An employer provided truck drivers with North 7900 series air-purifying disposable mouthpiece respirators for escape-only use at oil and gas refineries. The manufacturer's manual warned about physical conditions that might preclude respirator use, which seemed to conflict with an earlier OSHA interpretation saying medical evaluations were not required for escape-only respirators. The employer asked OSHA to clarify.
OSHA confirmed that, per its Inspection Procedures directive (June 26, 2014) and its March 8, 1999 letter to Ms. Mary Kiester, an employee who is only expected to wear a NIOSH-approved escape-only device does not need to complete a medical evaluation under 29 CFR 1910.134. The exception is self-contained breathing apparatus (SCBA), which is used to enter immediately dangerous atmospheres and does require medical evaluation. OSHA also flagged that truck drivers may fall under the HAZWOPER standard (29 CFR 1910.120) depending on their exposure during loading and unloading operations.
Skipping the medical evaluation does not mean skipping the program. Under 29 CFR 1910.134(c)(1), employers must "establish and implement those respirator program elements necessary for proper use," including a written program and training on correct use, cleaning, storage, and maintenance. OSHA specifically noted employees need education about the "psychological and physiological burdens" of respirator use, such as claustrophobia, anxiety, and aggravation of pre-existing cardiovascular or respiratory conditions. Employers may also voluntarily require medical evaluations at company expense.
On manufacturer manuals, OSHA said the information in a user's manual may exceed OSHA's requirements, and that is not prohibited; employers retain discretion to implement procedures that go beyond the OSHA standard.