3.2 Medical evaluation: before anything else

1 Before, not after

Paragraph (e)(1): 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 workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

That ordering is the single most commonly broken rule in the whole standard. A crew is fit tested in the morning and the medical questionnaires go out the following week. It is backwards, and it is backwards for a reason: the fit test itself is exertion in a respirator, on a person nobody has yet cleared to wear one.

Remember also who pays. Paragraph (c)(4): the employer shall provide respirators, training, and medical evaluations at no cost to the employee.

2 Who does it, and how

Paragraph (e)(2)(i): the employer shall identify a physician or other licensed health care professional (PLHCP) to perform medical evaluations using a medical questionnaire, or an initial medical examination that obtains the same information as the medical questionnaire.

Paragraph (b) defines a PLHCP as an individual whose legally permitted scope of practice — licence, registration or certification — allows them independently to provide, or to be delegated the responsibility to provide, some or all of the health care services required by paragraph (e). That deliberately covers more than physicians.

Paragraph (e)(2)(ii): the evaluation shall obtain the information requested by the questionnaire in Sections 1 and 2, part A of appendix C of the section. Appendix C is the mandatory questionnaire, and it is the reason a physical examination is not required for most workers — a questionnaire, properly reviewed, is the baseline route.

Paragraph (e)(5)(i) requires the employer to give the PLHCP five pieces of context before a recommendation is made: the type and weight of the respirator to be used; the duration and frequency of respirator use, including use for rescue and escape; the expected physical work effort; additional protective clothing and equipment to be worn; and temperature and humidity extremes that may be encountered.

Those five turn a general question into a specific one. “Can this person wear a respirator” is unanswerable. “Can this person wear a full facepiece for six hours doing heavy work in a Tyvek suit at 95 degrees” can be answered.

3 Confidentiality and the conditions of the questionnaire

Paragraph (e)(5)(ii) requires that supplemental information already provided to the PLHCP need not be provided again if the same PLHCP performs the evaluation and it is readily available.

More importantly, paragraph (e)(5) and the surrounding provisions protect how the questionnaire is administered. The employer must ensure that the medical questionnaire and examination are administered confidentially during the employee's normal working hours or at a time and place convenient to the employee, and that the questionnaire is administered in a manner that ensures the employee understands its content. The employer must also provide the employee an opportunity to discuss the questionnaire and examination results with the PLHCP.

The practical consequence: a supervisor collecting completed questionnaires and reading them is a breach of the design. The questionnaire goes to the PLHCP, and what comes back to the employer is a recommendation, not a medical history.

4 What comes back

Paragraph (e)(6)(i): in determining the employee's ability to use a respirator, the employer shall obtain a written recommendation regarding the employee's ability to use the respirator from the PLHCP. And the standard limits what that recommendation may contain: it shall provide only the following information — any limitations on respirator use related to the employee's medical condition or to the workplace conditions in which it will be used, including whether the employee is medically able to use the respirator; the need, if any, for follow-up medical evaluations; and a statement that the PLHCP has provided the employee with a copy of the written recommendation.

That restriction is deliberate. The employer learns whether the person can wear the respirator and under what limitations — not what condition they have.

One specific provision is worth knowing: where the recommendation is that an employee cannot use a negative pressure respirator, the standard requires the employer to provide a PAPR if the PLHCP's medical evaluation finds the employee medically able to use one. A negative finding on a half mask is not automatically the end of the road.

5 When it has to happen again

There is no fixed re-evaluation interval in 1910.134. Instead, paragraph (e)(7) lists the circumstances that require an additional medical evaluation:

1. 1
   An employee reports medical signs or symptoms that are related to the ability to use a respirator.
2. 2
   A PLHCP, supervisor or the program administrator informs the employer that an employee needs to be re-evaluated.
3. 3
   Information from the program, including observations made during fit testing and program evaluation, indicates a need for re-evaluation.
4. 4
   A change occurs in workplace conditions — physical work effort, protective clothing, temperature — that may result in a substantial increase in the physiological burden on the employee.

The fourth trigger is the one to watch on a live site. Move a crew from an air-conditioned shop to summer outdoor work in coveralls, or from half masks to full facepieces with a supplied-air hose, and the physiological burden has changed materially. That is a re-evaluation trigger, not a paperwork nicety.

6 Running medical evaluation without friction

Three practices make this element work rather than stall.

Put it in the hiring or assignment sequence. Medical evaluation is the first step, so it belongs where onboarding already happens. Bolting it on afterwards is what produces the fit-test-first ordering error.

Send the five context items with the questionnaire, every time. The PLHCP cannot answer a specific question they were not asked. A one-page cover sheet carrying (e)(5)(i)(A) through (E) for the actual task is the whole fix.

Have an answer ready for a negative finding. If a worker cannot use a negative pressure respirator, the options are a PAPR where they are medically able, a change of task, or engineering controls that remove the need. Deciding that in advance keeps a medical finding from becoming an employment problem.