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April 1999

The New CalOSHA Respiratory Protection Medical Evaluation Requirements

    The revised CalOSHA respiratory protection standard, effective May 23, 1999 has several significant changes. One of the first requirements that an agency will need to address is that of assigning a program administrator who is "suitably trained" to administer the written respiratory protection program requirements. One of the first steps that this person will need to take is to ensure that each employee who wears a respirator (other than voluntary use of a dust mask) has been medically evaluated according to the new medical evaluation criteria. This will require (among other things) that specific medical conditions be evaluated using the information in a medical evaluation questionnaire found in Appendix C of the new standard. A copy of this medical evaluation questionnaire is available by calling the CSRMA Risk Control Hotline at (415) 371-5430.

    According to the attached letter from CalOSHA, if a Physician has already evaluated an employee or other licensed health care professional &LHCP), another medical evaluation is not necessary as long as the following is true:

    working conditions have not changed;

    • the PLHCP was provided the type and weight of the respirator to be used;
    • the PLHCP was provided with the duration and frequency of respirator use (including escape and rescue respirators);
    • the PLHCP was provided with the expected physical work effort, additional protective clothing to be worn, and the temperature and humidity extremes that may be encountered;
    • the examination covered the questions listed in the CalOSHA medical questionnaire, and
    • the PLHCP provided a written recommendation.

    If previous medical evaluations did not include the all of the above conditions, then another medical evaluation is needed. Practically speaking, most employees will need to be re-evaluated. This is because prior to the new standard, this evaluation criterion was not available and most evaluations will not have included all of the new medical conditions.

    This evaluation can be performed in one of several ways:

    1. Provide all covered employees with a copy of the questionnaire along with a stamped, preaddressed envelope to the employer's Physician or other licensed health care professional. Once completed this is mailed directly to the PLIICP for his/her review who will then determine if a follow-up medical examination is necessary.

    2. Provide a copy of the medical questionnaire to the agency's PLHCP and systematically send each covered employee to the health care provider. The health care provider will interview each employee using these questions and will then determine if a follow-up medical examination is necessary.

    3. An employer may choose to use a medical examination in place of the questionnaire, however, the PLHCP must obtain the same information from the worker that is contained in the questionnaire.

    If an employee's answer is "yes" to any question among questions 1-8 in Section 2 of the questionnaire, that employee must be given a follow-up medical examination. Also, any employee who will be using a self-contained Breathing Apparatus (SCBA) or a full-face respirator and who answers "yes" to questions 10-15, must also be provided with a follow-up medical examination. For this reason, it may be in the employer's best interest to have the PLHCP adrninister this questionnaire at the clinic.

    Other conditions include the requirement that the employer pays for the medical evaluation (including travel costs) and that the information in the questionnaire remain confidential. The employer may only see the written recommendation from the PLHCP, not the medical questionnaire information. Also, the employer must inform their employees that the PLHCP is available to discuss the medical questionnaire with them and that they (the employees) may discuss the results of their questionnaire with the PLHCP. The employer must also provide the PLHCP with a copy of their written respiratory protection program and a copy of the CalOSHA Respiratory Protection standard.

    Finally, the standard requires the employer to obtain a written recommendation from the PLHCP about the employee's ability to use a respirator. This written recommendation must include the following information:

  • A determination of whether or not the employee is medically able to use a respirator.
  • Any limitations on respirator use related to the medical condition of the employee or to the workplace conditions in which the respirator will be used.
  • The need, if any, for follow-up medical evaluations.
  • A statement that the PLHCP has provided the employee with a copy of the PLHCP's written recommendations.

    In summary, the employer has the responsibility for making the final determination as to an employee's ability to wear a respirator. The PLHCP's opinion is an important factor that you must consider in making this determination. For this reason, it is in the employer's best interest to ensure that the PLHCP filly understands the type(s) of respirators the employees will be wearing, the conditions under which they will wear them, and the types of work activities that they will be performing when wearing a respirator. If the PLHCP does not filly understand these conditions, they could make inaccurate recommendations that consequently impact an employee's ability to perform the essential functions of their job. If this happens, the employer will then need to determine if reasonable accommodations can be made under the American with Disabilities act.