Employer's Guide to OSHA Respirator Medical Evaluations (2026)
Dr. Nader Mikhail, MD
18 min read
Published: February 11, 2026
Key Takeaways for Employers
- OSHA 1910.134 requires medical evaluations BEFORE employees can use respirators
- Evaluations must be reviewed by a licensed PLHCP (physician or healthcare professional)
- Online evaluations are OSHA-compliant and save 70-85% vs clinic visits
- 98% of employees receive instant clearance; 2% require PLHCP review
- Employers must maintain records for duration of employment + 30 years
If your employees use respirators in the workplace, you're legally required to ensure they receive a respirator medical evaluation before they can be assigned respiratory protection. This isn't optional—it's a federal OSHA requirement under 29 CFR 1910.134, and violations can result in citations ranging from $15,625 to $156,259 per incident.
This comprehensive guide explains everything employers need to know about respirator medical evaluations: what they are, who needs them, how the process works, and how to achieve compliance efficiently while minimizing costs. Whether you manage 5 employees or 5,000, this guide will help you build a compliant respiratory protection program.
What is a Respirator Medical Evaluation?
A respirator medical evaluation is a health screening that determines whether an employee can safely wear a respirator. Wearing respiratory protection places physiological stress on the body—particularly the cardiovascular and respiratory systems. Certain medical conditions can make respirator use dangerous or even life-threatening.
The evaluation uses the OSHA Appendix C questionnaire, which asks about medical history, current health conditions, and the type of respirator and work conditions. A licensed healthcare professional (PLHCP) reviews the responses and determines whether the employee is:
- Cleared for respirator use
Employee can proceed with fit testing and respirator assignment
- Cleared with restrictions
Employee can use certain respirator types or under specific conditions
- Not cleared
Employee cannot use the specified respirator type; alternatives may be recommended
OSHA 1910.134 Requirements Explained
OSHA's Respiratory Protection Standard (29 CFR 1910.134) establishes comprehensive requirements for respiratory protection programs. Section 1910.134(e) specifically addresses medical evaluation requirements:
Core OSHA Requirements for Medical Evaluations:
- 1. Timing
Medical evaluation must occur BEFORE fit testing and BEFORE the employee is required to use a respirator
- 2. Questionnaire
Must use OSHA's mandatory Appendix C questionnaire (or Appendix C equivalent)
- 3. PLHCP Review
A licensed healthcare professional must review questionnaire responses and make clearance determination
- 4. Confidentiality
Employee medical information must be kept confidential; employers receive only clearance status
- 5. Record Retention
Medical evaluation records must be maintained for duration of employment plus 30 years
The employer must also provide the PLHCP with specific information about the employee's job duties, including the type of respirator, frequency of use, expected physical work effort, and any additional protective equipment required.
Who Needs Respirator Medical Evaluations?
Any employee required to wear a respirator in the workplace must receive a medical evaluation. This includes:
Mandatory Respirator Use
- Construction workers (silica, lead, asbestos exposure)
- Manufacturing employees (chemical, dust hazards)
- Healthcare workers (N95 for TB, COVID, etc.)
- Painters and coating applicators
- Welders and metal fabricators
- Emergency responders
- Laboratory workers
Voluntary Use (N95 Filtering Facepieces)
If employees voluntarily choose to wear filtering facepieces (N95, N99, N100) and their use is NOT required by the employer:
- Medical evaluation is NOT required
- Fit testing is NOT required
- Employer MUST provide Appendix D information
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The Respirator Medical Evaluation Process Step-by-Step
Whether you choose clinic-based or online respirator medical evaluation, the process follows these steps:
Employer Provides Job Information
Before the evaluation, the employer provides information about the type of respirator, frequency of use, expected physical exertion, and workplace conditions to the PLHCP.
Employee Completes Questionnaire
The employee completes the OSHA Appendix C questionnaire, answering questions about medical history, current health conditions, and any symptoms related to respirator use.
PLHCP Reviews Responses
A licensed healthcare professional reviews the questionnaire. For 98% of employees, responses indicate no concerns and clearance is granted immediately. The remaining 2% require additional PLHCP review.
Clearance Determination
The PLHCP issues a written recommendation stating whether the employee is cleared, cleared with restrictions, or not cleared for respirator use.
Employer Receives Results
The employer receives only the clearance status—not the employee's medical information. The employee receives their full results and certificate.
