Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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

December 22, 1998

Dr. Kendall Green, M.D. Ph.D.
American Airlines
P.O. Box 582809
Tulsa, OK 74158-2809

Dear Dr. Green:

This is in response to your letter dated October 19, concerning the Occupational Safety and Health Administration's (OSHA's) revised Respiratory Protection Standard, CFR 1910.134. We apologize for the long delay.

In your letter you ask several questions concerning the medical provisions of the respiratory standard. A medical evaluation consists of the administration of a medical questionnaire (mandatory) or provision of a physical examination that elicits the same information as the questionnaire, prior to the employee using a tight-fitting respirator in the workplace. When the questionnaire is used, the entire form must be completed by the employee. The employer can add questions, but the employer cannot delete questions. The employer must obtain a written recommendation as to the employee's ability to wear a respirator from the Physician or other Licensed Health Care Professional (PLHCP). The employer must ensure all of these provisions are met prior to allowing an employee to use a respirator where respirators are required. If the employee is required to wear a full face emergency SCBA under potentially IDLH conditions, the employer is responsible for providing a full respiratory protection program to these users, which includes a complete medical evaluation.

Thank you for your interest in safety and health. If you have any further questions, please feel free to contact OSHA's Office of Health Compliance Assistance at (202) 693-2190.


Richard E. Fairfax
Directorate of Compliance Programs