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OSHA 1910.134 Medical Evaluation Online - $22

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OSHA 1910.134 Compliant

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Compare: Online OSHA Evaluation vs Traditional Clinic

Traditional Occupational Clinic

$150-$300

per employee


❌ Schedule 1-3 weeks out

❌ 2-4 hours with travel/wait

❌ Results in 3-7 business days

❌ Employee time off work

❌ Paper certificates (easy to lose)

❌ Manual renewal tracking

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Save $128 per employee (85% savings)


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Understanding OSHA 1910.134 Medical Evaluation Requirements

OSHA 1910.134 is the federal respiratory protection standard that governs all workplace respirator use. Section (e) establishes mandatory medical evaluation requirements before employees can use respirators. For comprehensive compliance trends and industry data, see our 2025 Respirator Compliance Report.

What OSHA 1910.134 Requires
  • Medical evaluation before respirator use - No exceptions
  • PLHCP review required - Must be licensed physician or healthcare professional
  • OSHA Appendix C questionnaire - Or PLHCP-approved equivalent
  • Written PLHCP recommendation - Documenting clearance status
  • Medical evaluation before fit testing - Sequence is critical
  • 30-year record retention - Medical evaluation records must be kept
What OSHA Allows (Flexibility)
  • Questionnaire-only evaluations - Physical exam not required unless PLHCP determines necessary
  • Online medical evaluations - OSHA explicitly permits remote evaluations
  • Various PLHCP types - Physicians, PAs, NPs, other licensed professionals
  • Employer choice of PLHCP - Can select any qualified provider
  • Electronic records - Digital documentation accepted
  • Confidential employee responses - Employer only receives clearance status
Need compliant online medical evaluations? We handle OSHA compliance for you.

Who Qualifies as a PLHCP Under OSHA 1910.134?

OSHA 1910.134 defines a PLHCP (Physician or Licensed Healthcare Professional) as "an individual whose legally permitted scope of practice allows him or her to provide the medical evaluation services required by paragraph (e) of this section independently."

This broad definition allows employers flexibility in selecting qualified medical professionals, but the PLHCP must meet specific qualifications:

✓ Qualified PLHCPs Include:
  • Physicians (MD/DO) - Medical doctors and doctors of osteopathy
  • Physician Assistants (PA) - Licensed PAs working within scope
  • Nurse Practitioners (NP) - Licensed NPs authorized to provide medical evaluations
  • Occupational Health Nurses - Licensed RNs with OHN certification (state dependent)
  • Other Licensed Professionals - As permitted by state scope of practice laws
✗ NOT Qualified as PLHCPs:
  • Safety Managers - Even with safety certifications (CSP, CIH)
  • Unlicensed Medical Assistants - Cannot independently approve evaluations
  • First Aid Certified Employees - First aid training is insufficient
  • EMTs/Paramedics - Unless licensed as PLHCP in their state
  • Chiropractors - Scope of practice generally excludes respirator evaluations
RespiratorTest.com PLHCP

All evaluations reviewed by Dr. Nader Mikhail, MD


🎓 Board-Certified Physician

California Medical License #G88906

⚕️ OSHA-Qualified PLHCP

Meets all 1910.134(e)(5) requirements

🏥 15+ Years Experience

Occupational health and respiratory medicine

✓ 15,000+ Evaluations Reviewed

100% OSHA audit acceptance rate

OSHA 1910.134(e) Section-by-Section Breakdown

Understanding each subsection helps ensure complete compliance

1910.134(e)(1)
Medical Evaluation Required

Employer must provide medical evaluation before employee uses any respirator

Serious violation - $16,131 per affected employee
1910.134(e)(2)
PLHCP Qualification

Evaluation must be performed by licensed Physician or Licensed Healthcare Professional

Serious violation - $16,131 per evaluation
1910.134(e)(3)
Questionnaire Use

Must use OSHA Appendix C questionnaire or PLHCP-approved equivalent

Other-than-serious violation - up to $16,131
1910.134(e)(4)
Examination Optional

Physical examination not required if questionnaire review determines employee can wear respirator

N/A (clarifies compliance flexibility)
1910.134(e)(5)
Follow-up Exams

Provide follow-up medical exams if PLHCP determines necessary based on questionnaire

