Reader Questions
Respirator exams not required annually
Question: A reader question in the January issue of Occupational Health Management addressed the need for annual respirator fit testing, saying the testing is necessary on an annual basis. But what about the respirator exam? Is that also necessary whenever a fit testing is required?
Answer: Respirator exams are not required on an annual basis, says Craig Moulton, an industrial hygienist with the Occupational Safety and Health Administration’s Office of Health Compliance Assistance in Washington, DC.
The distinction between "respirator exams" and "fit tests" is important for understanding when the tests are necessary. A "respirator exam" usually means the overall physical examination of an employee to ensure he or she is healthy enough to use a respirator without exceptional risk. A fit test is the examination that ensures the respirator fits properly on the worker’s face.
The OSHA respirator standard, 42 CFR Part 84, requires that all tight-fitting respirators be fit tested on the employee. (But fit tests are not necessary for any respirators worn voluntarily by the worker or for any type of loose-fitting respirator, even if it is required by OSHA or the employer.) The employee must pass a fit test before being initially cleared for respirator use, and then "an annual fit test is required after the initial fit test." Also, fit tests are required if the employee’s physical condition has changed in a way (i.e., weight gain or loss or injury) that could affect respirator fit. New fit tests also are necessary if the employee switches to a respirator with a face mask that fits differently.
For what some occupational health providers call "respirator exams," the requirements are different. Here is where some of the terminology can be confusing. OSHA says the employee must undergo an initial "medical determination" before being cleared for respirator use, but note that OSHA uses the term "medical determination" as the initial step, not "respirator exam" or "medical evaluation."
The medical determination required by OSHA begins with a written questionnaire in which the employee is asked about various health conditions. That can be followed by an actual medical evaluation, but it does not have to be.
"The medical evaluations are more event-driven, so they’re performed whenever the employee suffers a change in health, or if the physician notices something that could affect respirator use," Moulton says.
OHM enlisted help to understand the rule from William Patterson, MD, FACOEM, MPH, chairman of the Medical Policy Board at Occupational Health and Rehabilitation in Wilmington, MA. He explains that OSHA does not require any hands-on physical examination before respirator use unless the person reviewing the questionnaire concludes that an examination is warranted in order to reach a determination about the employee’s ability to safely use a respirator.
The standard requires the employer provide a copy of its written respirator program to the occupational health professional overseeing respirator use. Based on a review of that respirator program and/or individual employee questionnaires, the provider may recommend to the employer that a physical examination or pulmonary function test (PFT) be performed.
After that initial questionnaire review (and possible exams), subsequent questionnaire reviews are required by OSHA in these situations:
• The employee reports medical signs or symptoms related to the ability to use a respirator.
• The supervisor or respirator program administrator informs the employer that the employee needs to be reevaluated.
• Information from the respirator program, such as observations during fit testing, indicates a need for further evaluation.
• There is a change in workplace conditions, such as the addition of protective clothing that may result in substantial increase to the physiological burden placed on the employee.
Patterson notes, however, that these are only the minimum expectations of OSHA. With his own clients, Patterson often recommends more detailed and individualized examination of employees wearing respirators to ensure their safety.
While the initial medical questionnaire may be effective in detecting most conditions that could affect respirator use, he points out that some workers may not answer the questions truthfully if they fear job restriction.
Some conditions, such as hypertension, may be unknown to the worker and therefore would not be detected in the questionnaire but likely would be detected in a physical examination. A physical examination also offers the opportunity to monitor any health changes from a hazardous environment, reinforce the employer’s respirator safety principles, encourage smoking cessation, and obtain baseline assessments for occupational lung disease.
For those reasons, Patterson suggests taking a liberal approach to recommending physical examinations and PFTs when the initial questionnaire leaves any doubt as to the worker’s ability to use a respirator safely or when exposures and working conditions represent meaningful risk.
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