[MCOH-EH] Fit Testing in Pre-Employment

[David S. Cockrum]

Thanks Erica. I was able to do a few minutes of deep dive into the OSHA website, what I found was that the fit test must be performed “at no cost to the employee,” so doing it at pre-employment fits within that category. There is also a statement that the questionnaire and any medical exams must be done “during the employee’s normal working hours.” But since a pre-employment eval is on someone not employed, this rule doesn’t really fit.

Still interested to see if there are any other interpretations that I may have missed.

David

David S. Cockrum, MD, MPH
He/Him/His
Medical Director & Section Chief
Occupational & Environmental Medicine
Department of Medicine
Tel (603) 653-3881 | Fax (603) 650-0930
Dartmouth-Health.org

Dartmouth Hitchcock Medical Center
[cid:image001.png at 01DA7AB9.D4B23C40]<https://www.dartmouth-health.org/>     [cid:image002.png at 01DA7AB9.D4B23C40]

From: Erika Sweet <esweet at dhs.lacounty.gov>
Sent: Wednesday, March 20, 2024 11:21 AM
To: MCOH-EH <mcoh-eh at mylist.net>
Cc: David S. Cockrum <David.S.Cockrum at hitchcock.org>
Subject: RE: Fit Testing in Pre-Employment **EXTERNAL**

We perform screening for vaccine preventable disease and respirator fit testing during the post offer screening appointment for candidates. It has never been brought up that candidates need to be paid for this screening. Thanks, Erika Erika


We perform screening for vaccine preventable disease and respirator fit testing during the post offer screening appointment for candidates. It has never been brought up that candidates need to be paid for this screening.

Thanks,
Erika

Erika Sweet, RN, MSN, NP, COHN-S
Director of Employee Health Services
Los Angeles County Department of Health Services
Office Number: (424) 306-4060
esweet at dhs.lacounty.gov<mailto:esweet at dhs.lacounty.gov>

[cid:image003.png at 01DA7AB9.D4B23C40]




From: MCOH-EH <mcoh-eh-bounces at mylist.net<mailto:mcoh-eh-bounces at mylist.net>> On Behalf Of David S. Cockrum via MCOH-EH
Sent: Tuesday, March 19, 2024 5:20 AM
To: MCOH-EH <mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>>
Cc: David S. Cockrum <David.S.Cockrum at hitchcock.org<mailto:David.S.Cockrum at hitchcock.org>>
Subject: [MCOH-EH] Fit Testing in Pre-Employment

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Hello-

Our leadership has asked if we could separate OSHA-mandated respirator fit testing from new employee orientation day. Currently, those who need it attend a 45-60 minute group session the afternoon of orientation where they are trained in donning/doffing then fit tested.

At other locations, I have seen the fit testing process included in the pre-employment medical evaluation. While there are some potential caveats to this, one issue has been raised, I was hoping someone in this community has experience with this. Under the OSHA RPP, it is a requirement that employees must be paid for their time to perform fit testing. This can mean as part of their regular work day, or if brought in from off work, paid separately for their time. Does this pay requirement apply to job candidates? I’ve never heard that said, but it certainly presents a regulatory concern if it is true.

Thoughts/comments?

Thanks,

David

David S. Cockrum, MD, MPH
He/Him/His
Medical Director & Section Chief
Occupational & Environmental Medicine
Department of Medicine
Tel (603) 653-3881 | Fax (603) 650-0930
Dartmouth-Health.org

Dartmouth Hitchcock Medical Center
[cid:image001.png at 01DA7AB9.D4B23C40][secure-web.cisco.com]<https://urldefense.com/v3/__https:/secure-web.cisco.com/1xV2Kr0fMn3S9ax8P8eCc3T_U3YkT6QhTrHhSCRgIA6W8Rv4dISISCOoG0TllnRo9pjtMFFmX1sYr0VUS4CTK77E25qx9UVMq9BD9zl0FDio2NN9abYURD88uJcscf3jvmnlSI1-ooEkPB0Wy4RB4vSQuB0HQmrfEAz5oORkCeJRjwdutqX2Tcizap-kx6FmFXo8-zCRfhAGstwKpQFsUCb6b7x-YF69gvE4Qov00qoL4YjlaPheUZYXyiK1jgeyp9ll_DuRseDTb4qoQVGBD1X1nuNRtZhO3PwMuEDT8C3TESZmuboTcAtpmTMlCMTW2y_amsA18xQPNsrCLEErg3d4qHh0ih4SALczst4n2ud6zIXAoF4UDTT1dqpeqTNUG/https*3A*2F*2Fwww.dartmouth-health.org*2F__;JSUlJQ!!Eh6P0A!UfXTrsR7VQQQ62MTjOa7k9P-gowpJj2AOj_2YtCdHa0xy6pE44howVTpaDqCDm9uJbjg0Pdz5q-R5x8jvFNir_9vzF0Xjs8$>     [cid:image002.png at 01DA7AB9.D4B23C40]



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