October 28, 2004

Ms. Debra Pittman
Shands at AGH
801 SW 2^nd Avenue
Gainesville, FL 32601

Dear Ms. Pittman:

Thank you for your June 29, 2004 letter to the Occupational Safety and Health Administration (OSHA) regarding the requirements of the respiratory protection standard, 29 CFR 1910.134. Specifically, you ask about the requirements for medical evaluations for employees before training exercises. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

Scenario: Your facility provides training for emergency response team members to practice their skills and fire fighting techniques. During training, each member wears a "Level C" hooded protective suit with a powered air purifying respirator (PAPR). The suit is worn in the same manner as a true event during the exercises.

Question: Do these trainees need to be medically evaluated prior to training?

Response: Yes, these trainees would need to be medically evaluated prior to the training exercises. Paragraph (e) of the respiratory protection standard (29 CFR 1910.134(e)) requires employees to be medically evaluated prior to being fit-tested and their initial use of a respirator. A medical evaluation must be performed on every employee required to use a respirator, regardless of the duration and frequency of respirator use.

The purpose of a medical evaluation program is to ensure that any employee required to use a respirator can tolerate the physiological burden associated with such use, including the burden imposed by the respirator itself; musculoskeletal stress; limitations on auditory, visual, and odor sensations; and isolation from the workplace environment.

Various medical conditions can compromise an employee's ability to tolerate the physiological burdens imposed by respirator use, thereby placing the employee at increased risk of illness, injury, and even death. These medical conditions include cardiovascular and respiratory diseases, reduced pulmonary function caused by other factors (e.g., smoking or prior exposure to respiratory hazards), neurological or musculoskeletal disorders (e.g., ringing in the ears, epilepsy, lower back pain), and impaired sensory function (e.g., a perforated ear drum, reduced olfactory function). Psychological conditions, such as claustrophobia and severe anxiety, can also impair the effective use of respirators by employees and may also cause, independent of physiological burdens, significant elevations in heart rate, blood pressure, and respiratory rate that can jeopardize the health of employees who are at high risk for cardiopulmonary disease. For these reasons, a medical evaluation is required, even for the use of a PAPR.

Thank you for your interest in occupational safety and health. We hope you find this information helpful. 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. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,


Richard E. Fairfax, Director
Directorate of Enforcement Programs