OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 26, 1981

Ms. Cindy Nelson, RRT
Technical Director
Charlotte Chest Laboratory
Suite 215
1928 Randolph Road
Charlotte, N.C. 28207

Dear Ms. Nelson:

This is in response to your inquiry to Mr. Gail Brinkerhoff of my staff concerning training requirements for persons who administer the pulmonary function testing required by the cotton dust standard, 29 CFR 1910.1043. Please accept my apology for the delay in replying.

You quoted the opening paragraph in main division IV of Appendix D to the cotton dust standard. You asked whether the only way of becoming certified to administer the pulmonary function testing required by the cotton dust standard was to attend a course presenting the 16 hours of training mentioned in the paragraph. You then requested special consideration for OSHA certification without taking the 16 hours of training.

At the outset, we wish to point out that, contrary to the impression the passage you quoted may leave, OSHA does not certify persons who satisfactorily complete training in pulmonary function testing. Instead, the procedure is to require the institution providing the training to issue a certificate to each trainee who satisfactorily completes the course.

The course must be approved by the National Institute for Occupational Safety and Health (NIOSH). In this regard the cotton dust standard provides at 29 CFR 1910.1043(h)(1)(iii) that, "persons other than licensed physicians, who administer the pulmonary function testing required by this section shall complete a NIOSH approved training course in spirometry."

Although we can appreciate the extensive training, education and experience you have undertaken in order to become a registered respiratory therapist, you must complete a NIOSH approved training course in spirometry if you will be performing the measurements of forced vital capacity (FVC) and forced expiratory volume in 1 second (FEV1) that are required by the cotton dust standard. The NIOSH approved training courses in spirometry are very specialized courses which are designed to develop a high degree of uniformity in pulmonary function test results. The goal of these courses is to assure that any technician testing a particular subject's pulmonary functions would obtain the same results.

We appreciate the opportunity to address your concerns. If we can serve you in the future, we shall be glad to do so.


Bruce Hillenbrand
Acting Director, Federal
Compliance and State Programs