Serious violation - $16,131
1910.134(e)(6)
Written Recommendation

PLHCP must provide written recommendation regarding employee ability to use respirator

Other-than-serious violation - up to $16,131
1910.134(e)(7)
Re-evaluation Triggers

Provide additional evaluations if employee reports symptoms, conditions change, or PLHCP recommends

Serious violation - $16,131

OSHA Appendix C Questionnaire Explained

OSHA Appendix C is the standardized medical questionnaire that employers must use (or an equivalent approved by the PLHCP) to evaluate employees before respirator use. The questionnaire is mandatory under 29 CFR 1910.134(e)(3) and serves as the foundation for all respirator medical evaluations.

What the Appendix C Questionnaire Covers

The questionnaire contains 15 medical screening questions divided into three parts:

Part A: General Information

Employee demographic and workplace information including:

  • Age, height, weight
  • Job title and work location
  • Respirator type to be used
  • Duration and frequency of use
Part B: Medical History (12 Questions)

Yes/no questions about medical conditions:

  • Cardiovascular conditions
  • Respiratory diseases (asthma, COPD)
  • Diabetes, epilepsy, seizures
  • Claustrophobia and anxiety
Part C: Work Environment (3 Questions)

Questions about respirator use conditions:

  • Temperature and humidity exposure
  • Physical workload intensity
  • Confined space work

How PLHCPs Review Appendix C Responses

When employees complete the Appendix C questionnaire, the PLHCP reviews their responses to determine if they can safely use respirators:

✓ Typical "Yes" Responses Leading to Clearance:

Approximately 98% of employees answer "no" to all Part B medical questions and receive instant medical clearance. Common "yes" answers that still result in clearance include:

  • Seasonal allergies (controlled)
  • Well-managed asthma
  • Controlled hypertension
  • Corrected vision issues
⚠ "Yes" Responses Requiring PLHCP Review:

Certain "yes" responses trigger mandatory PLHCP review within 24 hours:

  • Recent heart attack or cardiac surgery
  • Active asthma with frequent symptoms
  • Severe claustrophobia or panic attacks
  • COPD, emphysema, or chronic bronchitis

Employee Privacy Protections

OSHA 1910.134(e)(5) includes strict confidentiality protections for employee medical information:

This privacy protection encourages honest employee responses without fear of employment discrimination. Employees can trust that their specific health conditions remain confidential while employers receive the clearance information needed for OSHA compliance.

Complete OSHA Appendix C Questionnaire Online

RespiratorTest.com provides the official OSHA Appendix C questionnaire with instant PLHCP review. 98% of employees receive medical clearance within minutes.

Online vs In-Person Medical Evaluations: Which is OSHA Compliant?

Both online and in-person evaluations can be OSHA 1910.134 compliant when conducted properly. OSHA explicitly permits remote evaluations under section 1910.134(e)(4).

RequirementOnline EvaluationIn-Person Clinic Visit
OSHA Appendix C Questionnaire✓ Yes - Exact OSHA form✓ Yes - Paper or digital
PLHCP Review Required✓ Yes - Licensed MD reviews✓ Yes - Clinic PLHCP reviews
Written PLHCP Recommendation✓ Yes - Digital certificate✓ Yes - Paper or email
HIPAA Compliance✓ Yes - Encrypted storage✓ Yes - Locked filing
30-Year Record Retention✓ Yes - Automatic digital⚠ Employer responsibility
Time to Complete15 minutes (from anywhere)2-4 hours (travel + wait + visit)
Cost Per Employee$22$75-300 (clinic fee only)
Results TimelineInstant (98% of cases)1-7 days
Employee Productivity Loss0 hours (done during breaks)2-4 hours per employee
Scheduling ComplexityNone - Self-service 24/7High - Coordinate 50+ appointments

When In-Person Exams Are Required

While 98% of employees receive clearance through online questionnaire review alone, in-person follow-up examinations are required in specific situations:

PLHCP Requests Follow-Up

When questionnaire responses indicate potential cardiovascular, respiratory, or psychological conditions requiring clinical assessment. PLHCP determines if in-person exam is medically necessary.

