PLHCP Qualifications for Respirator Medical Evaluations: Who Can Perform Them?
Complete guide to PLHCP qualifications for respirator medical evaluations. Learn who qualifies as a PLHCP, state-by-state variations, credential verification, and how online PLHCP oversight models ensure OSHA compliance.
Published January 24, 2025 • Updated November 19, 2025
What Does PLHCP Stand For?
PLHCP stands for Physician or Other Licensed Healthcare Professional. Under OSHA 1910.134, a PLHCP is qualified to conduct respirator medical evaluations and includes physicians (MD or DO), physician assistants (PA), nurse practitioners (NP), and other licensed professionals authorized to provide medical clearance.
Get PLHCP-reviewed evaluation from $17 →Quick Answer: Who Qualifies as a PLHCP?
OSHA defines PLHCPs as physicians (MD or DO), physician assistants (PA), advanced practice registered nurses (APRN/NP), or other licensed healthcare professionals whose legally permitted scope of practice includes conducting medical evaluations. PLHCPs must be licensed, knowledgeable about respirator use demands, and able to make medical clearance decisions. OSHA does not require specialty training in occupational medicine.
When employers implement respiratory protection programs, one of the most common questions is: "Who can perform the medical evaluations?" OSHA's answer is clear—evaluations must be conducted by a PLHCP (Physician or other Licensed Healthcare Professional).
But what exactly does "Licensed Healthcare Professional" mean? Can your company nurse perform evaluations? What about a physician assistant? Does the doctor need to be board-certified in occupational medicine? And how do online medical evaluation services ensure qualified PLHCPs review questionnaires?
This guide answers these questions and explains everything you need to know about PLHCP qualifications for respirator medical evaluations, including OSHA 1910.134 compliance requirements. For organizations managing comprehensive respiratory protection programs, see our complete program management solution. If you're evaluating different compliance platforms, our respirator compliance software comparison can help you choose the right solution.
What Does PLHCP Mean?
PLHCP stands for Physician or other Licensed Healthcare Professional. This is OSHA's terminology for medical professionals qualified to conduct respirator medical evaluations under 29 CFR 1910.134.
OSHA's formal definition (from 1910.134(b)):
Physician or other licensed healthcare professional (PLHCP) means an individual whose legally permitted scope of practice (i.e., license, registration, or certification) allows him or her to independently provide, or be delegated the responsibility to provide, some or all of the healthcare services required by this section.
In plain English: A PLHCP is a medical professional who is:
- Licensed, registered, or certified
Holds active credentials in their profession
- Legally permitted to conduct medical evaluations
Their scope of practice includes medical assessments and clearance decisions
- Able to independently make decisions
Can determine medical fitness for respirator use without requiring another professional's approval
Who Qualifies as a PLHCP?
Based on OSHA's definition and state licensing laws, the following medical professionals typically qualify as PLHCPs:
Physicians (MD / DO)
Qualifies: All 50 states
Training: Medical school, residency, state medical board license
Scope: Full authority to conduct medical evaluations and make clearance decisions
Specialties: Any specialty (family medicine, internal medicine, occupational medicine, emergency medicine, etc.)
Physician Assistants (PA)
Qualifies: All 50 states
Training: Master's degree in physician assistant studies, national certification, state license
Scope: Can conduct medical evaluations; some states require physician supervision or collaboration
Authority: Permitted to make medical clearance decisions within scope of practice
Nurse Practitioners (NP / APRN)
Qualifies: All 50 states (with state-specific variations)
Training: Master's or doctoral degree in nursing, national certification, state advanced practice license
Scope: Can conduct medical evaluations; practice authority varies by state (full, reduced, or restricted)
Authority: Permitted to make independent medical clearance decisions in most states
Other Licensed Professionals
May qualify: State-dependent
Examples: Occupational health nurses (OHN), clinical nurse specialists (CNS), licensed independent practitioners
Requirement: Must verify state law permits independent medical evaluation authority
Note: Registered nurses (RN) typically do NOT qualify unless they hold advanced practice credentials (NP/APRN)
What Do PLHCPs Evaluate?
