Given the critical nature of worker protection in the construction industry, and the vital role of Personal Protective Equipment (PPE) as a last line of defense, OSHA has revised the 29 CFR 1926.95(c) criteria. Effective January 2025, the standard will require PPE to fit workers based on their individual body type and size. This change aligns the construction standard with existing requirements for general industry and shipyards, reinforcing OSHA’s long-standing interpretation of the rule.
Why the change? Construction led all industries in workplace fatalities in 2023 with a total of 1,075 deaths – the highest number the sector has seen since 2011. Over a third of these fatalities were due to slips, trips and falls. Properly fitting PPE is essential for effective protection. OSHA acknowledges the growing number of women in construction and the diversity of body shapes and sizes, regardless of gender. Improperly fitting PPE can be ineffective, create additional hazards or even discourage workers from wearing it altogether. This revision aims to clarify employers’ existing obligations and ensure everyone is adequately protected.
What Does This Mean for Your Organization?
This revised standard impacts a wide range of PPE, including safety harnesses, vests, hard hats, gloves, eye protection, respirators, hearing protection, footwear and face shields. Beyond individual fit, employers must ensure the PPE is appropriate for the specific job hazards, properly maintained and replaced when worn or damaged. It is equally important for employees to receive thorough training on the limitations of the PPE and how to wear it correctly.
Five Steps to Compliance
Achieving compliance with OSHA’s PPE standard involves these five key steps:
- Conduct a PPE Assessment: Evaluate workplace hazards to determine the necessary PPE. Remember to follow the hierarchy of controls – prioritizing hazard elimination, substitution, and engineering and administrative controls before relying solely on PPE. All PPE has limitations, so a comprehensive approach is essential.
- Provide Varied Sizes: Offer a range of sizes to accommodate both male and female workers as well as different body types.
- Inspect for Proper Fit: Regularly inspect PPE to ensure it fits correctly and provides the necessary level of protection for the identified hazards.
- Ensure Proper Fit Testing and Training: All employees must be fit tested and trained on the proper use and care of their assigned PPE.
- Document Everything: Maintain records of PPE assessments and training to demonstrate compliance.
OSHA’s Own PPE Update
In related news, OSHA has announced a switch from traditional hard hats to safety helmets (Type II, Class G) for its construction employees. For more information, refer to their safety and health information bulletin SHIB 3-6-2024.
Reach Out to a Risk Consultant
If you have any questions or require assistance with your PPE program, please contact a SISCO Risk Consultant. We’re here to help you create a safe and compliant work environment.