Your Essential Guide to OSHA Respirator Medical Clearance
A practical, plain-English walkthrough for safety managers, HR, and operations teams. Learn what OSHA expects, what records matter, and how to clear workers quickly using a modern online process—without clinic scheduling headaches.
What “Respirator Medical Clearance” Actually Means
An OSHA respirator medical clearance (also called a medical evaluation) is the step that confirms an employee can safely wear a respirator for work. Respirators protect workers—but they also add breathing resistance, increase heat/physiological burden, and can create anxiety or claustrophobia for some users. The medical evaluation exists to identify those risks before a respirator is assigned and used.
The sequence matters: medical evaluation first, then fit testing (if required), then use in the workplace. When programs break this order, it’s one of the most common audit and operational failure points.
OSHA’s respiratory protection standard requires employers to provide a medical evaluation for employees who must use respirators in the workplace.
A Physician or other Licensed Healthcare Professional (PLHCP) determines clearance status and any limitations based on the OSHA questionnaire and follow-up, if needed.
The employer needs the PLHCP’s written recommendation/clearance result for records and audits (not the employee’s detailed answers).
Important note on changes: OSHA has proposed changes that could affect medical evaluation requirements for certain respirator types (such as filtering facepiece respirators and some loose-fitting PAPRs). Until a final rule is issued and adopted, employers should continue to follow the current 29 CFR 1910.134 requirements and any applicable state plans.
What OSHA Requires Under 29 CFR 1910.134(e)
OSHA requires employers to provide a medical evaluation to determine an employee’s ability to use a respirator before the employee is fit-tested or required to use the respirator at work. The evaluation can be completed using:
- OSHA’s Respirator Medical Evaluation Questionnaire (Appendix C), or
- An initial medical exam that obtains the same required information.
Confidentiality is part of compliance
Employers should not review the employee’s medical questionnaire responses. The process is designed so the PLHCP receives the information confidentially. The employer should retain the PLHCP’s written recommendation/clearance determination and administer the program based on that result.
What the employer must be able to show
In practice, the employer should be able to demonstrate that the respirator program is implemented end-to-end—not just a single clearance PDF. A typical “audit-ready” file set includes:
- Program administration: a designated program administrator and written procedures appropriate to your workplace.
- Medical evaluation: documented clearance determination from a PLHCP for each required respirator user.
- Fit testing: fit test records for each tight-fitting respirator model/size used, as applicable.
- Training: training records for respirator users (why, how, limitations, maintenance, and policies).
- Re-evaluation tracking: a system to trigger additional medical evaluations when conditions change.
Operational tip: Most compliance failures are process failures, not medical decisions. Build a workflow that makes the “right order” automatic for supervisors and onboarding teams.
Who Needs a Respirator Medical Evaluation?
Any employee who is required to wear a respirator as part of their job must be medically evaluated. This includes situations where a respirator is required by your hazard assessment, your client site policy, or your respiratory protection program.
Common roles and environments
- Construction & trades: silica dust, concrete cutting, demolition, welding fumes, painting/spraying.
- Manufacturing & industrial: grinding/sanding, chemical handling, particulate exposure, maintenance shutdowns.
- Healthcare: required N95 use for airborne infectious disease controls and facility policy.
- Utilities, remediation, and cleaning: mold, asbestos lead (as applicable), chemical disinfectants, confined/dirty environments.
- Emergency response: hazardous atmospheres, SCBA/supplied-air program participants.
Respirator types that often trigger clearance
- Filtering facepieces: N95 / N99 / N100 / P100, when required by the employer.
- Tight-fitting elastomeric respirators: half mask and full-face respirators.
- PAPR: tight-fitting and loose-fitting systems (requirements depend on your program and respirator selection).
- Supplied air / SCBA: higher-burden use cases that often involve more stringent program controls.
N95 clarification: If your employer requires an N95 as a condition of work, it’s typically part of the respiratory protection program—meaning medical evaluation comes first. If you’re unsure whether your use is “required” vs. “voluntary,” align with your written hazard assessment and site policy.
Need N95-focused guidance? See N95 Medical Clearance.
A Simple, Audit-Ready Compliance Workflow
Think of respirator medical clearance as one step in a broader system. The fastest programs are the ones that sequence the work correctly and keep documentation centralized. Here’s a practical workflow you can implement for onboarding, annual cycles, and jobsite mobilization.
Employer workflow checklist
- Hazard assessment & selection: identify hazards and select NIOSH-approved respirators appropriate to the task.
- Medical evaluation: employee completes Appendix-C-based questionnaire; PLHCP issues clearance or requests follow-up.
- Fit testing (if tight-fitting): conduct fit testing for the specific make/model/size to be used.
- Training: provide training on use, limitations, don/doff, maintenance, and procedures.
- Ongoing program controls: maintenance, storage, cartridge change schedules, and periodic evaluation.
