Eliminating PLHCP-led screening for respirators commonly used in hazard-driven environments shifts complex medical fitness decisions to non-clinicians, increasing the risk for workers with cardiopulmonary or other health conditions - particularly in situations where respirator use is mandatory. To address these concerns, AIHA recommends that OSHA: Maintain PLHCP screening for all required respirator use, including filtering facepiece respirators (FFRs) and loose-fitting powered air-purifying respirators (PAPRs), while allowing for streamlined questionnaires and triage by PLHCPs. Restrict any exemptions to truly voluntary, low-exposure scenarios, and clearly define specific triggers for PLHCP referral (e.g., symptoms, pre-existing conditions, extended wear durations, heat stress). Issue a compliance guide clarifying (a) when screening is required, (b) PLHCP triage workflows and documentation, and (c) interaction with substance-specific standards; explicitly flag triggers for PLHCP referral (e.g., cardiopulmonary disease, symptoms, extended wear, heat stress, or physically demanding tasks requiring negative-pressure respirators). Please see additional comments in the attached file.
Respirators - Medical Clearance
Activity
American Industrial Hygiene Association (AIHA) filed 1 comment on this docket between Oct 31, 2025 and Oct 31, 2025. 18 other organizations filed here. The comment window closed 22d ago.
What American Industrial Hygiene Association (AIHA) filed (1)
Abstract
OSHA is proposing removing the medical evaluation requirements in the Respiratory Protection Rule (1910.134) for employees using filtering facepiece respirators (FFRs) and loose-fitting powered air-purifying respirators (PAPRs). This change is based on the lack of data indicating adverse health effects from using these respirators. Medical evaluations will remain required for other respirator types - exempting only FFRs and loose-fitting PAPRs. Other provisions of the Respiratory Protection Standard remain unchanged. OSHA invites comments on all aspects of the proposed rule.
View on regulations.gov →Co-filers (18)
See everyone who commented →- American Industrial Hygiene Association (AIHA)THIS ORG1 filing · confidence 97%
- Ad-hoc coalition of trade associationstrade assoc.1 filing · confidence 85%
- AFL-CIO1 filing · confidence 97%
- American Health Care Association (AHCA/NCAL)trade assoc.1 filing · confidence 97%
- American Public Health Associationtrade assoc.1 filing · confidence 85%
- Angus; North American Insulation Manufacturers Associationtrade assoc.1 filing · confidence 85%
- Cheryl; National Roofing Contractors Associationtrade assoc.1 filing · confidence 85%
- Citizens Rulemaking Alliancetrade assoc.1 filing · confidence 85%
- CRLA Foundationtrade assoc.1 filing · confidence 85%
- Daaiyah; National Education Associationtrade assoc.1 filing · confidence 85%
- Dalia; American Federation of Statetrade assoc.1 filing · confidence 85%
- Eugene; Institute of Hazardous Materials Managementtrade assoc.1 filing · confidence 85%
- International Safety Equipment Associationtrade assoc.1 filing · confidence 85%
- Jennylynn Balmer; American Association of Occupational Health Nursestrade assoc.1 filing · confidence 85%
- Kelly; American Federation of Teacherstrade assoc.1 filing · confidence 85%
- Kerri; American Public Health Associationtrade assoc.1 filing · confidence 85%
- National Federation of Independent Businesstrade assoc.1 filing · confidence 97%
- Representative Robert "Bobby"; Committee on Education and Workforce Lettertrade assoc.1 filing · confidence 85%
- University of Maryland School of Medicineunverified attribution1 filing · confidence 70%