The OSHA Respirator Medical Evaluation Questionnaire, Explained in Plain English

Every respiratory protection program starts in the same place. Before the fit test, before the training, before anyone puts on an N95 or a half-face respirator, OSHA requires a medical evaluation. Skip it and every fit test you run afterward is built on a compliance gap that shows up in audits and citations.

This guide walks through what the questionnaire asks, who is allowed to review it, what happens when an employee's answers raise a flag, and how the process works when you run it 100% online.

What the MEQ Is and Where It Comes From

The questionnaire is not a form your occupational health clinic invented. It is a federal document, published as Appendix C of 29 CFR 1910.134, and its use is mandatory. Employers may use the Appendix C questionnaire or a medical evaluation that obtains the same information.

The questionnaire is organized in two parts:

• Part A, Section 1: identifying information every employee completes (name, age, job duties, respirator type)
• Part A, Section 2: required health questions covering cardiopulmonary history, symptoms like shortness of breath or chest pain, medications, prior respirator problems, and conditions like claustrophobia
• Part B: discretionary questions the PLHCP may add

Employees answer in private. That privacy is not a courtesy, it is a design requirement, and it matters for how you handle the completed forms (more on that below).

Who Must Complete It, and When

29 CFR 1910.134(e)(1) requires a medical evaluation before fit testing and before first use of a respirator. That covers:

• New hires whose roles require respirators
• Existing employees moving into respirator-required roles
• Voluntary users of respirators other than filtering facepieces (voluntary N95-only use follows Appendix D instead)
• Employees whose health status or working conditions change (see below)

OSHA does not require an annual re-evaluation by default. Re-evaluation is triggered by events: an employee reports symptoms, a PLHCP or supervisor recommends it, fit test observations raise questions, or workplace conditions change the physiological burden. Many employers in healthcare and senior living re-evaluate on an annual cycle anyway because it aligns with their N95 fit testing refresh. Our guide to annual respirator medical evaluations covers the trigger events in detail.

Who Reviews It: The PLHCP Requirement

The standard requires review by a physician or other licensed health care professional. Not a safety manager, not an HR coordinator, not software alone. A PLHCP must:

• Review the responses under the license of their state
• Determine fitness for respirator use, including any limitations
• Provide a written recommendation to the employer covering only the clearance determination

This is the part of the standard that separates real programs from paper-shuffling. VestMed's evaluations are reviewed by our own staff PLHCPs with rotating coverage, operating under a physician-founded, physician-led medical direction structure. Most employees clear in minutes through the screening algorithm; answers that need clinical judgment route to a PLHCP call-back instead of an automatic pass. That distinction matters in an audit: an algorithm can screen, but a clearance determination carries a clinician's license behind it.

See how online MEQ review works →

What the Employer Sees (and What It Never Should)

Completed MEQs are medical records. The employer's copy of the outcome is one line: cleared, cleared with limitations, or not cleared. The health answers stay with the PLHCP.

This is where paper programs quietly go wrong. When employees hand completed questionnaires to a supervisor to fax or file, the employer is now holding protected health information next to employment records. That is HIPAA exposure your safety program never needed. A digital MEQ keeps the medical content encrypted and stored separately; the employer portal shows clearance status only.

Is an Online MEQ OSHA-Defensible?

Yes, and the standard itself is the answer. 29 CFR 1910.134(e) requires a medical evaluation using the Appendix C questionnaire (or equivalent), reviewed by a PLHCP, with confidentiality maintained. It does not require an in-person visit, a stethoscope, or a clinic waiting room. An online MEQ that uses the mandatory questionnaire, routes it to a state-licensed PLHCP, and produces a written clearance determination fulfills 1910.134(e).

What auditors and industrial hygienists actually check:

1. Was the evaluation completed before fit testing and first use?
2. Did a PLHCP make the determination?
3. Can you produce the clearance records? Records must be retained and accessible under 1910.134(m)(1), and medical records carry a 30-year retention obligation
4. Were follow-up evaluations under 1910.134(e)(3) handled when answers required them?

VestMed produces audit-ready PDF records for every clearance, stored for 30 years, retrievable in seconds during a walkthrough. Our record retention guide covers what to keep and for how long.

The Clinic Path vs the Online Path

The traditional route sends employees to an occupational health clinic. It works, but count the real cost: the visit itself, paid travel time, scheduling friction, and the productivity gap while a crew member is off-site for half a day. Organizations that switch to online clearance typically see 60 to 80% time savings per employee. The comparison deserves its own page, so we wrote one: online respirator clearance vs the clinic.

The short version: an employee completes the MEQ on a phone in about 15 minutes, in English or Spanish, and most are cleared before the break ends. Log on. Get cleared. Go to work.

After Clearance: Fit Testing and Records

Medical clearance is step one of two. Fit testing under 1910.134(f) comes after, and it is where clearance and records meet: the fit test record and the clearance determination need to live somewhere an auditor can find them together. VestMed stores digital fit test records alongside clearances, and our guide to what respirator fit testing is covers the qualitative and quantitative methods.

Where jobs require it, pulmonary function testing layers onto the same workflow with clinical-grade, ATS/ERS-standard spirometry review.

Industry Notes

• Healthcare and dental: annual N95 refresh cycles and Joint Commission surveys make batch re-clearance the norm. See respirator clearance for healthcare
• Senior living: CMS infection-control survey prep is the common trigger. See respirator clearance for senior living
• Construction: project mobilization and silica-rule jobsites need crews cleared fast. See respirator clearance for construction
• Oil and gas: H2S rotations and turnaround season create clearance spikes measured in days, not quarters. Workers can complete the MEQ before rotation, at the hotel, or on a phone, and the clearance travels with them. See respirator clearance for oil and gas
• A note for healthcare and senior living safety teams: TB and immunization tracking do not satisfy this requirement. Respiratory clearance under 1910.134 is a separate obligation from occupational health surveillance