Employee Reports Symptoms

If employee reports breathing difficulty, chest pain, dizziness, or other symptoms while using respirators. Requires immediate medical examination per OSHA 1910.134(e)(7).

Extreme Work Conditions

For SCBA use in extreme heat, heavy physical exertion, or confined spaces, some PLHCPs may require stress tests or pulmonary function testing before clearance.

RespiratorTest.com Approach to Follow-Up Exams

Our PLHCP (Dr. Nader Mikhail, MD) reviews all flagged questionnaires within 24 hours. When follow-up is needed, we:

  • Provide clear guidance on what type of examination is needed
  • Coordinate with employee's personal physician if appropriate
  • Offer telehealth consultations for certain conditions
  • Recommend alternative respirator types (e.g., PAPR) that may not require follow-up

OSHA 1910.134 Compliance Cost Analysis: Online vs Clinic

The true cost of OSHA compliance includes far more than the medical evaluation fee. Here's a complete cost breakdown for employers.

Traditional Clinic Evaluation Cost
Clinic fee$75-300
Employee wages (3 hours @ $30/hr)$90
Lost productivity (backfill/OT)$120-180
Mileage reimbursement (30 mi @ $0.67)$20
HR scheduling/coordination time$30-50
30-year record storage (manual)$50-100
Total Per Employee$385-740
Online Evaluation Cost
Online evaluation fee$22
Employee wages (15 min @ $30/hr)$7.50
Lost productivity$0
Mileage reimbursement$0
HR scheduling/coordination time$0
30-year record storage (digital)$0
Total Per Employee$29.50

💰 Net Savings: $355-710 Per Employee

Annual compliance savings by company size:

10 Employees
$3,550-7,100
saved per year
50 Employees
$17,750-35,500
saved per year
200 Employees
$71,000-142,000
saved per year
1,000 Employees
$355,000-710,000
saved per year

Complete OSHA 1910.134 Compliance Checklist

Use this checklist to ensure your respiratory protection program meets all OSHA requirements

Before Respirator Use

  • Written respiratory protection program established
  • Medical evaluation completed for each employee
  • PLHCP written recommendation received
  • Employee medically cleared before fit testing
  • Fit test completed and passed
  • Initial training provided
Documentation Required

  • Respiratory protection program (current)
  • Medical evaluation records (30 years)
  • PLHCP written recommendations (duration of employment)
  • Fit test records (until next fit test)
  • Training records (until next training)
  • Respirator inspection and maintenance logs
Ongoing Compliance

  • Annual medical evaluations
  • Annual fit tests for tight-fitting respirators
  • Annual training refreshers
  • Workplace hazard assessments updated
  • Program effectiveness evaluations
  • Employee symptom monitoring
OSHA Inspection Readiness

  • All records organized and accessible
  • Current medical clearances for all respirator users
  • Fit test dates within 12 months
  • Training dates within 12 months
  • Written program reflects actual practices
  • PLHCP contact information documented
✓ Automate Your OSHA 1910.134 Compliance

RespiratorTest.com handles medical evaluations, PLHCP review, certificates, and 30-year record retention automatically. Focus on safety - we handle compliance.

Most Common OSHA 1910.134 Violations

Learn from others' mistakes - avoid these frequently cited violations

No Medical Evaluation
Very Common

Employees using respirators without any medical evaluation

Penalty: $16,131 per employee

✓ Fix: Complete medical evaluations before respirator use

Expired Medical Clearances
Common

Medical evaluations older than 12 months with no documented re-evaluation triggers

Penalty: $16,131 per employee

✓ Fix: Implement annual re-evaluation schedule

Missing PLHCP Documentation
Common

No written recommendation from PLHCP on file

Penalty: Up to $16,131

✓ Fix: Ensure PLHCP provides written clearance letters

Non-Qualified Evaluator
Occasional

Medical evaluations performed by non-licensed personnel or unqualified PLHCP

Penalty: $16,131 per evaluation

✓ Fix: Use only licensed PLHCPs (MD, DO, NP, PA)

Fit Test Before Medical
Very Common

Conducting fit tests before medical evaluation completed

Penalty: $16,131 per employee

✓ Fix: Ensure medical clearance before scheduling fit tests

Inadequate Record Retention
Common

Medical evaluation records not maintained for 30 years

Penalty: Up to $16,131

✓ Fix: Implement 30-year medical record retention system

Related OSHA Compliance Resources

Online Respirator Medical Evaluation

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OSHA Respirator Medical Evaluation Service

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OSHA 1910.134 Medical Evaluation FAQs

Common questions about OSHA respiratory protection medical evaluation requirements

What is OSHA 1910.134 medical evaluation requirement?

