Cal/OSHA · dir.ca.gov
Program-Based Standards

Respiratory Protection — Medical Evaluation Medical Surveillance

Respirator use imposes physiological burden (cardiopulmonary stress) requiring medical clearance; affects any worker required to wear a respirator across general industry and construction.

Who is covered: Every employee required to use a respirator must receive a medical evaluation before fit testing or use. 8 CCR 5144 applies across covered work (general industry and construction) — Cal/OSHA does not split respiratory protection into separate GI/construction sections; medical-evaluation provisions in 5144(e) track 1910.134(e) nearly verbatim.

Evaluation performed by: PLHCP — physician or other licensed health care professional (California licensure scope)

🩺 Baseline / Pre-Placement

Before the employee is fit tested or required to use a respirator — 8 CCR 5144(e)(1)

  • OSHA Respirator Medical Evaluation Questionnaire — Appendix C (Mandatory), Part A, Section 1 (basic info: name, age, height, weight, job title, respirator type) and Section 2 (mandatory medical-history/symptom questions, Q1-8 cardiopulmonary; Q10-15 mandatory for full-facepiece/SCBA users) — covering tobacco use; seizures/diabetes/allergies/claustrophobia; pulmonary conditions (asthma, emphysema, TB, lung cancer); current respiratory symptoms (shortness of breath, cough, wheeze, chest pain); cardiovascular history/symptoms (heart attack, angina, arrhythmia); current cardiac/respiratory/BP/seizure medications; prior respirator-use problems
  • Alternatively, an initial medical examination that obtains the SAME information as the Appendix C questionnaire (equivalent entry pathway)
  • Appendix C Part B questions at the PLHCP's discretion (occupational exposures, work intensity/duration, environmental conditions, additional protective clothing)
Abnormal results & exposure-event protocols

Abnormal Results & Exposure-Event Protocols

  • Employee answers 'yes' to any of questions 1-8 in Section 2, Part A of Appendix C, OR the initial medical exam shows a need 8 CCR 5144(e)(3): Employer provides a FOLLOW-UP medical examination by the PLHCP; the follow-up exam includes any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary to make a determination of fitness to use a respirator. Tests: Medical examination by the PLHCP, Any medical tests, consultations, or diagnostic procedures the PLHCP deems necessary (e.g., spirometry or chest X-ray ONLY if the PLHCP deems them necessary — not mandated by the standard)
  • Additional medical re-evaluation required when: (i) the employee reports medical signs/symptoms related to ability to use a respirator; (ii) a PLHCP, supervisor, or respirator program administrator informs the employer that re-evaluation is needed; (iii) information from the respiratory protection program (including observations during fit testing or program evaluation) indicates a need; or (iv) a workplace change occurs that may substantially increase the physiological burden on the employee. 8 CCR 5144(e)(7): Provide an additional medical evaluation (questionnaire or exam as appropriate) to re-determine the employee's ability to use the respirator. Tests: Repeat medical evaluation via Appendix C questionnaire or examination, as indicated by the trigger

Reporting Requirements

Who performs the evaluationPLHCP (physician or other licensed health care professional whose scope of practice permits the services in paragraph (e))
Reported to employerPLHCP provides a WRITTEN RECOMMENDATION limited to: whether the employee is medically able to use the respirator; any limitations on respirator use (including for emergency/high-burden conditions); the need for a follow-up medical evaluation; and a statement that the PLHCP has provided the employee a copy of the recommendation. No clinical findings or diagnoses are disclosed.
Reported to / for the employeePLHCP must provide the employee a copy of the PLHCP's written recommendation.
Time limitsEvaluation must be completed before fit testing or first respirator use. No fixed turnaround stated for the recommendation beyond that it precede respirator use.
RecordkeepingMedical evaluation records retained per 8 CCR 3204 — duration of employment plus 30 years. The completed questionnaire is confidential to the PLHCP; the employer is not given the questionnaire itself.

Medical Removal Protection

No medical removal protection — medical clearance to use a respirator, not removal-based surveillance. No fixed periodic interval; re-evaluation is trigger-based (see abnormal_protocols).

How this compares to Federal OSHA: Essentially aligned — 8 CCR 5144(e) tracks 29 CFR 1910.134(e) nearly verbatim (same pre-use evaluation, same PLHCP definition, same Appendix C questionnaire pathway, same follow-up and four re-evaluation triggers). Difference is jurisdictional/administrative only. Federal splits the requirement across general industry (1910.134) and construction-by-reference (1926.103); California applies a single 5144 across covered work.

Occu-Med handles Respiratory Protection — Medical Evaluation surveillance end-to-end

Scheduling, exams, lab panels, physician review, removal/return determinations, and audit-ready recordkeeping — fully compliant with Cal/OSHA requirements.