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

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 http://www.osha.gov.


November 16, 1998

Mr. David Taylor
OCAW Local 4-227
2306 Broadway
Houston, TX 77012

Dear Mr. Taylor:

This letter is in response to your letter to Ray Skinner of our Houston office. It was forwarded to our office for response. In your letter you have requested clarification of the medical evaluation provisions in the revised respiratory protection standard.

The respiratory protection standard requires the employer to provide a medical evaluation for each employee who is required to wear a respirator and also for those employees who voluntarily wear elastomeric facepieces for comfort or other reasons when there is no recognized hazard.

The standard does not prohibit an employee from using his own physician to evaluate his or her ability to wear a respirator. This arrangement may work fine for small employers, but can become difficult to administer for larger employers, because the employer would need to maintain contact with each physician and provide each physician with a copy of the supplemental information. If the employer chooses to use the employees' physicians as the PLCHP, then both the physicians' fees and employees' time must