OSHA 1910.134(e) requires employers to provide medical evaluations for all employees before they use respirators. The evaluation determines if the employee is medically able to wear a respirator. This must be conducted by a PLHCP (Physician or Licensed Healthcare Professional) and completed before fit testing or respirator use.

Who must complete OSHA 1910.134 medical evaluations?

All employees required to wear respirators for workplace protection must complete medical evaluations per OSHA 1910.134. This includes N95 masks, half-face respirators, full-face respirators, and PAPRs. Voluntary use may have different requirements based on your respiratory protection program.

What are the penalties for not complying with OSHA 1910.134?

OSHA can issue citations with fines up to $16,131 per violation for serious violations. Willful or repeated violations can reach $161,323 per violation. If an employee is injured due to lack of medical evaluation, employers face additional liability including lawsuits, workers compensation claims, and potential criminal charges.

Does OSHA 1910.134 allow online medical evaluations?

Yes. OSHA 1910.134(e)(4) explicitly states that medical evaluations may be conducted using a questionnaire without requiring a physical examination. Online evaluations that use the OSHA Appendix C questionnaire and include PLHCP review are fully compliant.

How long are OSHA 1910.134 medical evaluations valid?

Medical evaluations are typically valid for 12 months. Re-evaluation is required if: the employee reports respiratory symptoms, a supervisor observes medical concerns, the PLHCP recommends follow-up, or there are changes in workplace conditions or respirator type that increase physiological burden.

What documentation is required for OSHA 1910.134 compliance?

Employers must maintain: written respiratory protection program, medical evaluation records (30 years minimum), PLHCP written recommendations, fit test records (until next test), training records, and respirator maintenance logs. All records must be available for OSHA inspection.

Who is a qualified PLHCP under OSHA 1910.134?

PLHCP (Physician or Licensed Healthcare Professional) includes physicians (MD/DO), physician assistants, nurse practitioners, and other licensed healthcare providers authorized to provide medical evaluations in their scope of practice. They must be knowledgeable about respirator medical evaluation procedures.

What happens if an employee fails OSHA 1910.134 medical evaluation?

The PLHCP may: approve without restrictions, approve with restrictions (e.g., require PAPR instead of N95), request additional medical information, or deny clearance. Employers must provide reasonable accommodations. Outright denials are rare - most cases result in alternative respirator recommendations.

Can employees use respirators without OSHA 1910.134 evaluation?

No. OSHA 1910.134 strictly prohibits respirator use before medical evaluation and clearance. Employees who use respirators without evaluation violate OSHA regulations, and employers face citations, fines, and liability for any resulting injuries.

How much does OSHA 1910.134 medical evaluation cost?

Occupational health clinics charge $150-300 per evaluation. RespiratorTest.com provides OSHA-compliant medical evaluations online for $22 per employee with instant PLHCP review. Volume pricing of $17 per evaluation is available for 100+ employees.

What is OSHA Appendix C?

OSHA Appendix C is the mandatory medical questionnaire included in 1910.134. It contains questions about cardiovascular health, respiratory conditions, medications, and work environment. Employers must use this exact questionnaire or a PLHCP-approved alternative that provides equivalent information.

Does OSHA 1910.134 apply to construction and general industry?

Yes. OSHA 1910.134 applies to all general industry workplaces. Construction sites must also comply with 1910.134 respiratory protection requirements. The regulation covers manufacturing, healthcare, construction, shipyards, and any workplace where respirators are used.

Achieve OSHA 1910.134 Compliance Today

Complete OSHA-compliant medical questionnaires online in 15 minutes. PLHCP reviewed, instant certificates, 30-year record retention. Get medical clearance before fit testing - stay compliant, avoid fines.

✓ PLHCP Reviewed • ✓ Instant Certificates • ✓ 30-Year Record Retention

Questions about compliance? Contact us for help