A question came to OSHA asking whether board certified occupational medicine physicians can perform spirometry testing required by the respirable crystalline silica standards' medical surveillance provisions.
OSHA's answer: only if they hold the NIOSH certificate. The standards mandate that any individual administering a pulmonary function test must hold a current certificate from a National Institute for Occupational Safety and Health (NIOSH)-approved spirometry course (29 CFR 1910.1053(i)(2)(iv); 29 CFR 1926.1153(h)(2)(iv)). Under these requirements, all medical personnel administering tests — including physicians, physician assistants, and nurses — are considered technicians.
OSHA quoted its directive directly: anyone who administers PFTs under the silica standards must hold a current certificate from a NIOSH-approved spirometry course regardless of other certifications, experience, or education. The NIOSH approval criteria derive from standards established for the cotton textile industry, based on recommendations from the American Thoracic Society and European Respiratory Society, which OSHA notes makes them applicable across all industries.