Amending the Medical Evaluation Requirements in the Respiratory Protection Standard for Certain Types of Respirators

The Essential Minerals Association supports OSHA's proposal to eliminate medical evaluation requirements for filtering facepiece respirators and loose-fitting powered air-purifying respirators. They argue that these respirators are comfortable, reduce the work of breathing, and that removing unnecessary medical evaluations will improve worker compliance and access without introducing additional risk.

The commenter, representing a company that manufactures reusable elastomeric respirators, opposes the proposed amendment because it removes medical evaluation requirements for filtering facepieces (FFRs) and powered air purifying respirators (PAPRs) without including reusable elastomeric half masks. They argue that their reusable masks offer superior comfort, lower breathing resistance, and better sealing properties than disposable FFRs, and they suggest that if the amendment proceeds, reusable elastomeric half masks should be included in the exemption.

The Associated General Contractors of America (AGC) opposes the proposed rule to amend medical evaluation requirements for certain respirators. They argue that the existing medical questionnaires and evaluations are essential for identifying underlying health conditions and ensuring worker safety, and that the proposed deregulation could increase liability and risk.

North America’s Building Trades Unions (NABTU) opposes the proposed rule to remove medical evaluation requirements for certain respirators, arguing that the change would create confusion, increase worker health risks, and remove an industry best practice. They advocate for maintaining the current standards based on feedback from the Advisory Committee for Construction Safety and Health (ACCSH).

The American Health Care Association and National Center for Assisted Living (AHCA/NCAL) supports the proposed rule to remove medical evaluation requirements for filtering facepiece respirators and loose-fitting powered air-purifying respirators. They argue that these requirements are no longer necessary in the post-pandemic era and that removing them will reduce administrative burdens, allowing staff to focus more on patient care.

Representatives from the University of Wisconsin Hospital and Clinics, Madison, support the proposal to eliminate medical evaluation requirements for filtering facepiece respirators and loose-fitting powered air-purifying respirators. They argue that these respirators impose minimal physiological burden and that their internal data shows a negligible rate of employee denials, making the current requirements an unnecessary administrative and financial burden.

The commenter expresses a mixed position, suggesting that the administration should proceed with removing medical evaluation requirements for loose-fitting PAPRs but should maintain the requirements for filtering facepiece respirators (N95s). They cite a study indicating that proper fit testing for N95s is necessary to prevent respiratory infections, while noting that CDC guidelines do not require fit tests for loose-fitting PAPRs.

Kelly Taylor and Alan R. Johnston, representing Damarco Solutions, LLC, oppose the proposed exemption from medical evaluation requirements for filtering facepiece respirators (FFRs). They argue that the proposal fails to account for workers using FFRs for prolonged periods or heavy work efforts and that the current screening process is vital for identifying medically compromised individuals who may suffer health risks.

Muhammad Raza Ejaz, an occupational health and safety professional, opposes the proposal to remove medical evaluation requirements for filtering facepiece respirators and loose-fitting PAPRs. He argues that these evaluations are essential for identifying underlying health conditions and maintaining consistency with international safety standards like ISO 45001, suggesting a tiered, risk-based approach as a compromise.