PLHCPs conducting respirator medical evaluations review the employee's OSHA Appendix C questionnaire and determine if the employee can safely use a respirator based on:
Medical Considerations
| Health Category | What the PLHCP Assesses |
|---|---|
| Cardiovascular Health | Heart disease, chest pain, high blood pressure, heart attacks—conditions that increase cardiac demand while wearing respirators |
| Respiratory Health | Asthma, COPD, shortness of breath, lung disease—conditions that affect breathing capacity when respirator increases work of breathing |
| Psychological Factors | Claustrophobia, panic attacks, anxiety—conditions that may be triggered by wearing tight-fitting respirators |
| Physical Capabilities | Ability to perform work tasks while wearing respirator, communication needs, vision/hearing limitations |
| Work Environment | Temperature extremes, physical exertion level, duration of respirator use, job task demands |
| Medications | Drugs affecting heart rate, breathing, consciousness, or ability to respond to emergencies |
PLHCP Clearance Decisions
After reviewing the questionnaire, the PLHCP makes one of three decisions:
- Full Medical Clearance
Employee is medically able to use any respirator type without restrictions
- Clearance With Restrictions
Employee can use certain respirator types only (e.g., PAPR instead of N95, limited wear time, specific work conditions)
- Medical Clearance Denied
Employee is not medically able to use respirators; may require additional medical evaluation, treatment, or reassignment
State-by-State Variations in PLHCP Authority
While OSHA's PLHCP definition is federal, healthcare professional licensing is governed by state law. This creates some variation in who can perform respirator evaluations.
Nurse Practitioner Practice Authority
Nurse practitioners face the most state-by-state variation:
| Practice Authority Level | States | Can Perform Respirator Evals? |
|---|---|---|
| Full Practice Authority | 26 states + DC (as of 2025) | Yes, independently |
| Reduced Practice Authority | 14 states | Yes, with physician collaboration agreement |
| Restricted Practice Authority | 10 states | Yes, with physician supervision |
PLHCP vs Occupational Health Physician: What's the Difference?
Many employers mistakenly believe they need an occupational health physician or occupational medicine specialist to perform respirator evaluations. This is not required.
Key Differences
Occupational Health Physician
Specialty training in workplace health
Board certification in occupational medicine (optional)
Deep knowledge of workplace hazards
Often employed by large companies or occ health clinics
Cost: $150-300 per evaluation
PLHCP (for Respirator Evaluations)
Any licensed MD, DO, PA, or NP
No specialty training required by OSHA
Must understand respirator demands
Can practice in any setting (clinic, telemedicine, online)
Cost: $22-150 per evaluation
Bottom line: While occupational health physicians bring valuable expertise, OSHA does not require them for respirator medical evaluations. Any PLHCP operating within their scope of practice can perform evaluations—making online evaluation services with licensed MDs, PAs, or NPs fully compliant.
Online PLHCP Oversight: How It Works
Online respirator medical evaluation services like RespiratorTest use licensed PLHCPs to review employee questionnaires remotely. This model provides the same OSHA compliance as in-person clinic evaluations at a fraction of the cost.
The Online Evaluation Process
- Employee completes OSHA Appendix C questionnaire online
15-20 minute questionnaire covering medical history, work environment, and respirator type
- Licensed PLHCP reviews questionnaire
Board-certified physician (like Dr. Nader Mikhail, MD) reviews responses via HIPAA-compliant platform
- PLHCP makes medical clearance decision
Approves, restricts, or denies clearance based on medical review
- Digital certificate issued
Medical clearance certificate delivered within 24 hours, stored securely for compliance
- Follow-up if needed
PLHCP may request additional information, in-person exam, or specialist consultation for complex cases
Dr. Nader Mikhail: Medical Review Officer for RespiratorTest
Dr. Nader Mikhail, MD
Medical Review Officer & PLHCP
Board-Certified Internal Medicine
Dr. Mikhail serves as the Medical Review Officer for RespiratorTest.com, reviewing all respirator medical questionnaires and making medical clearance decisions in accordance with OSHA 1910.134 requirements.