What the PLHCP provides
- Written recommendation: a clearance determination and any limitations on respirator use.
- Confidential review: the employee’s detailed responses remain confidential; the employer receives the outcome needed for program decisions.
- Follow-up guidance: when a response requires clarification or further evaluation, the PLHCP specifies next steps.
- Re-evaluation input: recommendations when additional evaluation is needed due to symptoms or changes in job conditions.
How QuickCare ProTrain fits into this workflow
QuickCare ProTrain is designed to handle the medical evaluation step quickly and consistently, so your internal team can focus on operations. Employees complete a secure online questionnaire; a PLHCP reviews it; and you receive a digital clearance determination you can store with your program records.
Step 1: Employee completes the online questionnaire
Mobile-friendly completion in about 10 minutes, without clinic scheduling. Designed around OSHA’s required questionnaire content.
Step 2: PLHCP review
Confidential professional review by a licensed clinician. If follow-up is needed, the employee receives clear next steps.
Step 3: Digital clearance result
Receive a digital clearance determination—often within ~15 minutes—ready to file with your respiratory protection documentation.
Managing a team? See volume discounts and our employer workflow options on ProTrain.
When Do You Need an Additional Medical Evaluation?
OSHA does not set one fixed expiration date for every worker in every workplace. Instead, the standard focuses on triggers that require re-evaluation. Your program should have a simple way to identify and act on these triggers quickly.
Common triggers that require additional evaluation
- Symptoms reported: the employee reports medical signs or symptoms related to respirator use.
- PLHCP recommendation: the PLHCP indicates the employee should be reevaluated.
- Observed problems: fit testing or program evaluation indicates a need for reevaluation.
- Work conditions changed: increased physical workload, heavier PPE, temperature changes, or other factors that substantially increase physiological burden.
Many employers set an annual cadence as a best practice—especially in higher-risk environments or where respirator use is frequent—because it simplifies tracking and supports consistency across job sites.
FAQs: Medical Clearance, Fit Testing, and N95 Requirements
Below are the most common questions we see from safety managers and frontline workers when building or maintaining a respiratory protection program.
Yes. OSHA requires the medical evaluation to be completed before the employee is fit-tested or required to use a respirator in the workplace. If you’re mobilizing a jobsite quickly, medical clearance is often the gating item that determines how fast you can fit test and deploy.
No. They are separate requirements that work together:
- Medical evaluation: determines whether the employee can safely wear a respirator (and whether limitations apply).
- Fit test: verifies a tight seal for a specific make/model/size on the employee’s face.
Medical clearance comes first. Then fit test (for tight-fitting respirators). For more detail, see Fit Test vs. Medical Clearance.
If an employer requires an employee to wear an N95 as part of the job, it is typically part of the respiratory protection program, and the medical evaluation is required before use.
Need N95-specific help? Visit N95 Medical Clearance.
OSHA focuses on triggers that require additional medical evaluation (symptoms, PLHCP recommendation, program observations, or workplace changes that increase burden). Many employers choose an annual cadence as a best practice to simplify tracking.
If you need help designing a tracking cadence for new hires and annual cycles, ProTrain’s employer options are listed on Pricing.
Yes. The medical questionnaire is meant to be handled confidentially. Employers typically receive the clearance determination and any limitations, not the employee’s detailed questionnaire responses.
QuickCare ProTrain is designed as a privacy-first workflow: employees complete the questionnaire through a secure portal, and employers get only what they need to run the program.
Sometimes a PLHCP needs clarification or additional evaluation to make a safe determination. If follow-up is required, the employee receives clear instructions for next steps. After follow-up, the clearance determination is updated so the employer can proceed with fit testing and assignment (as appropriate).
Not legal advice: This guide is provided for general informational purposes. Your requirements may vary based on your hazard assessment, respiratory protection program design, and state-plan rules.
Why Companies Use QuickCare ProTrain
Respiratory compliance breaks down when it’s slow, fragmented, or hard to administer. ProTrain is designed to make the medical evaluation step fast and consistent— while supporting audit readiness and minimizing operational disruption.
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Fast turnaround: employees complete the questionnaire quickly; many clearances are delivered in about ~15 minutes.
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Program-aligned documentation: get a digital clearance determination that fits cleanly into your respirator program records.
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Cost control: reduce downtime and clinic scheduling overhead. See cost & savings and pricing tiers.
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Easy access: mobile-friendly completion for employees; simpler onboarding for distributed teams and multi-site operations.
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Cleaner recordkeeping: digital outputs support audit organization and reduce “lost paperwork” risk.
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Support when it gets complicated: if a case needs follow-up, the employee is guided through next steps so your team isn’t stuck guessing.
Want an end-to-end solution beyond medical evaluation? Explore ProTrain options for teams and recurring compliance cycles on ProTrain.