In an earlier article, we addressed employer Respirator Medical Clearance requirements. Throughout the United States, millions of workers in various industries are required to wear respirators. Respirators protect workers against insufficient oxygen environments, harmful dust, fogs, smoke, mists, gases, vapors, and sprays. These hazards may cause cancer, lung impairment, diseases, or death.
Regulations
Within OSHA’s 29 CFR 1910 General Industry regulations, under Subpart I- Personal Protective Equipment, resides the Respiratory Protection Standard. Failure to comply with the OSHA Respiratory Protection Standard causes hundreds of deaths and thousands of illnesses annually.
PPE Program
Respirators, like all Personal Protective Equipment (PPE), require employers to ensure that employees not only use the PPE when required but also provide training on criteria such as selection, proper donning and doffing, limitations of the PPE, inspection, cleaning, care, maintenance, and storage. This should all be part of an effective employer PPE program.
Respiratory Protection Program
Once it is determined that respirators are required to be used by any employee, the employer is responsible to establish and maintain a written and effective respiratory protection program. Simply providing employees with respirators does meet compliance. How do you know if your employees are even able to wear a respirator?
Medical Questionnaire
Accordingly, 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 worn. This section outlines the delicate and confidential steps between the employee and PLHCP designated by the employer and the use of the medical questionnaire.
Convenient
The employer shall identify a physician or other licensed healthcare professional (PLHCP) to perform medical evaluations using a medical questionnaire or an initial medical examination that obtains the same information as the medical questionnaire.
The employer must allow employees to answer this questionnaire during normal working hours, or at a time and place that is convenient to them.
Examination Results With the PLHCP
To maintain confidentiality, the employer or supervisor must not look at or review the employee’s answers, and the employer must tell the employee how to deliver or send the questionnaire to the health care professional who will review it. The medical questionnaire shall be administered in a manner that ensures that the employee understands its content.
The employer shall provide the employee with an opportunity to discuss the questionnaire and examination results with the PLHCP.
