changes as we age.We may be fit to wear that respirator at 30, but not be healthy enough to wear it at age 55. Use common sense when choosing a health care professional.They are putting their name on the dotted line of the clearance that they’re giving to your employee.It is in your company’s best interest to only have employees wearing respirators that are fit enough to handle the added stress that a respirator puts on the human body.Liability for your employees rests upon the company’s shoulders. Your health care professional will have to store all the paperwork that goes with a respirator clearance. (the graphs from the PFT, the medical questionnaire, a physical exam form that the physician and the employee fill out)OMY handles the storage and will gladly fax those results to your company physician if the employee signs and faxes back to us a Medical Release Form giving us permission to give this information to either his doctor or the company doctor. If you have a medical department with a nurse or physician onsite, then OSHA allows you to keep the results on your premises.We are following the new OSHA regulations to keep our company and YOUR company in compliance. Our name and phone number is on the new medical questionnaire so that your employees can call us if they have any questions about the form.Our techs are NIOSH certified and will gladly help employees with questions on the forms, and if they can’t answer a question while onsite, a nurse or physician at our office can help.Also, our forms are in Spanish if you need them.Give us a call if we can be of service to your company.