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OSHA FAQs
| Are seasonal or temporary workers
exempt from the requirement for medical evaluations? (FR p. 1209-1210) |
| . |
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) |
| . |
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) |
| . |
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) |
| . |
| 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) |
| . |
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) |
| . |
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) |
| . |
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) |
| . |
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) |
| .. |
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) |
| . |
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) |
| . |
| Yes. |
| Can the employer maintain a
copy of the employee’s completed medical questionnaire? (FR p.1218 & 1282) |
| . |
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) |
| . |
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? |
| . |
| No. Only an employee completing the questionnaire counts as one
of the purchased evaluations. |
| What happens if an employee
takes the evaluation twice? |
| . |
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? |
| . |
| 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? |
| . |
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? |
| . |
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.
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