The Department of Labor Occupational Safety and Health Administration (OSHA) published a Federal Register document for public comment on updating the medical clearance requirements for respiratory protection. According to the docket, OSHA is proposing to remove medical evaluation requirements in the Respiratory Protection Rule for filtering facepiece respirators (FFRs) and loose-fitting powered air-purifying respirators (PAPRs). OSHA is requesting comments through September 2, 2025. Voicing your thoughts – pros and cons – are strongly encouraged!
Filtering face piece respirators (FFRs) are disposable respirators that filter out airborne particles like dust, mist, and fumes, but do not protect against gases or vapors. One type of filtering face piece respirators are N95s. Fit testing and medical clearance as well as training are mandatory, when respirator use is required for the job. Fit testing and training will continue to be mandatory regardless of the decision related to medical clearance for FFRs and PAPRs.
The Standard has been in place since established in 1971 when OSHA adopted the American National Standards Institute (ANSI) standard Z88.2 1969, “Practices for Respiratory Protection,” as well as ANSI Standard K13.1 1969, “Identification of Gas Mask Canisters.” Eventually the standard was revised to 29CFR 1910.134, and it has been revised several times since; however, the purpose has always been to protect workers from inhaling hazardous airborne contaminants in the workplace as well as ensuring the respirator did not pose a health hazard.
29CFR 1910.134 requirement is establishing a comprehensive written respiratory protection program including key components,
- Hazard identification
- Respirator and cartridge selection,
- Procedures for respirator use, storage, and maintenance
- Training,
- Fit testing,
- Medical Evaluation for clearance,
- Program Evaluation
Because of the potential physical burden of wearing a respirator, medical evaluation by a licensed health care provider (LHCP) is necessary to determine whether employees are physically able to wear respirators safely. One of the recent standard changes was eliminating the requirement for pulmonary function testing (PFTs), except as required by certain OSHA standards, for example the cotton dust standard. It is left up to the discretion of the LHCP whether to include PFTs for clearance. It was controversial then, but while PFTs are valuable for many reasons, respirator use was not found to be one. In fact, no correlation was found related to PFT results and a person’s ability to wear a respirator.
OSHA now finds that there are not sufficient negative health impacts to warrant the medical requirement for FFRs and loose-fitting PAPRs. OSHA has preliminarily determined this burden differs based on the type of respirator worn and therefore proposes an amendment to the medical evaluation requirements of the standard for FFRs and loose-fitting PAPRs. Of note is that these are both popular respirators currently in use.
We don’t disagree that there is a health impact difference; however, the LHCP is aware of the type of respirator worn and takes this into consideration when deciding if use could exacerbate a medical condition or not. That said, even an employee who is medically cleared can experience a health concern when wearing a respirator. Medical clearance is not a guarantee. Rarely though is there an instance of not being able to wear a respirator (especially PAPRs). However, there are many instances of needing to control hypertension for example, or other health risks. Certainly, there may be temporarily restrictions for usage but not usually permanent restrictions – including wearing FFRs and PAPRs. We often identify health risks that need to be addressed.
OSHA also argues that neither type of respirator can be worn in extremely dangerous or life-threatening environments anyhow and so an employee would be able to immediately leave the area and report if they experience distress from using the respirator. This procedure should already be advised and specifically written into the respiratory protection plan since as already mentioned, even healthy employees without any medical history to warrant respirator use restrictions can experience a negative health effect. Instead under the proposed rule, employers would only be required to provide a medical evaluation after an employee exhibits symptoms potentially caused by respirator use. This places the burden on the employee who may or may not be willing to step forward.
We believe the benefits of health clearance by an LHCP are invaluable. Medical clearance for PAPRs and FFRs may be best for your employee population, or you may agree with OSHA that it is a waste of time and money. Your voice needs to be heard! Please log into the docket to let OSHA know your thoughts.
Honestly, we still hear from employees who years ago we identified with atrial fib, irregular heart rhythms, and crisis level blood pressure readings. We would not advise any respirator be worn until risk factors are considered and controlled.
Federal Register (includes the background information and sources)