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.

July 30, 2018

John J. Koehler, MD
750 Orth Road
Caledonia, Illinois 61011


Dear Dr. Koehler:

Thank you for your letter to the Occupational Safety and Health Administration’s (OSHA) Directorate of Enforcement Programs, regarding OSHA’s Respirable Crystalline Silica (silica) standards, 29 CFR 1910.1053 and 29 CFR 1926.1153, and specifically pulmonary function testing (PFT). This letter constitutes OSHA’s interpretation only of the requirements herein and may not be applicable to any situation not delineated within your original response. Your question has been summarized below, followed by our reply.

Question: Are board certified occupational medicine physicians able to perform spirometry testing under the silica standards?

Reply: The silica standards specifically require that PFT be administered by a technician who holds a current certificate from a National Institute for Occupational Safety and Health (NIOSH)-approved spirometry course. Under the silica standards, any medical personnel (e.g., physicians, physician assistants, nurses) who administers PFTs is viewed as a technician. Therefore, anyone who administers PFTs under the silica standards must hold a current certificate from a NIOSH-approved spirometry course regardless of other certifications, experience, or education. For more information about NIOSH-approved spirometry training programs, please visit NIOSH’s spirometry website: https://www.cdc.gov/niosh/topics/spirometry/1

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the Agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA’s website at http://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.



Thomas Galassi, Director
Directorate of Enforcement Programs


[1] NIOSH approves a spirometry training course if it meets the minimum OSHA/NIOSH criteria for performance of spirometry testing in the cotton textile industry. Since these course criteria are based on recommendations from the American Thoracic Society and the European Respiratory Society, they are applicable to spirometry testing in all industries.