Respiratory medical evaluation required?
For disposable face filtering masks (N-95) that are required for use, are medical evaluations (pulmonary function testing) required?
Comments (9)

It depends on what the N95s are used for. Per 1910.134, PFTs are NEVER required unless the PLHCP requires it in order to sign off on your medical evaluation/examination. It doesn't come out and say that in the standard, but in my experience, many PLHCPs won't sign off until they do the PFT. Ultimately, it's up to the PLHCP to determine what additional tests/examinations may be necessary for them to make an accurate medical determination on the ability to wear a respirator.
However, there are some specific standards that DO require a PFT, such as OSHA's asbestos, cotton dust, benzene, silica, and formaldehyde standards (and maybe a few others). You may not be wearing an N95 in those situations, but those are examples of where a PFT would be specifically required by OSHA.
Even if not required by OSHA and the PLHCP doesn't require it, i'd still recommend it as a best practice.

I am glad you posted this. I was taught that a required N-95 is a respirator and thus requires at least a medical evaluation and compliance with 1910.134. Just last week, I was told by certified "ASP" guy in passing that it only applies to full face respirators. I shook my head "no" but he insisted. I insisted they are required. I have been distracted by other things so have not had time to check it out more.
I shall tell my friend to read this thread! Drew and Tim are right on, as I understood 1910.134. Thanks Guys!
I would add to Tim's excellent response that if you allow the use of N-95 respirators voluntarily, you need to follow "1910.134 Appendix D Information for Employees Using Respirators When Not Required under the Standard."
https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134
I work in construction. If the respirator meets the legal definition and contains a filtering face piece, yes. If not, by letter of interpretation, you still need to train them and document it even if it's "voluntary" or "employee provided." Justification for a violation for this scenario I believe is the general duty clause.