FREQUENTLY ASKED QUESTIONS
Here are some of the most common questions we’ve heard from our experience with employers and safety service providers. Have a question you don’t see here?
WHO NEEDS RESPIRATOR CLEARANCE?
Any employee who is required by their employer to use a respirator at work.
WHEN IS RESPIRATOR CLEARANCE REQUIRED?
OSHA states that the respirator Medical Evaluation Questionnaire (MEQ) must be filled out, submitted, and cleared prior to respirator fit testing. The MEQ is used to determine if respirator use could have adverse effects on the wearer, so Respirator Clearance must be obtained before donning a respirator, even for the fit-testing process.
DO YOU NEED RESPIRATOR CLEARANCE FOR VOLUNTARY RESPIRATOR USE?
Respirator Clearance is required any time an employee is using a respirator at work, including when that use is voluntary. The only exception to this rule is when an employee is using a filtering-facepiece, disposable respirator.
WHO CAN REVIEW AN MEQ TO PROVIDE RESPIRATOR CLEARANCE?
An MEQ must be evaluated by a PLHCP (Physician or other Licensed Health Care Professional), defined by OSHA as a healthcare provider that is licensed to independently practice medicine within their state. Because state medical boards are in control of who can independently practice medicine in each state, the level of licensure required will be different according to state guidelines.
IS RESPIRATOR CLEARANCE REQUIRED ANNUALLY?
There are no expiration dates or time limits associated with Respirator Clearance unless specifically stated by the PLHCP providing the judgement. OSHA has specified that an employee must receive updated Respirator Clearance whenever there are changes to the employee’s work environment, job description, respirator usage, or if the employee experiences significant health changes.
Because of the personal nature of changes in health, most employers don’t rely on their workforce to self-report significant health changes. These employers require employees to receive Respirator Clearance every year along with the required annual fit-test.
HOW CAN EMPLOYERS PROVIDE RESPIRATOR CLEARANCE FOR THEIR EMPLOYEES?
There are several ways that an employer can obtain Respirator Clearance for its workforce. The two most common ways are sending employees to an occupational health clinic or having employees fill out a paper MEQ that is faxed to a healthcare provider for review at a later time.
WHAT ARE THE RECORD STORAGE REQUIREMENTS FOR THE MEQ?
OSHA requires that the MEQ and MEQ results be retained for 30 years from the last day of employment by an employee. This means that if an employee fills out their first MEQ in 2012, then works for your company until their retirement in 2030, you would be responsible for securely retaining the initial MEQ until 2060. The storage of the MEQ is also subject to HIPAA standards for securing and retaining PHI (Protected Health Information).
CAN AN EMPLOYEE OBTAIN RESPIRATOR CLEARANCE IN THEIR OFF HOURS?
OSHA mandates that the Respirator Clearance process be conducted during work hours (on the clock), and that the process is paid for by the employer. The need to minimize time away from work and the cost associated with Respirator Clearance is a large contributor to the prevalence of online solutions.
DO I NEED RESPIRATOR CLEARANCE FOR AN N95 OR FILTERING-FACEPIECE RESPIRATORS?
As with all tight-fitting respirators, N95s (and other filtering-facepiece respirators) require Respirator Clearance if use is required by the employer.
DO I NEED RESPIRATOR CLEARANCE FOR A HOOD TYPE POWERED AIR-PURIFYING RESPIRATOR (PAPR)?
Although a hood type PAPR isn’t tight-fitting and doesn’t require a fit-test, Respirator Clearance is still required if use of the PAPR is required by the employer.
DO I NEED A PULMONARY FUNCTION TEST (PFT) TO USE A RESPIRATOR?
PFTs are not a component of the Respiratory Protection Standard and are instead specific to different substance standards.