Whether the respiratory protection medical evaluation may consider factors beyond respirator use

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.

August 1, 2025

Robert K. McLellan, MD, MPH, FACOEM
Professor, Active Emeritus
Geisel School of Medicine
The Dartmouth Institute of Health Policy and Clinical Practice
74 College St
Vail Building, Room 715
Hanover, NH 03755

Philip Harber, MD, MPH, FACOEM
Adjunct Professor of Public Health
University of Arizona
Professor, Emeritus
University of California, Los Angeles

Dear Drs. McLellan and Harber:

29 CFR 1910.134(e)(5)-- Respirator Fit-Testing

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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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.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 Instruction CPL 2-2.29 October 27, 1980 Office of Compliance Programming

Subject: 29 CFR 1910.134(e)(5)--Respirator Fit-Testing

A. Purpose. This instruction provides guidance regarding enforcement policy for the respirator fit-testing requirement under by 29 CFR 1910.134(e)(5).

B. Scope. This instruction applies OSHA-wide.

C. Action. OSHA Regional Administrators and Area Directors shall assure that violations resulting from use of improper fit-testing procedures are cited as set forth in F. of this instruction.

Respiratory protection medical evaluations: additional evaluations; use of employee's physician; testing; medical removal; and confidentiality.

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.

October 21, 2004

Mr. Gregory Norton
3708 Lake Arrowhead Drive
Harvey, LA 70058

Dear Mr. Norton: