How the OSHA respirator medical evaluation works
Before any employee is fit tested or required to wear a respirator, the employer must provide a medical evaluation to determine whether the employee is physically able to use one — at no cost to the employee (29 CFR 1910.134(e)(1); payment 29 CFR 1910.134(c)(4)). Wearing a respirator adds breathing resistance and physiological burden; the evaluation screens for heart, lung, and other conditions that could make respirator use dangerous.
The standard offers two routes (29 CFR 1910.134(e)(2)): the employee completes the mandatory Appendix C questionnaire, or receives an equivalent initial medical examination. Most employers use the questionnaire — which is exactly what this tool generates, in English or Spanish.
Who completes which section
Appendix C, Part A has two sections. Section 1 and questions 1 to 9 of Section 2 are completed by every respirator wearer. Questions 10 to 15 are required only for employees who will use a full-facepiece respirator or a self-contained breathing apparatus (SCBA), and voluntary for other wearers. The tool above adds them to your packet automatically based on the respirator class you choose.
| Respirator | Assigned protection factor | Required questionnaire |
|---|---|---|
| N95 / disposable filtering facepiece | APF 10 | Section 1 + Section 2 Q1-9 |
| Half-mask air-purifying respirator | APF 10 | Section 1 + Section 2 Q1-9 |
| Full-facepiece air-purifying respirator | APF 50 | Section 1 + Section 2 Q1-15 |
| Powered air-purifying (PAPR), full facepiece | APF 1000 | Section 1 + Section 2 Q1-15 |
| Supplied-air / SCBA, full facepiece | APF up to 10,000 | Section 1 + Section 2 Q1-15 |
APF values from 29 CFR 1910.134(d)(3)(i) Table 1; Section applicability from Appendix C. Construction uses the identical requirements via 29 CFR 1926.103 (adopts 29 CFR 1910.134).
Required use vs. voluntary use (the N95 trap)
The Appendix C medical evaluation is mandatory whenever respirator use is required — either by the employer or by an OSHA substance standard (silica, lead, asbestos, welding fume, etc.). It is the required use that triggers the evaluation, not the respirator class. A worker required to wear an N95 must still be medically evaluated.
The one exception is truly voluntary use of a filtering facepiece (e.g., an N95 a worker chooses to wear when none is required): the employer is exempt from the written program and the medical evaluation for that use, but must give the wearer the information in 29 CFR 1910.134 Appendix D (29 CFR 1910.134(c)(2)(i)). Voluntary use of any other tight-fitting respirator — even a reusable half-mask — still requires a medical evaluation (29 CFR 1910.134(c)(2)). When in doubt, evaluate.
Confidentiality is mandatory — by design
The questionnaire must be administered confidentially, during the employee's normal working hours or at a time and place convenient to the employee (29 CFR 1910.134(e)(4)). The employee's completed answers go directly to the PLHCP — a physician or other licensed health care professional — not to the supervisor or employer. The employer receives only the PLHCP's written recommendation (29 CFR 1910.134(e)(6)). This tool never collects the employee's health answers; the packet routes them to the PLHCP.
Worked examples
Example 1 — N95 on a drywall crew. A laborer will wear a disposable N95 for nuisance dust control on a finish job. Because an N95 is a filtering facepiece (APF 10), the worker completes Section 1 and questions 1 to 9 of Section 2. The packet is administered confidentially, the worker returns it to the clinic, and the PLHCP clears him before his first fit test.
Example 2 — SCBA for confined-space rescue. A standby rescue technician will use a full-facepiece SCBA. Because SCBA triggers Section 2, the packet includes both Section 1 and Section 2 — including the high-altitude, work-effort, and special-responsibility questions. The PLHCP reviews the heavier physiological profile before clearing the technician for that duty.
What to do next
- Generate and administer the packet before scheduling fit testing — the medical evaluation must come first (29 CFR 1910.134(e)(1)).
- Keep the chain confidential. Answers go to the PLHCP; the employer files only the written recommendation.
- Schedule fit testing once cleared — required before first use and at least annually (29 CFR 1910.134(f)(2)).
- Re-evaluate on any trigger in 29 CFR 1910.134(e)(7) (new symptoms, PLHCP/supervisor recommendation, or a substantial increase in physiological burden).
- Retain records — medical records for employment + 30 years (29 CFR 1910.1020); fit-test records until the next test (29 CFR 1910.134(m)(2)(ii)).
Frequently asked questions
When is a respirator medical evaluation required?
OSHA requires a medical evaluation to determine an employee's ability to use a respirator BEFORE the employee is fit tested or required to wear the respirator in the workplace (29 CFR 1910.134(e)(1)). The employer must provide it at no cost to the employee (29 CFR 1910.134(c)(4)).
