Respirator Medical Evaluation: 1910.134 Appendix C Questionnaire Explained

What does 1910.134 require before an employee wears a respirator?

29 CFR 1910.134(e) requires a medical evaluation to determine an employee's ability to use a respirator before that employee is fit tested or required to wear one on the job, and again whenever conditions change — a new respirator type, a physician's recommendation for reevaluation, or signs of a medical condition that could affect the employee's ability to wear one safely. The evaluation has to be performed by a physician or other licensed health care professional (PLHCP), and the standard's mandatory questionnaire, Appendix C, is the vehicle most employers use to gather the information the PLHCP needs to make that call. Employers can't skip this step by assuming a respirator is "voluntary use only" — even voluntary use of a filtering facepiece respirator carries a lighter medical-evaluation obligation under Appendix D, not a full exemption.

What's on the Appendix C questionnaire?

Appendix C is split into two parts. Part A, Section 1 covers administrative information (employer, respirator type, work conditions) that every employee completes. Part A, Section 2 is the mandatory medical history section, asking about height and weight, prior respirator use and any problems with it, and a checklist of conditions — asthma, chronic bronchitis, emphysema, pneumonia, chest pain, heart conditions, high blood pressure, seizures, claustrophobia, and more — that can affect tolerance for the added breathing resistance, weight, and heat stress a respirator introduces. Part B contains supplemental questions the PLHCP can require for employees using tight-fitting full-facepiece or SCBA respirators in high-hazard environments, covering additional cardiovascular and respiratory history, and can also require a physical exam if the questionnaire responses warrant it.

Section	Who completes it	Purpose
Part A, Section 1	Employee	Administrative/employer info
Part A, Section 2	Employee	Mandatory medical history
Part B	Employee, PLHCP discretion	Supplemental history for higher-hazard respirator use

Who is allowed to review the questionnaire?

Only a PLHCP can review Appendix C responses and issue a clearance determination — a supervisor, safety manager, or HR staffer reviewing the form and deciding "looks fine" doesn't satisfy the standard, even if no red flags are obvious. The PLHCP's job is to determine whether the employee can wear the specific respirator model and use conditions described, follow up directly with the employee on any flagged answer, and if needed, order additional tests or a physical exam before issuing written recommendations. Employers keep those recommendations on file and act on any restrictions the PLHCP notes — a limit on respirator type, a required follow-up interval, or in some cases a determination that the employee cannot safely wear the respirator model in question.

How does medical clearance connect to fit testing?

Medical clearance has to happen before fit testing, not alongside it or after — 1910.134(e)(1) is explicit that the evaluation precedes both fit testing and actual respirator use. In practice this means an employer scheduling an annual fit-test day needs medical clearance status confirmed for every employee on that list first; an employee whose questionnaire triggers a PLHCP follow-up that isn't resolved yet shouldn't be fit tested until clearance comes through. Programs that batch these two steps together on the same day sometimes discover the gap only when a PLHCP flags someone mid-session, which forces a reschedule. Building in a lead time of at least a few days between questionnaire submission and the fit-test date gives the PLHCP room to review and follow up without holding up the whole group.

How does Foster handle medical evaluation and fit testing together

Foster coordinates the Appendix C questionnaire distribution and PLHCP review as part of scheduling on-site fit-test visits, so employers aren't managing two separate vendors or timelines. We confirm clearance status for each employee before the fit-test technician arrives on site, flagging any outstanding PLHCP follow-ups so they don't turn into a wasted trip for that employee. For programs using both qualitative and quantitative fit testing across different respirator classes, we also track which clearance covers which respirator type, since a PLHCP recommendation can be specific to a model or category rather than a blanket approval.

Frequently asked questions

Does every employee need a new questionnaire every year?

No. 1910.134 doesn't set a fixed annual requirement for the questionnaire itself — a new evaluation is required when an employee reports medical signs or symptoms related to respirator use, when a PLHCP, supervisor, or the respirator program administrator identifies a need for reevaluation, when a change in workplace conditions increases physiological burden, or when the employee's respirator type changes. Many employers do refresh the questionnaire annually alongside fit testing as a practical matter, but it isn't an OSHA-mandated interval on its own.

Can an employee fill out Part B if the employer doesn't require it?

Yes. Appendix C allows the PLHCP to require Part B for tight-fitting full-facepiece or SCBA use, but an employer can also choose to include it for other respirator classes if it wants a more complete medical picture — the standard sets the floor, not a ceiling.

What happens if a PLHCP recommends against respirator use?

The employer has to accommodate that determination for the respirator in question. Depending on the job and the specific restriction, that can mean assigning a different respirator model the PLHCP does clear, adjusting the role to reduce exposure, or in some cases involving occupational health and HR on broader accommodation options.

Is the questionnaire confidential?

Yes. Appendix C responses go to the PLHCP, and the employer only receives the PLHCP's written recommendations — not the underlying medical answers — unless the employee consents otherwise.

Does a voluntary-use respirator still need a medical evaluation?

Voluntary use of a filtering facepiece respirator (like an N95) is covered by Appendix D, which is an information sheet rather than a medical questionnaire, and doesn't require PLHCP review. Voluntary use of any other respirator type still requires the full medical evaluation.

Foster coordinates medical evaluation and fit testing as one scheduled visit — see our fit testing services or the broader on-site testing program, and request a quote to get a program started. For more on how medical clearance connects to periodic spirometry surveillance, see our post on spirometry medical surveillance under 1910.1053.