Potential changes to medical evaluation requirements could reduce administrative burdens, but effective respirator selection, exposure assessment, training and other core protections remain essential.

Respiratory protection is the final line of defense in the hierarchy of controls. OEHS professionals first seek to eliminate hazards, substitute less hazardous materials, implement engineering controls and improve work practices before selecting respirators. When these measures cannot adequately control airborne exposures, respirators are necessary to prevent occupational illness and disease.

Effective respiratory protection has repeatedly proven valuable across industries where workers may encounter hazardous airborne exposures. A well-designed respiratory protection program includes hazard assessment, respirator selection, medical evaluation, fit testing where required, training, maintenance and periodic program evaluation under OSHA’s Respiratory Protection Standard, 29 CFR 1910.134. Recent federal proposals have prompted questions about whether some elements of these programs can be streamlined without jeopardizing worker protections.

OSHA’s Respiratory Protection Standard requires employers to develop written respiratory protection programs whenever respirators are necessary to protect worker health. These programs address exposure assessment, respirator selection, medical evaluation, fit testing, user seal checks, maintenance, cleaning and storage, training and program evaluation.

Since its adoption in 1998, the standard has been recognized internationally as one of the most comprehensive respiratory protection regulations. Numerous OSHA substance-specific standards, including those covering asbestos, benzene, formaldehyde, lead, cadmium, hexavalent chromium and inorganic arsenic, contain respiratory protection provisions that either supplement or reference 29 CFR 1910.134.

One of OSHA’s most widely discussed proposals would eliminate mandatory pre-use medical examinations for workers wearing filtering facepiece respirators, such as N95 respirators, and loose-fitting powered air-purifying respirators, or PAPRs.

The proposal would not eliminate medical assessments for employees using tight-fitting half-mask respirators, full-facepiece respirators, supplied-air respirators or self-contained breathing apparatus, or SCBA.

OSHA has indicated that filtering facepiece respirators and loose-fitting PAPRs generally impose a relatively low physiological burden on healthy users and that existing evidence does not support mandatory clinical examinations for every worker using these devices.

This article originally appeared in the October 2026 issue of Occupational Health & Safety.

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