What is the OSHA Appendix C questionnaire?
Appendix C to 29 CFR 1910.134 is the MANDATORY medical evaluation questionnaire. Part A, Section 1 and questions 1 to 9 of Part A, Section 2 must be completed by every employee selected to use any type of respirator. Questions 10 to 15 of Section 2 are mandatory for employees who will use a full-facepiece respirator or a self-contained breathing apparatus (SCBA), and voluntary for everyone else. The completed questionnaire is reviewed confidentially by a physician or other licensed health care professional (PLHCP) — it is not given to the employer.
Who has to fill out Section 2?
Every employee selected to use a respirator answers questions 1 to 9 of Section 2 (29 CFR 1910.134, Appendix C, Part A), N95 and half-mask wearers included. Questions 10 to 15 are mandatory only for a full-facepiece respirator or a self-contained breathing apparatus (SCBA); for other respirators, answering them is voluntary. This tool adds questions 10 to 15 to the packet automatically when you select a full-facepiece respirator or SCBA.
Who reviews the completed questionnaire?
A physician or other licensed health care professional (PLHCP) reviews the questionnaire and issues a written recommendation on the employee's ability to use a respirator (29 CFR 1910.134(e)(6)). The employer only receives the PLHCP's written recommendation — not the employee's medical answers, which stay confidential.
Does the questionnaire have to be administered confidentially?
Yes. The employer must administer the questionnaire confidentially during the employee's normal working hours or at a time and place convenient to the employee, and must provide the employee an opportunity to discuss the results with the PLHCP (29 CFR 1910.134(e)(4)). The employee's completed answers go to the PLHCP, not the supervisor.
Does this apply to construction work?
Yes. Construction adopts the general-industry respiratory protection standard through 29 CFR 1926.103, which states the requirements are identical to 29 CFR 1910.134. There is no separate construction respirator-content standard, so the same Appendix C medical evaluation and 1910.134(e)(1) timing apply on construction sites.
When must a follow-up or re-evaluation be done?
An additional medical evaluation is required if the employee reports respirator-related medical signs or symptoms, a PLHCP or supervisor recommends re-evaluation, fit-test or program observations indicate a need, or workplace conditions change (e.g., physical work effort, PPE, temperature) that substantially increase the physiological burden (29 CFR 1910.134(e)(7)).
How long are these records kept?
Medical evaluation records are employee medical records kept for the duration of employment plus 30 years under 29 CFR 1910.1020. Fit-test records are kept until the next fit test is administered (29 CFR 1910.134(m)(2)(ii)).
Who pays for the medical evaluation?
The employer. 29 CFR 1910.134(c)(4) requires respirators, training, and medical evaluations at no cost to the employee, and fit testing sits inside the written program required by (c)(1) — so it cannot be charged either. Construction reaches the identical rule through 29 CFR 1926.103. The general PPE payment rules (29 CFR 1910.132(h), construction 29 CFR 1926.95(d)) cover the respirator as equipment, but they do not reach the fit test or the medical evaluation. The narrow exception is a respirator an employee uses voluntarily when none is required.
Can the employee fill out the questionnaire online or does a doctor visit it require?
OSHA allows the medical evaluation to be done either using the Appendix C questionnaire or an equivalent initial medical examination (29 CFR 1910.134(e)(2)). The questionnaire route does not require an in-person exam unless the PLHCP determines one is needed based on the answers. Either way the PLHCP — not the employer — makes the determination.
Is a medical evaluation required for voluntary N95 use?
Not the Appendix C medical evaluation. When employees voluntarily wear a filtering facepiece (e.g., an N95) and the employer does not require it, the employer is exempt from the written respiratory protection program and the medical evaluation for that use — but must still provide the information in Appendix D to those wearers (29 CFR 1910.134(c)(2)(i)). The moment respirator use is required by the employer or by an OSHA standard, the full medical evaluation under 1910.134(e) applies, even for an N95. Voluntary use of any tight-fitting respirator other than a filtering facepiece (e.g., a half-mask APR) still requires a medical evaluation (29 CFR 1910.134(c)(2)).
Sources & verification
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1910/subpart-I/section-1910.134
- https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XVII/part-1926/subpart-D/section-1926.103
- OSHA — 29 CFR 1910.134 Appendix C (mandatory questionnaire)
Regulatory facts verified 2026-08-26. This packet reproduces OSHA's mandatory Appendix C questionnaire as an administrative aid — it is not medical advice, and the medical determination must be made by a physician or other licensed health care professional. State-Plan states may have additional requirements.
Fit-test method & schedule selector →Respirator fit-test log →Respiratory protection program builder →29 CFR 1910.134 (full standard) →