In a July 1, 2025 Federal Register notice [90 FR 28463], the Occupational Safety and Health Administration (OSHA) proposed amendments to the medical evaluation requirements for certain types of respirators covered by the Respiratory Protection Standard [29 CFR 1910.134].
The medical evaluation requirements of the standard were originally put in place to determine whether employees are physically able to wear respirators safely. Before using one, employees are required to be evaluated by a physician or other licensed health care professional (PLHCP). The mandatory OSHA medical questionnaire, or an equivalent method, is required to assess medical conditions that could interfere with respirator use, such as cardiovascular or pulmonary diseases. This helps to assess if the associated physiological burden can be tolerated by the wearer.
OSHA is currently proposing to remove the medical clearance requirements for users of filtering facepiece respirators (FFRs) such as N95s and loose-fitting powered air-purifying respirators (PAPRs). Key points outlined by the Agency to support their proposed rule are summarized below.
- There is a lack of sufficient data showing that medical evaluations meaningfully reduce material impairment caused by wearing an FFR or PAPR. Epidemiological evidence demonstrating that medical evaluations effectively predict adverse outcomes for workers wearing these types of respirators is also absent.
- The body of literature is largely in consensus that any physiological burden of wearing FFRs and PAPRs is minimal during low to moderate exertion that is typical in the vast majority of workplaces.
- In the event that a user of a FFR or PAPR experiences related health symptoms, employers would be required to obtain a medical evaluation for these employees before they continue respirator use.
- All other required provisions under the Respiratory Protection Standard, including, but not limited to, the hazard assessment; selecting and providing respiratory protection equipment; fit testing, training, and education; and proper use, cleaning, care, and maintenance, would remain in effect.
OSHA estimates the collective cost savings for businesses, associated with the recommended changes, to be more than $600 million over ten years. This takes into account the cost of administering medical questionnaires, physicians reviews, and follow-up examinations. This change could also simplify compliance for employers and reduce delays in employee fit testing.
However, it’s important to consider how the proposed revisions might impact your organization and its respiratory protection program. For instance, training may need to be revised to communicate to employees who are no longer receiving a medical evaluation the importance of self-monitoring for conditions they may have experienced while using a respirator, as well as the value in reporting them. In addition, supervisors/managers will need to be more vigilant in recognizing when workers may be experiencing health issues.
The bottom line is that the main goal of an EHS program is to ensure worker safety. Even if the proposed rule is adopted, continuing to require medical evaluations for all respirator wearers may be the best option for your organization. Depending on circumstances, both a safety and liability perspective should be considered when deciding.
OSHA is accepting comments on the proposed changes, including the submission of information and data on the efficacy of medical evaluations preventing adverse health outcomes when using FFRs or loose-fitting PAPRs. The comment period was extended and they may now be submitted until November 1, 2025.
If you need assistance determining if this regulation and the potential changes affect you or your employees, or with implementing a Respiratory Protection Program at your facility—contact us!
This blog was written by Beth Graham, Safety Partners’ Director of Quality, Research, and Training.