Qualifications & Experience
- Board-certified in Internal Medicine
- Licensed physician in multiple states
- Extensive experience in occupational health evaluations
- Expert in cardiovascular and respiratory medicine
- Thousands of respirator medical evaluations reviewed
"My role is to ensure every worker can safely wear a respirator based on their unique health profile. Online evaluations allow me to review questionnaires efficiently while maintaining the same rigorous medical standards as in-person clinic evaluations."
— Dr. Nader Mikhail, MD
Frequently Asked Questions
What does PLHCP stand for in respiratory protection?
PLHCP stands for Physician or other Licensed Healthcare Professional. This is an OSHA-defined term for medical professionals qualified to conduct respirator medical evaluations and make medical clearance decisions for respirator use.
Who qualifies as a PLHCP for respirator medical evaluations?
OSHA defines PLHCPs as physicians (MD or DO), physician assistants (PA), advanced practice registered nurses (APRN/NP), or other licensed healthcare professionals whose legally permitted scope of practice includes conducting medical evaluations. This varies by state, but typically includes MDs, DOs, PAs, and NPs.
Can a nurse practitioner (NP) perform respirator medical evaluations?
Yes, in most states. Nurse practitioners (NPs) qualify as PLHCPs if their state scope of practice permits conducting medical evaluations. All 50 states allow NPs to perform respirator medical evaluations, though some require physician collaboration or supervision depending on the NP's practice authority level.
Can a physician assistant (PA) conduct respirator medical evaluations?
Yes. Physician assistants (PAs) qualify as PLHCPs and can conduct respirator medical evaluations in all 50 states. PAs review OSHA Appendix C questionnaires, make medical clearance decisions, and issue respirator clearance certificates. Some states require physician supervision or collaboration for PA practice.
What is the difference between a PLHCP and an occupational health physician?
An occupational health physician is a medical doctor specializing in workplace health, while a PLHCP is any qualified medical professional (MD, DO, PA, NP) performing respirator evaluations. Occupational health physicians may have additional training in workplace hazards, but OSHA does not require specialty training for PLHCP respirator evaluations—just appropriate licensure and scope of practice.
How does online PLHCP oversight work for respirator evaluations?
Online respirator evaluations use licensed PLHCPs who review employee questionnaires remotely via HIPAA-compliant platforms. Employees complete the OSHA Appendix C questionnaire online, the PLHCP reviews the responses and makes medical clearance decisions, then issues digital certificates. This model provides the same OSHA compliance as in-person evaluations at a fraction of the cost.
What medical credentials does Dr. Nader Mikhail have?
Dr. Nader Mikhail, MD is a licensed physician who serves as Medical Review Officer for RespiratorTest.com. He is board-certified in internal medicine, licensed in multiple states, and has extensive experience reviewing occupational health evaluations. Dr. Mikhail reviews all respirator medical questionnaires and makes medical clearance decisions in accordance with OSHA 1910.134 requirements.
Does OSHA require PLHCPs to have occupational medicine training?
No. OSHA does not require PLHCPs to have specialized occupational medicine training or board certification. Any licensed physician (MD or DO), physician assistant, or nurse practitioner operating within their scope of practice can perform respirator medical evaluations. However, PLHCPs must be knowledgeable about the physical and psychological demands of respirator use.
PLHCP-Reviewed Medical Evaluations in 24 Hours
Don't let confusion about PLHCP qualifications delay your respiratory protection compliance. RespiratorTest uses licensed physicians like Dr. Nader Mikhail, MD to review all medical questionnaires and issue clearance certificates.
Your employees complete the OSHA Appendix C questionnaire online in 15 minutes. Our board-certified PLHCP reviews their answers within 24 hours and issues medical clearance certificates. Same OSHA compliance as $150 clinic visits, for just $22 per employee.
Licensed PLHCP oversight. Full OSHA 1910.134 compliance. Digital certificates delivered in 24 hours.