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OSHA FAQs

Are seasonal or temporary workers exempt from the requirement for medical evaluations? (FR p. 1209-1210)
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No. The frequency and duration of respirator use and the worker’s term of employment, does not affect the requirement for medical evaluation.

Can a fit test for a respirator be performed before the initial medical evaluation has been completed? (FR p.1209)
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No. The initial medical evaluation must be conducted prior to fit testing to identify individuals whose health may be harmed by the limited amount of respirator use associated with fit testing.

Are employees who use filtering face piece respirators (dust masks) voluntarily (e.g., for employee comfort) also required to have medical evaluations? (FR p.1190, 1210)
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No. If the employer has determined that there is no hazard, and dust mask use is voluntary, then no medical evaluation is required. If employers allow voluntary use of this type of respirator, then they must provide the employee the information contained in Appendix D of the standard, and ensure that such respirator use will not itself create a hazard.

Does the employer have to use the exact language of the questionnaire in Appendix C if they choose to evaluate by medical questionnaire? (FR p. 1212)
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The language of Part A, Appendix C is mandatory if the employer chooses to medically evaluate by questionnaire.

If there is a single positive response on the questionnaire, does that automatically require a face-to-face visit with the PLHCP? (Professional Licensed Health Care Professional)(FR p. 1214)
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No, the scope of the medical evaluation is left to the discretion and professional judgment of the PLHCP (Professional Licensed Health Care Professional). There may be occasions where all that is needed is clarification of an issue.

Can an employee decline to be medically evaluated for the use of a respirator? (FR p.1220-1221)
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Paragraph (e)(1) requires the employer to provide a medical evaluation to an employee before the employee uses a respirator in the work place. Therefore, an employee cannot refuse to undergo medical evaluation and continue to use a respirator.

Who pays for the medical evaluation and any subsequent exams? (FR 1214)
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The employer must pay for the medical evaluation and any related expenses incurred by the employee during the evaluation, including travel costs.

Why does supplemental information need to be provided to the PLHCP? (FR p.1216-1217)
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When evaluating an employee’s medical limitations, the PLHCP may need to consider other workplace variables that may increase pulmonary and cardiovascular stress during respirator use.

Why is there no specific requirement to give the PLHCP a list of substances the employee may be exposed to? (FR 1215-1216)
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The company’s written respiratory program already specifies the exposure conditions that require the use of a respirator. A copy of the written program must be provided to the PLHCP instead. The program will provide the necessary information to the PLHCP without imposing an additional paperwork burden on employers.

Who is responsible for determining an employee’s ability to use a respirator? (FR p.1218)
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The responsibility rests with the employer. The PLHCP’s opinion regarding the employee’s medical ability to wear a respirator is an important element in making the final determination.

Does the PLHCP’s opinion on the employee’s medical ability to use a respirator have to be in writing? (FR p.1218)
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Yes.

Can the employer maintain a copy of the employee’s completed medical questionnaire? (FR p.1218 & 1282)
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No. The employer must maintain only the PLHCP’s written recommendation on an employee’s eligibility to wear a respirator. The completed questionnaire and PLHCP’s documented findings or diagnosis are confidential and must not be maintained by the employer.

Does the employer have to medically reevaluate the employee’s ability to wear a respirator on an annual basis? (FR 1219)
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No. There is no annual or periodic requirement for medical reevaluation. The standard lists four conditions that trigger medical reevaluation: an employee reports signs or symptoms related to the ability to wear a respirator; the PLHCP, administrator or supervisor determine it is necessary; information from the respiratory protection program indicates a need for reevaluation; or a change in workplace conditions substantially increases the physiological burden placed on the employee. (FR p.1219-1220)

Does logging into the site take away from the purchased number of evaluations?
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No. Only an employee completing the questionnaire counts as one of the purchased evaluations.

What happens if an employee takes the evaluation twice?
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Due to liability reasons, the employee’s certificate will become null and void and a note will be made in his/her record as such. It will also count against the number of purchased evaluations by the employer.

When an employee fails the questionnaire does that mean they cannot be certified?
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No. However, the employee will need to visit their health care professional in person.

What is the next step if an employee is not certified by the doctors on www.OSHAMed Eval.com?
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If the doctor is not able to certify them using the online format, it does not mean they cannot be certified, however, they will need to be seen in person by a health care professional, at the expense of the employer, for further evaluation.

How does the employer get a copy of the medical certificate for an employee?
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It is the responsibility of each individual employee to provide a copy of their medical certificate to their employer. If the certificate is lost, or if the employee had difficulty printing, please contact The Backup at (800) 822-9398 for a copy.


For more information email OSHA@TheBackup.com or call (800) 822-9398.
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