The construction industry is a high-risk sector. Therefore, personal protective equipment (PPE) acts as the last barrier between employees and injury or death.
As part of its efforts to improve the safety of employees within the construction sector, the Occupational Safety and Health Administration (OSHA) updated its 29 CFR 1926.95(c) regulation regarding the provision of PPE.
Effective January 13, 2025, OSHA’s updated regulation will obligate employers to issue appropriately sized PPE to each of their workers in the construction sector.
An update as seemingly simple in nature has ramifications for all employers, safety professionals, and employees involved in the construction industry. This is a result of the long-standing issue of PPE that has historically lacked a proper fit. Employees that wear ill-fitted PPE have had less protection than those using PPE that fits properly and in certain instances can introduce additional hazards into the workplace.
The Critical Change From “Available” To “Properly Fitted.”
Prior to the amendment, OSHA’s general Industry rule (1910.132) placed importance on providing an adequate fit, while the construction rule (1926.95) only required that PPE have “safe design and construction for the work being performed”. This distinction created a void, often leading to the “one-size-fits-all” mentality. This often left many workers – particularly females and those who don’t fit standard body shapes – without proper protection or at risk.
Through this new rule, OSHA directly addressed this issue by defining the requirements for PPE as follows:
- PPE must be of safe design and construction for the work being performed.
- PPE must be selected to fit properly for each affected worker.
The new rule aligns construction PPE regulations with rules under general industry and maritime. It creates a more uniform, enhanced safety system for all workers.
The Importance of Properly Fitting PPE: Why is Properly Fitting PPE Important?
The importance of wearing properly fitting PPE is more than just bureaucracy. In fact, the only reason for ensuring that your PPE fits properly is for improving worker safety. Having PPE that does not fit appropriately increases the risks to a worker safety by exposing them to potential hazards.
Increased Risk of Not Being Protected: When PPE does not fit well, it can shift and expose the worker to hazards. For example, a hardhat that is not secured properly will not offer a worker protection from falling objects, and safety glasses that are loose allow debris to enter the worker’s eyes. If, on the other hand, the PPE is too tight, it can limit the worker’s mobility and not cover the areas that need protection.
Reduced Effectiveness of PPE: PPE that does not fit properly will have reduced effectiveness. When a worker falls off and is not wearing a fall protection harness that is secured snugly, the forces are not distributed correctly. This failure to distribute forces correctly could result in serious injury or even death.
Development of Additional Hazards: Large or baggy PPE has the potential to become caught in machinery and create the risk for entanglement injuries. Poorly fitted footwear also increases the risk for trips and falls.
Increased Discomfort and Non-Compliance: Workers that find their PPE uncomfortable will often alter, remove, or choose to not wear the PPE therefore rendering any protective capability null and void. This is an especially important consideration because the best PPE will provide no value if it is never worn.
Reduction in Productivity: Workers that are continuously adjusting ill-fitting PPE lose focus and efficiency which can contribute to a decrease in productivity and an increased potential for mistakes in their work.
The New Requirements on Construction Employers
This update to the standard will make it clear what construction employers must do in order to comply with the new regulations and improve the safety of their employees. In order to accomplish these goals, the construction employers should take an active approach by implementing the following measures:
Perform an extensive hazard assessment. Prior to using any PPE, an extensive hazard assessment should be performed to identify the unique hazards associated with each specific job or worksite in order to determine what type of PPE is required.
Assess Existing PPE On-Hand For Proper Size:
Identify any missing sizes from current inventory of PPE to ensure availability of proper fit.
Understand that “one-size-fits-all” does not apply to all employees.
Consider adding additional ranges of sizes to your inventory (e.g., petite, tall, extra wide) and to provide options specifically designed for different body types (i.e., women’s sizing for harnesses and gloves).
Use Proper Fitting Priorities in Purchasing PPE:
Partner With PPE Suppliers To Identify Equipment That Comes In Varied Sizes And Can Be Adjusted.
Get Manufacturers’ Recommendations For Fit And Fitting Procedures.
Use Rigorous Fit Testing And Validation:
Respirators Have Fit Tests Done By Law (Qualitative Or Quantitative) Current Rules Regarding Fitting And Validating Fit Are Still Necessary.
Other Types Of PPE: Develop Clear Procedures To Verify Proper Fitting. This Could Include;
• Training Supervisors And Workers On How Appropriate Fitting Looks And Feels
• Use Of Visual Inspections To Confirm The Proper Way To Wear And Adjust The PPE
• Provide Information On How To Properly Adjust PPE To Ensure An Optimal Fit And Level Of Comfort.
Provide Comprehensive Training and Awareness:
- Educate all employees on the importance of properly fitting PPE and the risks associated with ill-fitting gear.
- Train workers on how to correctly don, doff, adjust, and maintain their PPE.
- Emphasize when PPE does not fit properly and the process for requesting replacements or adjustments.
Foster Open Communication and Feedback:
- Create a workplace culture where employees feel comfortable reporting ill-fitting or damaged PPE without fear of reprisal.
- Establish a clear and efficient system for workers to request new or different sizes of PPE and for the prompt replacement of equipment.
Regular Inspection and Maintenance:
- Ensure a consistent program for inspecting, cleaning, and maintaining all PPE.
- Promptly repair or replace any damaged or worn-out PPE to ensure its continued effectiveness and proper fit.
The Broader Impact on Construction Safety
The new OSHA PPE fit requirement is expected to have several positive impacts on the construction industry:
Enhanced Worker Protection: The most direct benefit is improved safety for all construction workers, reducing the likelihood of injuries and fatalities.
Increased Compliance and Reduced Citations: OSHA now clearly states that PPE must fit properly. Inspectors can issue citations not only for missing PPE but also for equipment that doesn’t fit. Employers who act proactively will be more likely to avoid penalties.
Improved Worker Comfort and Morale: Properly fitting PPE is more comfortable, leading to higher rates of compliance and a more positive attitude towards safety.
Greater Inclusivity: This rule especially benefits women and people with diverse body types. These groups have often struggled to find PPE that fits well. The change promotes a more inclusive and fair workplace.
Potential for Innovation: The growing need for more PPE sizes and adjustable options could inspire new ideas in manufacturing. This may lead to better, more comfortable, and more effective PPE designs.
Also read:-