Should the employer ensure that respirator medical evaluation questionnaires are not kept with employee records?
Reply 2: Yes. Medical records are to be kept confidential and separate from other employee records (e.g., timesheets, training). Question 3: Is the employer only required to maintain the written recommendation regarding an employee’s medical determination from the PLHCP in accordance with 1910.134(e)(6)? Reply 3: All medical records (including the medical determination) must be kept and made available by the employer as required by 1910.134(m)(1) and 1910.1020. Question 4: Is it acceptable for the program administrator to “pre-complete” questions 10-19 of the respirator medical questionnaire with standard information? Reply 4: Pre-filling any part of the medical questionnaire by the employer is not appropriate. The employee should be trained by the employer, so that the employee can answer the questions. Furthermore, the requirement under 1910.134(e)(5) requires for the employer to provide the PLHCP with supplemental information for each employee. This requires providing the PLHCP with
