Comment from Ejaz, Muhammad Raza
Muhammad Raza EjazAnalysis pending
Introduction and Standing to Comment<br/><br/>I submit this comment regarding OSHA Docket No. OSHA-2025-0006, Amending the Medical Evaluation Requirements in the Respiratory Protection Standard for Certain Types of Respirators (29 CFR 1910.134).<br/><br/>I am a Chartered Member of the Institution of Occupational Safety and Health (CMIOSH), an ISO 45001 Lead Auditor, ISO 14001 Lead Auditor, and AOSH Certified Master Trainer with more than twelve years of professional experience in occupational health and safety training, auditing, and management across construction, oil and gas, and industrial sectors in Saudi Arabia and Pakistan. This comment is submitted in my individual professional capacity.<br/><br/>Summary Position<br/><br/>I respectfully recommend that OSHA not proceed with the proposal to remove medical evaluation requirements for filtering facepiece respirators and loose fitting powered air purifying respirators (PAPRs). In my professional opinion, the current medical evaluation requirement remains an important worker protection measure and should be retained or modified through a targeted risk based approach rather than eliminated.<br/><br/>Comment 1 — Medical Evaluation Is an Essential Worker Protection<br/><br/>Medical evaluation serves as the primary mechanism for identifying underlying cardiovascular and pulmonary conditions before workers use respiratory protection. In industries such as construction, oil and gas, manufacturing, and warehousing, workers may have undiagnosed medical conditions that increase the risks associated with respirator use. Eliminating the requirement would remove an important safeguard that helps employers identify workers who may require additional assessment before respirator use.<br/><br/>Comment 2 — Consistency With ISO 45001 and Risk Management Principles<br/><br/>ISO 45001 emphasizes the importance of competency, fitness for duty, and risk based controls in occupational health and safety management systems. Respiratory protection depends not only on equipment selection but also on the worker's ability to safely use that equipment. Medical evaluation provides an important mechanism for verifying worker fitness and maintaining consistency between OSHA requirements and internationally recognized occupational health and safety practices.<br/><br/>Comment 3 — Risk Based Alternative to Complete Removal<br/><br/>If OSHA's objective is to reduce administrative burden, a more balanced approach would be to adopt a tiered, risk based framework. Full medical evaluations could be retained for workers with identified health concerns or those who use respirators for extended periods, while simplified screening procedures could be permitted for limited duration and lower risk applications. This approach would reduce compliance costs while preserving essential worker protections.<br/><br/>Comment 4 — Consideration of the ACCSH Recommendation<br/><br/>The Advisory Committee on Construction Safety and Health recommended that OSHA not proceed with the proposed removal and instead continue evaluating best practices for employers. This recommendation reflects practical field experience and recognizes the important role medical evaluations play in respiratory protection programs. OSHA should give substantial weight to this recommendation during its review of the proposed rule.<br/><br/>Conclusion<br/><br/>For the reasons discussed above, I respectfully urge OSHA to retain the medical evaluation requirement or adopt a targeted risk based modification rather than eliminating the requirement entirely. Thank you for the opportunity to comment on this proposal. I appreciate OSHA's continued efforts to protect worker health and safety and remain available to provide additional professional input if requested.<br/><br/>Respectfully submitted,<br/>Muhammad Raza Ejaz<br/>CMIOSH; ISO 45001 Lead Auditor; ISO 14001 Lead Auditor; AOSH Certified Master Trainer<br/>OTHM Level 7 Diploma in OHS Management; NEBOSH International Diploma; ProQual Level 6 NVQ Diploma in OHS Practice<br/>Email: razaijaz24434@gmail.com<br/>