Recently OSHA provided more information regarding the maintenance of medical evaluation and fit test records as required by the Respiratory Protection Standard, 29 CFR 1910.134. Listed below are several questions and answers from the OSHA interpretation letter.
Question 1: Should respirator medical evaluation questionnaires be maintained or destroyed by the physician or licensed healthcare provider (PLHCP) after the completion of the medical evaluation?
Answer: The respiratory protection standard requires an employer to retain and make available records of medical evaluations (including medical determinations and the questionnaires) in accordance with 29 CFR 1910.1020, Access to Employee Medical and Exposure Records. All information from the questionnaire and/or the medical exam is confidential, and arrangements must be made by the employer to ensure it is kept confidential. Usually, the employer will have the records maintained by the PLHCP.
Question 2: Should the employer ensure that respirator medical evaluation questionnaires are not kept with employee records?
Answer: Yes. Medical records are to be kept confidential and separate from other employee records (e.g., timesheets, training).
Question 3: Is the employer only required to maintain the written recommendation regarding an employee’s medical determination from the PLHCP in accordance with 1910.134(e)(6)?
Answer: All medical records (including the medical determination) must be kept and made available by the employer as required by 1910.134(m)(1) and 1910.1020.
Question 4: Are there any additional recordkeeping requirements for fit test results that would prevent the department from destroying historical fit test records, as long a current test record is maintained?
Answer: There are no additional requirements. 29 CFR 1910.134(m)(2)(ii) only requires fit testing records to be retained by the employer until the next fit test is administered.
For more information on this topic, visit the OSHA website.
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