The Occupational Safety and Health Administration (OSHA) has announced a significant update to its personal protective equipment (PPE) standard for the construction industry, with a new final rule that explicitly requires PPE to fit workers properly.
The revision is set to take effect on January 13, 2025.
Why Did OSHA Revise its PPE Standard for Construction?
OSHA revised its personal protective equipment standard for construction to explicitly require that the equipment must fit properly.
Construction has historically been male-dominated, which has led to an industry-wide issue: PPE designed primarily with male body types in mind.
"I've talked to workers in construction, particularly women, who have spoken of personal protective equipment that didn't fit or was simply unavailable at the jobsite in their size," said Assistant Secretary for Occupational Safety and Health Doug Parker. "PPE must fit properly to work.”
While proper PPE fit might seem like an obvious requirement, making it explicit in the standards helps eliminate any ambiguity and ensures that employers understand their responsibilities, particularly to women as well as physically smaller or larger workers.
Ill-fitting PPE can compromise worker safety – a hard hat that's too loose might fall off, oversized gloves can reduce dexterity, and loose safety glasses might not provide adequate protection. And, as any construction foreperson or safety professional can attest, poor fitting and uncomfortable PPE often results in reduced usage.
Impact of PPE Final Rule on Construction Employers
Construction industry employers will need to:
- Evaluate their current PPE inventory to ensure proper fit for all workers
- Potentially invest in a wider range of PPE sizes to accommodate their workforce
- Update their PPE protocols and training programs to emphasize proper fit
- Document their compliance efforts to provide properly fitting PPE
Employers within these North American Industry Classification System (NAICS) industries will be affected:
- NAICS 236 (Construction of Buildings);
- NAICS 237 (Heavy and Civil Engineering Construction); and
- NAICS 238 (Specialty Trade Contractors).
What Are the Costs Associated With This Final PPE Rule?
While the rule clarifies an existing obligation and creates no new requirements for employers, OSHA acknowledges that the clarification may result in some costs for employers, including:
- Time spent to familiarize themselves with the final rule;
- Time spent researching and finding PPE in non-standard sizes; and
- The cost of replacing ill-fitting PPE.
The costs for researching properly fitting PPE for purchase and for replacing improperly fitting PPE will only be incurred by employers who are out of compliance with the already-existing requirement to provide workers with PPE that fits properly.
PPE Comfort vs. Proper Fit
Just because PPE is uncomfortable doesn't automatically mean it's improperly fitted. Some safety equipment may have inherent discomfort while still providing proper protection.
For example:
- A respirator might feel restrictive but still seal correctly
- Steel-toed boots may feel heavy but fit appropriately
- Hard hats might cause pressure points while maintaining proper protection
However, discomfort can be an important warning sign that PPE doesn't fit correctly. Employers and workers should evaluate whether the discomfort stems from:
- The inherent nature of the protective equipment
- Or actual fit issues that could compromise safety
Check manufacturer’s instructions to help determine the proper fit of their workers’ PPE to meet the requirement of the rule.
How Will OSHA Enforce the Revised PPE Rule?
Expect OSHA inspectors to evaluate PPE fit during routine on-site inspections.
In addition, OSHA’s enforcement strategy will likely include:
- Investigating employee complaints
- Targeted enforcement within industries considered high risk for PPE-related hazards
- Verifying that employers provide adequate training to employees on how to properly select, wear, and maintain their PPE
- Employer awareness and outreach initiatives to help employers understand their obligations
When Will the Revised PPE Rule Go Into Effect?
Employers have until January 13, 2025, to ensure they're in full compliance with the new requirement.
Construction Industry Employers: Review Your PPE Program for Compliance Now
This update reinforces OSHA's commitment to ensuring worker safety through properly functioning protective equipment. Construction companies should begin reviewing their PPE programs now to ensure they'll be ready when the rule takes effect in 2025.
The complete rule and related documents are available on OSHA's website at www.osha.gov.
