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OSHA Proposes Eliminating Medical Evaluation Requirement for Some Respirators

    Client Alerts
  • July 25, 2025

As part of its deregulatory initiative on July 1, the federal Occupational Safety and Health Administration proposed deleting requirements for medical evaluations before employees are permitted to use certain classes of respirators. The rule would eliminate the medical evaluation requirement for filtering facepiece respirators (FFRs) such as N95 masks, or loose-fitting powered air-purifying respirators (PAPRs). The changes would not affect medical evaluation requirements for other types of respirators such as tight-fitting air-purifying or supplied-air respirators.

The medical evaluation requirements became a source of consternation for employers during the COVID-19 pandemic. Companies that promptly reacted to exposure risk by providing employees with personal protective masks sometimes faced OSHA inspections and citations when they did not complete medical certification before providing the masks. In the proposed rule, OSHA recognizes the lack of serious medical threats posed by use of FFRs and PAPRs. In the event that an employee experiences medical symptoms from use of such masks, employers would be required to obtain the medical evaluation on a case-by-case basis before continuing their use with that worker.

The proposal does not change employers' responsibility to provide PPE, or to fit test and train employees on the proper use of respirators. OSHA is accepting comments on the proposed rule through September 2, 2025.

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