[MCOH-EH] Respiratory protection standard compliance for non-employed clinicians, others in healthcare workplace

[Galaid Edward I]

I cross posted this, since I think the issue is generalizable.

For those in MCOH...do you oversee 1910.134 compliance for the community clinicians and others who work in your facility, or do you place the responsibility solely on them and their employers to comply.
And do you keep track of their compliance, for example in the Med Staff office.

This is from the standard (emphasis mine)

1910.134(a)(2)<https://www.osha.gov/pls/oshaweb/owalink.query_links?src_doc_type=STANDARDS&src_unique_file=1910_0134&src_anchor_name=1910.134(a)(2)>
"A respirator shall be provided to each employee when such equipment is necessary to protect the health of such employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program..."

In my system, Safety has managed the respiratory protection program.  I might get involved if there is an issue in the questionnaire responses...but I don't remember the last time that happened.

Ed Galaid


Edward I. Galaid, MD, MPH, FACOEM
ABIM, ABPM (OM)
Medical Director, Roper St. Francis Physician Partners Occupational Medicine
Charleston, SC
Member, ACOEM Task Group,  Guidance for the Medical Evaluation of Law Enforcement Officers
Special Expert, NFPA Fire Service Occupational Safety & Health (FIX-AAA) Committee
(O) 843-402-5053


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