Proposed OSHA Changes Put Respiratory Protection Programs in Focus

Potential changes to medical evaluation requirements could reduce administrative burdens, but effective respirator selection, exposure assessment, training and other core protections remain essential.

• By Bernard L. Fontaine Jr.
• Oct 15, 2026

Respiratory protection is the final line of defense in the hierarchy of controls. OEHS professionals first seek to eliminate hazards, substitute less hazardous materials, implement engineering controls and improve work practices before selecting respirators. When these measures cannot adequately control airborne exposures, respirators are necessary to prevent occupational illness and disease.

Effective respiratory protection has repeatedly proven valuable across industries where workers may encounter hazardous airborne exposures. A well-designed respiratory protection program includes hazard assessment, respirator selection, medical evaluation, fit testing where required, training, maintenance and periodic program evaluation under OSHA’s Respiratory Protection Standard, 29 CFR 1910.134. Recent federal proposals have prompted questions about whether some elements of these programs can be streamlined without jeopardizing worker protections.

Background

OSHA’s Respiratory Protection Standard requires employers to develop written respiratory protection programs whenever respirators are necessary to protect worker health. These programs address exposure assessment, respirator selection, medical evaluation, fit testing, user seal checks, maintenance, cleaning and storage, training and program evaluation.

Since its adoption in 1998, the standard has been recognized internationally as one of the most comprehensive respiratory protection regulations. Numerous OSHA substance-specific standards, including those covering asbestos, benzene, formaldehyde, lead, cadmium, hexavalent chromium and inorganic arsenic, contain respiratory protection provisions that either supplement or reference 29 CFR 1910.134.

Proposed Federal Changes

One of OSHA’s most widely discussed proposals would eliminate mandatory pre-use medical examinations for workers wearing filtering facepiece respirators, such as N95 respirators, and loose-fitting powered air-purifying respirators, or PAPRs.

The proposal would not eliminate medical assessments for employees using tight-fitting half-mask respirators, full-facepiece respirators, supplied-air respirators or self-contained breathing apparatus, or SCBA.

OSHA has indicated that filtering facepiece respirators and loose-fitting PAPRs generally impose a relatively low physiological burden on healthy users and that existing evidence does not support mandatory clinical examinations for every worker using these devices.

Why Did OSHA Propose the Changes?

According to OSHA, the proposed revisions are intended to reduce unnecessary regulatory burdens and administrative costs, eliminate requirements considered unsupported by current scientific evidence, simplify employer compliance and harmonize older substance-specific standards with the general OSHA Respiratory Protection Standard.

The proposals form part of a broader federal effort to review existing regulations for efficiency while maintaining worker protection.

Possible Benefits

Supporters of the proposed revisions suggest several possible advantages. Health examinations require scheduling, physician review, documentation and recordkeeping. Eliminating mandatory evaluations for certain respirator users could reduce administrative costs and expedite respirator deployment.

The change could also provide employers with greater flexibility, particularly large organizations with thousands of workers who may occasionally use N95 respirators.

During wildfires or emergency response operations, reducing unnecessary administrative delays could also enable faster respirator distribution.

Possible Issues

OEHS and occupational medicine professionals have identified several areas that justify careful consideration.

Health examinations occasionally identify workers with previously undiagnosed or underlying medical conditions, such as severe asthma, chronic obstructive pulmonary disease, cardiovascular disease, claustrophobia and other conditions that could affect respirator use. Although filtering facepiece respirators generally create less breathing resistance than elastomeric respirators, some individuals may still experience physiological or psychological difficulties. OEHS professionals should seek a medical opinion when they question whether a worker can safely use a respirator.

Medical questionnaires can also help identify occupational health concerns beyond respirator tolerance. Removing this requirement could reduce opportunities for early intervention or for identifying health conditions relevant to respirator use.

Medical assessments also help promote consistent implementation across employers. Without regulatory requirements or medical practitioner advice, practices could become more variable, particularly when production, assigned work tasks, exposure levels, environmental conditions or personnel change.

Effects on High-Hazard Industries

The proposed changes are unlikely to affect respirator selection for many high-risk operations because substance-specific OSHA standards and exposure assessments remain applicable.

TABLE 1. OSHA STANDARDS REQUIRING RESPIRATORY PROTECTION

For workers using tight-fitting respirators, medical examinations and fit testing would continue under the proposal.

Selection and Use Considerations

Regardless of whether the proposed changes are finalized, several fundamentals of respiratory protection remain important.

Exposure Risk Assessment: Respirators should never substitute for adequate exposure characterization. Comprehensive sampling remains necessary to evaluate worker health during routine and nonroutine work. Exposure risk assessments should evaluate potential job functions and work tasks and should be repeated when production, assigned tasks, occupational exposure levels, environmental conditions or personnel change.

Engineering Controls: Engineering controls remain OSHA’s preferred method for reducing exposure. Examples include local exhaust ventilation, process enclosure, wet methods and automation. Evaluate engineering controls for performance based on design specifications and production schedules.

Appropriate Respirator Selection: Selection should continue to consider the assigned protection factor, or APF; known exposure concentration; chemical, radiological and biological properties; oxygen concentration; and immediately dangerous to life or health, or IDLH, conditions during emergency response or self-rescue. When exposure cannot be evaluated, the OEHS professional should consider control-banding options.

Worker Training: Training remains critical regardless of medical evaluation requirements. Workers should understand proper donning procedures, restrictions on respirator selection and use, user seal checks, storage, maintenance and recognition of respirator malfunction. Training should be repeated when workers fail to follow written standard operating procedures or when exposure risk assessments indicate that the level of respiratory protection should change.

Looking Ahead

The proposed revisions highlight the challenge of balancing worker protection with efficient regulatory implementation. If finalized, the changes may reduce employers’ administrative burdens while maintaining core requirements for respirator selection, fit testing, training and hazard assessment.

At the same time, OEHS professionals should carefully consider whether reduced medical screening could affect workers with underlying conditions or diminish opportunities to identify health issues relevant to respirator use.

Regardless of the outcome of the rulemaking, employers and OEHS professionals should continue to prioritize elimination and engineering controls, conduct quantitative exposure assessments, select respirators based on measured risk and maintain comprehensive respiratory protection programs. Incorporate occupational medicine expertise when appropriate.

The proposed revisions represent an evolution in OSHA’s approach to respiratory protection program administration, not a wholesale change in respiratory protection philosophy. OEHS professionals remain responsible for applying the hierarchy of controls, conducting exposure assessments and ensuring respiratory protection programs are tailored to specific workplace hazards.

Regardless of regulatory changes, the objective remains unchanged: preventing occupational respiratory disease through sound science, effective risk management and evidence-based professional practice.

This article originally appeared in the October 2026 issue of Occupational Health & Safety.