Is a Medical Evaluation Needed for Using a Respirator in Confined Spaces?

Dear Raghu, let me try to give my views.

Understanding Your Concern

What I understand from your posting is that you want to send workers to work in a confined space. For that, your client's safety advice is to use a respirator. You do not wish the workers to use the respirator while performing the job. You also state that all the gas is within the permissible limit.

Question on Respirator Use

Now, your question is: if an employee is medically fit, does he need to use a respirator or not?

My answer is yes:

1. What's the loss in taking extra precautions?
2. Also, somebody suggests (your client's safety, surely with more expertise in the field) that you must go for it, and if you fulfill the requirement and anything goes wrong, you will be in trouble.
3. What's the guarantee that the normal situations will not change? IDLH situations can arise at any time in a confined space. So we have to be more cautious when it comes to confined space.

Regards,
Dipil Kumar V

Good morning to all, Next week, we have to work in a confined space (live lift station, 15 feet height masonry work, less than 20 minutes only). I have to check myself today in that lift station - oxygen, CO, H2S - everything is at the appropriate level. However, our client's safety advice is for me to use a respirator.

My Question:

Is a medical evaluation (certificate) of an employee required to use a respirator or not? Please advise me.

Thanks & Be safe
Regards,
Raghu

Dear Dilip,

Thank you for your valuable advice.

My question is: Is a medical certificate required for employees who use respirators?

Thanks & Be safe,
Raghu

Dear Raghuji,

I believe it is necessary to provide evidence that the employee is fit for the specific work required. In general, a medical certificate is essential for tasks involving heights, as individuals with conditions like vertigo may not be suitable for such work.

I suggest consulting with senior safety personnel to understand the rationale behind the medical certificate requirement, especially for work in confined spaces. You can also inquire directly with the individual requesting the certificate.

Thanks,
Abhay

Dear Safety Professional,

As per EM-385, an employee medical certificate is required to use respirators. Could someone clarify what OSHA 1926 states? If anyone knows the answer, please share with us. I have been trying but have not yet found an answer. Please help me.

I hope to receive your reply at the earliest.

Thanks & Be safe,
Raghu

Dear Friend, I see your plight. USACE deals with safety issues diligently. They consider human lives as precious.

Your Two Issues:

1. Confined space entry - a lift station. Your client's safety requires you to ensure that your people use a respirator.

2. Whether a medical evaluation is required for using a respirator or not?

USACE, EM 385 1.1. - 06.I.01 provides you with all the information on confined space entry.

In a lift station, for entry, if you can ensure that the atmosphere is maintained healthy, respirators are not required. Use forced ventilation if necessary and avoid the use of respirators as much as possible. Remember, PPE is not the first line of defense. You may inform your USACE safety representative that you are personally monitoring the atmosphere. However, for emergency use, you must ensure respirators are readily available at the entry point of your confined space.

Exemption from Medical Examination (EM 385.1.1.) 05.E.08

A medical evaluation is not required for employees whose only respirator use would be the use of a NIOSH certified Emergency Life Support Apparatus (ELSA) escape-only respirator that provides less than 30 minutes of breathing air and is used to escape from a building/structure in the event of an emergency.

For regular use of a respirator, a medical evaluation is required as per OSHA, and USACE 385.1.1. is just a copy of OSHA requirements.

OSHA 1910.134(e) Medical Evaluation

Using a respirator may place a physiological burden on employees that varies with the type of respirator worn, the job and workplace conditions in which the respirator is used, and the medical status of the employee. Accordingly, this paragraph specifies the minimum requirements for a medical evaluation that employers must implement to determine the employee's ability to use a respirator.

1910.134(e)(1)

General. The employer shall provide a medical evaluation to determine the employee's ability to use a respirator before the employee is fit tested or required to use the respirator in the workplace. The employer may discontinue an employee's medical evaluations when the employee is no longer required to use a respirator.

Regards,
Kesava Pillai