04 Aug OSHA Proposes Amendment of Certain Medical Evaluation Requirements in Its Respiratory Protection Standard

On July 1, 2025, OSHA issued a Notice of Proposed Rulemaking (NPRM) to remove some medical evaluation requirements in the Respiratory Protection Rule for filtering facepiece respirators (FFRs) and loose-fitting powered air-purifying respirators (PAPRs).

Comments on the proposed rule are due by Sept. 2, 2025.

Background

The current OSHA respiratory protection standard (29 CFR 1910.134) aims to protect workers from inhaling hazardous airborne contaminants (e.g., dusts, fogs, fumes, mists, gases, smokes, sprays, vapors) in the workplace by requiring employers to establish a comprehensive written respiratory protection program that includes procedures for:

• Respirator use;
• Medical evaluations;
• Training; and
• Fit testing.

A key component of this program is a medical evaluation, which determines whether employees are physically able to wear respirators safely. Before using a respirator, employees must be evaluated by a physician or other licensed health care professional using the mandatory OSHA medical questionnaire or an equivalent method to assess medical conditions that could interfere with respirator use, such as cardiovascular or pulmonary diseases. A medical evaluation helps ensure that any employee required to use a respirator can tolerate the physiological burden associated with respirator use, which is crucial to ensure worker safety.

Additionally, the standard mandates fit testing for tight-fitting facepiece respirators, training on proper use and maintenance, and ongoing monitoring of workplace conditions to ensure the selected respirators provide adequate protection. The program must be regularly evaluated for compliance and effectiveness, with records maintained for medical evaluations, fit testing and training, to reduce the risk of respiratory-related occupational illnesses.

Key Highlights

OSHA proposes that the initial medical evaluation requirements would only be removed for FFRs and loose-fitting PAPRs, and the medical evaluation requirements for any other air-purifying or supplied-air respirator would not be impacted and still apply. All other required provisions under the respiratory protection standard, including the following, continue to apply under this proposal:

• Hazard assessment;
• Selection of respiratory protection equipment;
• Fit testing;
• Training and education; and
• Maintenance and care.

OSHA states that this approach will allow employers to focus medical evaluations on employees for whom those evaluations are likely to be beneficial.

Additionally, OSHA states it acknowledges that respirators may negatively impact some workers’ health due to extreme exertion while wearing one, the impact on communication or ability to see, mental health concerns (e.g., claustrophobia) and other impacts on their quality of life. Consequently, OSHA has determined that this burden differs based on the type of respirator worn and, therefore, proposes an amendment to the medical evaluation requirements of the standard for FFRs and loose-fitting PAPRs. OSHA preliminarily concludes that there is not sufficient evidence to conclude that wearing FFRs and loose-fitting PAPRs without a prior medical evaluation can result in unavoidable adverse outcomes, and that the assumption that medical evaluation effectively detects risk for adverse effects from occupational use of FFRs and loose-fitting PAPRs is unproven.

Employer Takeaways

Employers should review their respiratory protection programs and determine how this proposed rule would impact their procedures. They should also continue to monitor the proposed rule and, if providing comments, do so by the due date.

Provided by Hilb Group