OSHA Reopens Comment Period on Respirator Medical Evaluation Rule: What Employers Need to Know Before July 6

Background: Why OSHA Is Proposing This Change

Under the current Respiratory Protection Standard, employers must provide a medical evaluation for every employee required to wear any type of respirator — before fit testing or use can begin. This evaluation typically involves administering the OSHA Respirator Medical Evaluation Questionnaire (Appendix C of 29 CFR 1910.134) and obtaining a written recommendation from a physician or other licensed healthcare professional (PLHCP).

OSHA first proposed amending this requirement in July 2025, citing several key findings:

• Minimal physiological burden: Research shows that filtering facepiece respirators and loose-fitting PAPRs impose minimal breathing resistance and physiological stress on wearers compared to tight-fitting elastomeric or supplied-air respirators.
• COVID-19 pandemic evidence: During the pandemic, millions of workers used N95 respirators without prior medical clearance, and no evidence of widespread harm attributable to the absence of medical evaluation emerged.
• Cost and compliance barriers: The mandatory evaluation adds significant time and cost to onboarding workers into respiratory protection programs, particularly for employers in construction, healthcare, and manufacturing who rely heavily on disposable FFRs.

What Changed on June 3, 2026

The June 3, 2026 Federal Register notice (91 FR 33130, Docket No. OSHA-2025-0006) reopened the public comment period following consideration by OSHA's Advisory Committee on Construction Safety and Health (ACCSH). This is not a new proposed rule — it is a reopening of the comment period on the original July 2025 proposal to allow additional stakeholder input informed by the ACCSH's review.

Key details:

• Docket Number: OSHA-2025-0006
• RIN: 1218-AD48
• Comment Deadline: July 6, 2026
• Submission: Electronic comments at regulations.gov using Docket No. OSHA-2025-0006

What the Proposed Rule Would Change

If finalized, the rule would specifically:

Remove Mandatory Medical Evaluations for Two Respirator Types

1. Filtering facepiece respirators (FFRs) — including N95, N99, N100, R95, P95, P99, and P100 disposable respirators
2. Loose-fitting powered air-purifying respirators (PAPRs) — hoods, helmets, or loose-fitting facepieces connected to a battery-powered blower unit

What Stays the Same

The proposed rule would not change:

• Medical evaluation requirements for tight-fitting elastomeric respirators (half-face or full-face)
• Medical evaluation requirements for tight-fitting PAPRs
• Medical evaluations for supplied-air respirators (SARs) or self-contained breathing apparatus (SCBA)
• Fit testing requirements (annual quantitative or qualitative fit testing for FFRs)
• Hazard assessment and respirator selection requirements
• Training and maintenance requirements
• The employer obligation to provide a medical evaluation if an employee reports symptoms or health complaints related to respirator use

Projected Impact and Cost Savings

OSHA estimates this rule could save U.S. businesses over $600 million across ten years by reducing costs associated with:

• Administering the OSHA medical questionnaire
• PLHCP review fees and follow-up examinations
• Delays in fit testing and worker onboarding while awaiting medical clearance
• Administrative tracking and recordkeeping for medical evaluation records

Industries expected to benefit most include healthcare, construction, manufacturing, and warehousing — sectors where large numbers of employees use disposable N95 respirators as part of routine operations.

What This Means for Employers

Right Now: Continue Current Compliance

Until the rule is finalized, employers must continue to comply with the current version of 29 CFR 1910.134. This means:

• Providing a medical evaluation before any employee uses a respirator
• Using the OSHA Appendix C questionnaire or an equivalent
• Obtaining a PLHCP written recommendation
• Maintaining confidentiality of medical evaluation records
• Providing additional evaluations when conditions change or symptoms arise

If the Rule Is Finalized

Employers should prepare for the following operational changes:

1. Faster onboarding: Workers assigned to N95 or loose-fitting PAPR programs could proceed directly to fit testing without waiting for medical clearance.
2. Reduced costs: Employers would save on PLHCP consultation fees, questionnaire administration, and follow-up exams for FFR and loose-fitting PAPR users.
3. Simplified recordkeeping: The medical evaluation documentation burden would be reduced for FFR-only programs.
4. Ongoing symptom-based duty: Employers would still be required to provide medical evaluation if a worker reports health symptoms related to respirator use — this obligation does not disappear.

Submitting Comments

Employers who want to influence the final rule should submit comments before July 6, 2026:

1. Go to regulations.gov
2. Search for Docket No. OSHA-2025-0006
3. Click "Comment" and follow the submission instructions
4. If uploading attachments, number them for easy identification

OSHA considers all public comments when developing a final rule. Industry-specific data on costs, safety outcomes, or implementation challenges are especially valuable.

How to Prepare Your Respiratory Protection Program

Regardless of when the final rule takes effect, employers should take these steps now:

• Audit your respirator inventory: Identify which employees use FFRs vs. tight-fitting elastomeric respirators. The proposed change only applies to the former category.
• Review your written respiratory protection program: Ensure your program distinguishes between respirator types and can be quickly updated once a final rule publishes.
• Maintain symptom-reporting procedures: Even if the medical evaluation requirement is removed for FFRs, employers must still have a process for workers to report respirator-related symptoms and receive prompt evaluation.
• Track the rulemaking timeline: Monitor the OSHA Respiratory Protection rulemaking page and the Federal Register for updates on the final rule.
• Consult your occupational health provider: Discuss how this change would affect your existing medical surveillance program and whether your provider recommends continuing voluntary evaluations for certain high-risk populations.

For a broader overview of how this rule fits into the full landscape of 2026 regulatory changes, BlueHive's 2026 OSHA Changes: What Has Taken Effect, What is Coming white paper provides a comprehensive compliance timeline and employer action guide.

Broader Context: OSHA's Regulatory Agenda in 2026

This proposed rule is part of OSHA's broader effort to modernize standards based on current evidence and reduce unnecessary compliance burdens while maintaining worker protections. Other notable 2026 regulatory actions include:

• Heat Illness Prevention Rule: Still in development, with the updated National Emphasis Program providing the enforcement framework in the interim.
• HazCom 2024 (GHS Revision 7): Employer compliance deadline of November 20, 2026 for updated chemical labeling and safety data sheets.
• Electronic Recordkeeping Expansion: Broader electronic submission requirements for injury and illness data under updated 29 CFR 1904.

Employers managing multiple compliance deadlines simultaneously should consider developing a unified regulatory calendar to track all key dates and action items.

Sources

• OSHA Proposed Rule: Amending the Medical Evaluation Requirements in the Respiratory Protection Standard for Certain Types of Respirators — Federal Register, June 3, 2026 (91 FR 33130)
• Original Proposed Rule — Federal Register, July 1, 2025 (90 FR 28463)
• OSHA Respiratory Protection Standard — 29 CFR 1910.134
• Regulations.gov — Docket No. OSHA-2025-0006
• OSHA Respiratory Protection Standards Page
• BlueHive — 2026 OSHA Changes: What Has Taken Effect, What is Coming
• OSHA Heat Injury and Illness Prevention Rulemaking
• OSHA Hazard Communication Standard