OSHA Seeks to Eliminate Medical Evaluation Requirement for Certain Respirators

The proposed rule would exempt filtering facepiece and loose-fitting powered air-purifying respirator users from mandatory medical clearance, citing minimal health risk and significant cost savings.

• By Stasia DeMarco
• Oct 15, 2025

The Occupational Safety and Health Administration (OSHA) is proposing a change to its Respiratory Protection Standard that would remove the requirement for medical evaluations when workers are assigned certain types of respirators. The agency announced on July 1, 2025, that it intends to exempt employees using filtering facepiece respirators, such as disposable N95 masks, and loose-fitting powered air-purifying respirators (PAPRs) from the longstanding obligation to undergo a medical clearance before being fit tested or put to work with these devices. 

If adopted, the revision would mark a significant shift in how OSHA regulates routine respirator use. Since 1998, employers have been required to arrange for a physician or licensed health care professional to evaluate workers’ fitness before they don any type of respirator. This process usually begins with a mandatory questionnaire and, if necessary, a follow-up exam to screen for conditions such as asthma, cardiovascular disease, or anxiety disorders that could be aggravated by respirator use. But OSHA has concluded that the evidence supporting this requirement for FFRs and loose-fitting PAPRs is weak, particularly when compared with respirators that are heavier, tighter-fitting, or designed for more hazardous environments. 

Why the Change Now? 

The agency’s reasoning rests on both science and experience. When the medical evaluation requirement was established, OSHA relied on research involving military and scuba equipment that placed far greater physiological demands on users than a lightweight disposable mask. More recent literature has shown that N95s and PAPRs cause only minor, temporary changes in breathing and heart rate under typical workplace conditions, effects that fall within normal limits for healthy individuals. The COVID-19 pandemic further tested the system: millions of employees across industries wore these respirators daily, often for full shifts and often without prior medical clearance. Despite this widespread use, OSHA has found no evidence of widespread health complications stemming from the absence of evaluations. 

In practice, very few employees are ever barred from respirator use after completing a medical evaluation. Studies cited by OSHA show that between one and two percent of workers are restricted, most often for reasons such as claustrophobia or pregnancy rather than clear-cut medical risks. The agency now argues that the process may not meaningfully prevent harm when applied to FFRs and PAPRs, especially since these respirators are not used in immediately dangerous to life or health (IDLH) environments. Workers who do experience discomfort or symptoms can safely remove the equipment and seek follow-up care without facing extreme exposure. 

Cost Savings and Administrative Relief 

The potential economic impact of the change is considerable. OSHA estimates that about 2.7 million employees currently use FFRs or loose-fitting PAPRs in the private sector. Eliminating the pre-use medical clearance for these groups would mean that roughly 1.2 million medical questionnaires and more than 250,000 follow-up exams would no longer be conducted each year. Recordkeeping requirements would also shrink, as employers would no longer have to store and maintain so many individual medical records. Taken together, these adjustments could save employers more than $80 million annually, or nearly $700 million over the next decade. OSHA notes that the majority of these savings would accrue to small businesses, which make up the bulk of firms covered by the Respiratory Protection Standard. 

Even with this proposed change, OSHA emphasizes that the broader obligations of the standard remain fully in force. Employers would still be required to evaluate workplace hazards, select appropriate respirators, conduct fit testing where applicable, provide training, and maintain equipment. The exemption would apply only to the initial medical evaluation step for FFR and PAPR users. OSHA also clarifies that if a worker does experience symptoms while wearing one of these respirators, the employer would be expected to arrange a medical evaluation before allowing continued use. 

The proposal arrives after years of tension between regulatory requirements and practical realities, particularly during the COVID-19 crisis. Employers who scrambled to provide N95s for frontline workers sometimes faced OSHA inspections and citations for failing to complete medical evaluations quickly enough. The agency’s current stance acknowledges those challenges and signals a move toward a more risk-based approach, where medical clearance is reserved for respirators that truly pose a physiological burden. 

Industry Perspective 

For safety professionals, the implications are significant. In industries like healthcare, construction, agriculture, and manufacturing, where FFRs and PAPRs are commonly used, the rule could reduce administrative burdens while still preserving critical protections such as fit testing and training. Respirators that create higher levels of strain — including tight-fitting elastomeric respirators, supplied-air systems, and self-contained breathing apparatus — would remain subject to medical evaluations. 

The rulemaking process is still at an early stage. OSHA is accepting public comments on the proposal until September 2, 2025, and will hold an informal public hearing if requested. Comments can be submitted electronically at www.regulations.gov under Docket No. OSHA–2025–0006. Once the comment period closes, OSHA will review the feedback and may revise the proposal before issuing a final rule. If adopted, the change would also extend to construction and maritime industries, which incorporate the general respiratory protection rule by reference. The Advisory Committee on Construction Safety and Health is expected to review the proposal and provide recommendations before the final decision is made. 

What Safety Professionals Should Watch 

For now, employers and safety managers should closely follow the progress of this rulemaking. If implemented, the exemption could streamline compliance programs, reduce costs, and shift resources toward other elements of respiratory protection that more directly impact worker safety. But the proposal also raises questions about whether case-by-case medical evaluations will adequately protect vulnerable workers. OSHA is actively soliciting data, experiences, and perspectives from the field to inform its final decision. 

The bottom line is that OSHA is rethinking how medical evaluations fit into its overall respiratory protection framework. By focusing on the devices that present minimal health risks, the agency hopes to balance worker safety with regulatory efficiency. For the millions of workers who rely on N95s and PAPRs every day, and for the safety managers who oversee their use, the next several months will determine whether medical clearance becomes a thing of the past for these respirators. 

This article originally appeared in the October 2025 issue of Occupational Health & Safety.