The Occupational Safety and Health Administration (OSHA) does not specifically mandate that respirator medical evaluations be completed annually. However, it does state that employers bear the responsibility of identifying if an employee exhibits any signs or symptoms related to their ability to wear a respirator. In such cases, the employee is required to complete the evaluation again.
According to OSHA guidance, under clause 1910.134(e)(7), additional medical evaluations complying with the requirements of this section should be provided by the employer under certain conditions. The specific OSHA guidance in states:
1910.134(e)(7)
At a minimum, the employer shall provide additional medical evaluations that comply with the requirements of this section if:
1910.134(e)(7)(i)
An employee reports medical signs or symptoms that are related to ability to use a respirator;
1910.134(e)(7)(ii)
A PLHCP, supervisor, or the respirator program administrator informs the employer that an employee needs to be reevaluated;
1910.134(e)(7)(iii)
Information from the respiratory protection program, including observations made during fit testing and program evaluation, indicates a need for employee reevaluation; or
1910.134(e)(7)(iv)
A change occurs in workplace conditions (e.g., physical work effort, protective clothing, temperature) that may result in a substantial increase in the physiological burden placed on an employee.
OSHA also published a standard interpretation letter that reads "The respiratory protection standard requires an initial medical evaluation to determine the employee's ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace. At a minimum the employer must provide additional evaluations if an employee shows signs or symptoms that are related to their ability to wear a respirator. There is not a specific annual requirement for medical evaluations in the standard. However, the physician or other licensed healthcare provider (PLHCP) may prescribe annual tests to ensure employees' continued ability to wear a respirator.". This means that after the initial screening, the burden is on the employer to notice things that may impact an employee's ability to wear a respirator such as a change in weight, breathing problems, heart trouble, change in physical burden of the job etc.
Our medical director requires our medical evaluation to expire after one year because we have no way of knowing when an employee's situation changes, and having the employees perform an annual screening is a relatively low-cost way to help limit claims that an employer did not meet the OSHA standard because they did not re-evaluate an employee frequently enough. This approach helps us to be proactive in recognizing any changes, such as a change in weight, breathing problems, heart trouble, or the physical burden of the job that may impact an employee's ability to wear a respirator.