Proceed to Fit Testing
Once cleared, the employee can proceed to respirator fit testing. The medical clearance certificate should be kept on file for compliance documentation.
Online vs Clinic Respirator Medical Evaluations
Employers have two options for obtaining respirator medical evaluations: traditional clinic visits or online platforms. Both are OSHA-compliant when properly administered, but they differ significantly in cost, convenience, and efficiency.
| Factor | Clinic-Based | Online Platform |
|---|---|---|
| Cost per Evaluation | $75-150 | $17-22 |
| Time Required | 2-4 hours (with travel) | 15 minutes |
| Scheduling | Appointment required | Available 24/7 |
| Results Timing | 1-3 business days | 98% instant |
| PLHCP Review | Yes | Yes |
| OSHA Compliant | Yes | Yes |
| Digital Records | Varies | Included (30-year retention) |
| Team Dashboard | No | Yes - real-time tracking |
Online evaluations use the same OSHA Appendix C questionnaire and provide the same PLHCP oversight as clinic visits. The key difference is efficiency: employees complete evaluations in 15 minutes from any device, anywhere, without scheduling appointments or losing work time.
Cost Comparison: Saving 70-85% on Respirator Medical Evaluations
The true cost of respirator medical evaluations goes beyond the direct fee. Consider this comparison for a company with 50 employees requiring annual evaluations:
Clinic-Based (50 employees)
- Evaluation fees
$135 avg × 50 = $6,750
- Lost productivity
3 hrs × $30/hr × 50 = $4,500
- Mileage/travel
$20 × 50 = $1,000
- Admin time
20 hrs × $35/hr = $700
Total: $12,950/year
Online Platform (50 employees)
- Evaluation fees
$20 × 50 = $1,000
- Lost productivity
0.25 hrs × $30/hr × 50 = $375
- Mileage/travel
$0
- Admin time
2 hrs × $35/hr = $70
Total: $1,445/year
View our volume-based pricing to calculate your exact savings. Larger organizations (100+ employees) can save $17-20 per evaluation with volume discounts.
Frequently Asked Questions
How much does a respirator medical evaluation cost?
Respirator medical evaluations typically cost $75-150 at occupational health clinics. Online evaluations through platforms like RespiratorTest.com cost $17-22 per evaluation depending on volume, saving employers 70-85% on direct costs plus eliminating travel time and productivity loss.
How often do employees need respirator medical evaluations?
OSHA does not specify a fixed re-evaluation period. However, employers must provide additional evaluations when: the employee reports signs/symptoms related to respirator use, a PLHCP recommends re-evaluation, observations suggest need for re-evaluation, or there are changes in workplace conditions. Industry best practice recommends annual evaluations aligned with fit testing requirements.
Can respirator medical evaluations be done online?
Yes, OSHA allows online respirator medical evaluations. The evaluation uses the same OSHA Appendix C questionnaire whether completed on paper or electronically. Online platforms provide PLHCP review of flagged responses, making them fully OSHA 1910.134 compliant while offering convenience and cost savings.
What happens if an employee fails the respirator medical evaluation?
If an employee is not cleared for respirator use, the PLHCP may recommend: additional medical examination, use of a different respirator type (such as a PAPR instead of tight-fitting), work restrictions, or workplace modifications. Employers cannot require employees to wear respirators if they are not medically cleared.
Do I need respirator medical evaluations for N95 masks?
Yes, if N95 use is mandatory (required by employer). OSHA requires medical evaluations for all tight-fitting respirators when use is mandatory. If N95 use is voluntary only, medical evaluation is not required, but employers must provide Appendix D information to employees about voluntary use.
Who can perform respirator medical evaluations?
Respirator medical evaluations must be reviewed by a PLHCP (Physician or other Licensed Health Care Professional). This includes physicians (MD/DO), nurse practitioners, and physician assistants who are legally permitted to provide medical evaluations in their jurisdiction. At RespiratorTest.com, all evaluations are reviewed by Dr. Nader Mikhail, MD.
Getting Started with Online Respirator Medical Evaluations
Ready to streamline your respirator compliance program? Here's how to get started with RespiratorTest.com:
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NM
Dr. Nader Mikhail, MD
Medical Review Officer
Board-certified physician with expertise in occupational medicine. Dr. Mikhail oversees all medical evaluations at RespiratorTest.com, ensuring OSHA compliance and accurate medical determinations.