As of January 13, 2025, OSHA's new rule on personal protective equipment (PPE) for the construction industry is now in effect. Published in the Federal Register on December 12, this rule requires that employers ensure PPE "properly fits" all workers.
Key Changes in the New Rule
- Proper Fit Requirement: PPE must now be tailored to fit each individual worker, addressing issues with ill-fitting equipment and ensuring maximum protection.
- Alignment with Other Standards: The updated construction PPE standard (29 CFR 1926.95) now aligns with OSHA's standards for general industry and maritime, creating a consistent safety approach across sectors.
- Clarification of Employer Responsibilities: Employers are explicitly required to provide and maintain properly fitting PPE, suitable for specific workplace hazards. The revised 29 CFR 1926.95(c) states:
- PPE must be of safe design and construction for the work performed.
- PPE must be selected to properly fit each affected employee.
- Employers must ensure both requirements are met.
Why Proper Fit Matters
Head and Face
- Hard Hats: A hard hat that is too loose can shift or fall off, leaving the worker's head unprotected from falling objects. Conversely, a hard hat that is too tight can cause headaches and discomfort, leading to distractions.
- Face Shields and Welding Helmets: If these are too large, they can obstruct the worker's view, increasing the risk of accidents. If too small, they may not provide adequate coverage, exposing the face to sparks, debris, or harmful radiation.
- Safety Glasses/Goggles: Poorly fitting eyewear can create gaps that allow debris to enter the eyes, potentially causing serious injuries. For example, a construction worker cutting metal might get metal shavings in their eyes if their safety glasses don't fit properly.
Torso
- FR/AR Garments: Flame-resistant (FR) and arc-rated (AR) clothing that is too large can get caught in machinery, posing a significant hazard. For instance, a worker operating a lathe could have their oversized sleeve caught in the rotating parts, leading to severe injury.
- Tyvek Suits: These suits are often used in environments with hazardous materials. If they are too loose, they can tear easily, compromising the worker's protection. If too tight, they can restrict movement and cause overheating, especially in warm conditions.
Hands
- Gloves: Gloves that are too large can slip off or reduce the worker's ability to handle tools and materials precisely. For example, a carpenter wearing oversized gloves might struggle to grip nails or screws, increasing the risk of accidents. On the other hand, gloves that are too small can cause hand fatigue and reduce dexterity, making tasks like wiring or assembling small parts more difficult and dangerous.
Feet
- Footwear: Poorly fitting safety shoes or boots can lead to a range of issues. For instance, shoes that are too big can cause tripping hazards, while shoes that are too small can cause blisters and foot pain. Over time, this can lead to more serious conditions like plantar fasciitis or even secondary injuries to the knees, hips, and spine. A construction worker wearing ill-fitting boots might also be more prone to slips and falls, especially on uneven surfaces.
Steps for Employers to Ensure Compliance
You might be wondering, "What do I need to do to ensure I'm compliant with the new rule?" By following these steps, you'll not only meet OSHA's requirements but also enhance the safety and well-being of your team:
- Assess current PPE: Review existing PPE to ensure it meets the new fit requirements. Identify any equipment that does not properly fit workers and needs replacement.
- Update PPE inventory: Purchase PPE that is available in a range of sizes to accommodate all workers and ensure that it is of safe design and construction for the tasks performed.
- Train employees: Conduct training sessions to educate workers on the importance of properly fitting PPE and how to check if their equipment fits correctly.
- Implement fit tryouts: Establish a process for testing or trying out PPE to ensure it properly fits each worker. This may involve trying on different sizes and styles to find the best fit.
- Document compliance: Keep records of PPE assessments, purchases, training sessions, and fit testing to demonstrate compliance with the new rule.
- Monitor and maintain: Regularly check the condition of PPE and replace any that is worn out or no longer fits properly and make adjustments as needed.
Ensuring that personal protective equipment (PPE) is properly fitted to meet each worker's unique needs can prevent potential issues and enhance both safety and productivity.