Temporary Enforcement Guidance
Annual Fit-Testing, Respiratory Protection and Face Coverings during COVID-19 Pandemic, DOSH Directive 11.80, is still the latest word on fit testing, and the annual requirement is back in effect as of 1/1/22.
Fit testing must be completed under four circumstances: initially (upon hire or prior to first exposure); annually; change of face that would affect fit (noticeable change in weight, scar, etc.); and change in make or model of respirator.
Medical evaluations must be completed prior to the initial fit test (unless the new employer has similar hazards as the previous employer or is given the last medical evaluation and agrees to use it) when: the hazards change; the type of respirator changes (e.g., FFR to PAPR); the employee’s medical situation changes in a way that would be impacted by wearing a respirator; or a licensed healthcare provider says so.
There is no requirement in the WAC for routine medical evaluations. However, as we experienced during at least one inspection over the last couple of years, there are some DOSH inspectors expecting or requiring an expiration date be put on the medical evaluations and they seemed to think that two years was about long enough.
So, for medical evaluations, if the licensed health care professional (LHCP) that did the evaluation did not put an expiration date on the evaluation, you don’t have to perform another one unless you fit one of the other situations that requires a new evaluation. If the LHCP did put in an expiration date on the evaluation, you will need to follow it. However, without an expiration date you can, at your discretion, set a timeline for re-evaluation, such as annually or bi-annually, to ensure you are not missing any health events in your employees’ lives that would require one.
Get more information about L&I Safety and Health standards.