If The PPE Fits: Why OSHA Clarified its Ruling on Personal Protective Equipment

If The PPE Fits: Why OSHA Clarified its Ruling on Personal Protective Equipment

Imagine you’re on the job, working with sharp or hazardous materials, in gloves that are two sizes too big. Or, what if you were sawing into concrete and the respirator you’re required to wear won’t even fit over your head? If you’re like most of the construction workforce, you’d be tempted to ditch the PPE and get the work done.

For about 10% of the construction industry, ill-fitting Personal Protective Equipment is an everyday occurrence, leading to accidents, injuries, and cementing the idea that your employer is not committed to your personal safety.

A smiling woman in a hardhat, safety glasses, and safety vest looks back over her shoulder
Nine out of 10 women in a recent construction safety survey cited poor PPE fit as a contributing factor to their risk on the job, according to Construction Dive.

That’s why in 2023, The U.S. Occupational Safety and Health Administration (OSHA) announced its intent to clarify its rules for Personal Protective Equipment for General Industry Standard.

Specifically, they are clarifying the rules change first proposed in 2016 to the Standards Improvement Project IV (SIP-IV) to explicitly state that PPE must fit properly.

While language regarding the proper fit of PPE exists in current 29 CFR 1926.95 requirements, it states that “PPE be provided by an employer in a reliable condition, that employee-owned PPE be adequate, and that PPE be of safe design,” but does not explicitly state that the adequacy of the PPE includes fitting properly.

The rules change is being undertaken to ensure that “the requirement is clear and more understandable for the industry to ensure workers of all sizes have appropriate PPE.”

OSHA does single out the increase in women in construction as part of their description of “smaller construction workers” for whom the one-size-fits-all PPE approach puts at risk. However, it’s important to note that proper PPE fit is not limited to smaller workers, although they are the ones expected to reap the most benefit from the rule clarification.

A public comment period on the clarification was held through September 18, 2023. Stakeholders, specifically OSHA’s Advisory Committee on Construction Safety and Health (ACCSH), recommended the rule clarification. Industry publication Construction Dive wrote about the need for proper PPE fit in support of the effort, and construction advocates like The Safety Rack and North America’s Building Trades Union (NABTU) supported the proposal.

“This minor regulation clarification means that construction workers will be afforded PPE that fits their various sizes and will improve safety for all workers in our industry. This is a huge positive change for tradeswomen and other trade professional workers who wear different sizes,” Sean McGarvey of NABTU told Construction Dive.

The Safety Rack’s mission is “PPE Equity for Women” to “Ensure Safety for Women in the Workplace.” To that end, they’ve pioneered the #mybodymyppe campaign, which held a week-long awareness-raising event that began April 29, 2024. Their founder, Amy Roosa, weighed in on the rule in July of 2023, saying, “My initial reaction is that this is very positive. That’s the biggest struggle we’re seeing is [PPE] properly fitting women in the construction industry, and this rule proposal has the potential to change that for us.”

What Will PPE That Fits Cost?

The rules proposal from OSHA puts the transitional expense to the construction industry at $545,000. That is arguably a drop in the bucket compared to the annual cost of accidents and PPE failures industry-wide, which are approximately $11.5 billion according to the National Institutes of Health, and the rule clarification cost could impact that larger figure by limiting accidents and injuries caused by ill-fitting equipment.

That $545,000 is considered by OSHA as a one-time expense, whereas the cost of construction injuries in the billions is annual, with $7 billion in non-fatal injuries and $4 billion calculated as the cost of accident-related construction deaths.

Valuing Every Voice in Safety

2024’s Construction Safety Week theme was Value Every Voice, to urge employers, safety directors, and industry leaders to listen and engage with their workers. GPRS is a long-time Construction Safety Week sponsor, and has conducted more than 200 educational sessions on jobsites across the nation in 2024 alone, focusing on personal responsibility as a key driver of construction safety.

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There is nothing more personal to a construction worker than the equipment that keeps them safe. So, making sure their PPE fits and protects them properly is perhaps the most valuable tool for keeping jobsites safe, too.

Frequently Asked Questions

What types of PPE are commonly used in construction?

Common types of PPE in construction include:

  • Hard hats/Safety Helmets: Protect the head from falling objects and impact
  • Safety Glasses and Face Shields: Protect the eyes from dust, debris, and chemical splashes
  • Hearing Protection: Earplugs or earmuffs to protect against loud noise
  • Gloves: Protect hands from cuts, abrasions, and chemical exposure
  • Safety Boots: Steel-toed boots to protect feet from crushing injuries and punctures
  • High-Visibility Clothing: Enhances visibility to prevent accidents, especially in low-light conditions
  • Respirators: Protect against inhaling hazardous dust, fumes, and chemicals

Who is responsible for providing PPE on a construction site?

Employers are generally responsible for providing PPE to their workers at no cost. They must also ensure that the PPE is properly maintained and replaced as needed. Workers are responsible for using PPE correctly and reporting any damage or deficiencies.

Can PPE be shared among workers?

PPE that comes into direct contact with the skin, such as gloves and respirators, should not be shared. If PPE must be shared, it should be thoroughly cleaned and sanitized between uses to prevent the spread of contaminants and ensure proper hygiene.

Schedule a Safety Week or Toolbox Talk with GPRS and we’ll bring the education to you.