Standard Interpretations - Table of Contents
• Standard Number: 1910.134; 1910.134(e)(2)(i)

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA"s interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA"s website at

October 16, 1998

Mr. Everett A. Beaujon
Director Safety and Health
Austin Industrial Inc.
P.O. Box 87888
Houston, TX 77287-7888

Dear Mr. Beaujon:

This is in response to your letter of May 14, addressed to Mr. Raymond Skinner in the Houston South Area Office of the Occupational Safety and Health Administration (OSHA). Your letter requested a review of the medical evaluation portion of your company's respiratory protection program to determine compliance with OSHA's new Respiratory Protection Standard, 29 CFR 1910.134. We apologize for the long delay in formulating this response.

In your letter, you mentioned that medical technicians conduct the medical evaluations under the direction of a designated licensed occupational physician. The medical technicians conduct and evaluate the occupational history questionnaire, a physical exam, and a pulmonary function test. As described in your letter, the physician performs a further medical evaluation when an employee fails the initial medical evaluation. Further, the physician reviews the medical program periodically.

The new Respiratory Protection Standard states that, "The employer shall identif