US Dept of Labor

Occupational Safety & Health AdministrationWe Can Help

Standard Interpretations - Table of Contents
• Standard Number: 1910.134(e)

October 16, 1998

Ms. Laila Freidmann, RN, COHN-S
Concentra Health Services
400 North Beach
Fort Worth, Texas 76111

Dear Ms. Freidmann:

This letter is in response to your requests of May 19th and July 14th; we apologize for the delay in responding to your requests. You asked several questions concerning the Occupational Safety and Health Administration's (OSHA) Respiratory Protection standard, 29 CFR 1910.134. Specifically, you asked about Appendix C, the Respirator Medical Evaluation Questionnaire (Questionnaire).

In your first letter, you asked if OSHA plans to make Part B of the Questionnaire mandatory, and, if not, how can a physician or other licensed health care professional (PLHCP) obtain the information in Part B. OSHA does not plan to make Part B of the Questionnaire mandatory. The PLHCP, moreover, has total discretion to add none, any, or all of the optional questions to the Questionnaire, or to add other questions to the Questionnaire that the PLHCP believes are necessary to perform the medical evaluation. In addition, the PLHCP has discretion regarding when Part B (but not Part A) is administered (e.g., after fit testing).

You also stated that the Questionnaire's numbering system is "challenging," and asked if the questions can be renumbered. OSHA's response is that a PLHCP or an employer can renumber the Questionnaire to suit their needs.

In your second letter, you expressed concerns regarding the follow-up medical examinations specified in 29 CFR 1910.134(e)(3)(ii). You asked if this paragraph requires the PLHCP to provide a "hands-on" medical examination to an employee who gives a positive response to questions 1 through 8 in Section 2, Part A of the Questionnaire, or when the employee's initial medical examination demonstrates the need for a follow-up medical examination. Again, the PLHCP has total discretion in determining the scope and form of the follow-up medical examination. A positive response to the Questionnaire, for example, does not automatically require a face-to-face visit with the PLHCP or a hands-on medical examination. The PLHCP may conduct a hands-on medical examination, perform additional diagnostic tests, or clarify medical issues in a telephone consultation with the employee. Therefore, while PLHCPs are free to administer a hands-on medical examination after reviewing responses to the Questionnaire, and prior to making a referral or obtaining a consultation, they are not required to do so by the standard.

With regard to your question about supplemental information on the medical-evaluation provisions of the standard, there are several documents currently available that provide this information. A document titled "Questions and Answers on the Respiratory Protection Standard" contains over 70 pages of questions and answers on the entire standard, including the medical-evaluation provisions. The OSHA Compliance Directive, CPL 2-0.120, titled "Inspection Procedures for the Respiratory Protection Standard," also provides information on the entire standard. In addition, the "Small Entity Compliance Guide" is available. All of these documents can be accessed on OSHA's Web site at; you may also obtain printed copies of these documents from OSHA's Publications Office by telephoning (202) 219-4667.

Thank you for your interest in occupational safety and health. If you have any further questions, please telephone our Office of Health Compliance Assistance, at (202) 219-8036.


Richard E. Fairfax
Acting Director
Directorate of Compliance Programs

Standard Interpretations - Table of Contents

Thank You for Visiting Our Website

You are exiting the Department of Labor's Web server.

The Department of Labor does not endorse, takes no responsibility for, and exercises no control over the linked organization or its views, or contents, nor does it vouch for the accuracy or accessibility of the information contained on the destination server. The Department of Labor also cannot authorize the use of copyrighted materials contained in linked Web sites. Users must request such authorization from the sponsor of the linked Web site. Thank you for visiting our site. Please click the button below to continue.