If it Doesn’t Fit, You Must Change it!

On July 20, 2023, the Occupational Safety and Health Administration (OSHA) issued a notice of proposed rulemaking to modify 29 C.F.R. 1926.95(c) of the construction regulatory standard set to require construction employers to ensure that their employees have personal protective equipment (PPE) that “properly fits”.  OSHA already has specific standards that address PPE fit for general industry (29 CFR 1910.132(d)(1)(iii)) and maritime (29 CFR 1915.152(b)(3)), so this proposed change to the construction regulations will align with requirements already in place in other industries.

Hazards exist in facilities and job sites in all industries; therefore, strategies to protect workers are essential. The priority should be to follow the “hierarchy of control” including elimination, substitution, or engineering control(s) of hazards at their source or along the path between the source and the worker. Many methods are available, and those most appropriate to the specific situation should be used. The hierarchy of controls should be used by employers identify and rank safeguards to protect workers from hazards from the most to least effective, including elimination, substitution, engineering controls, administrative controls, and personal protective equipment.

Application of the hierarchy of controls aside, PPE is often essential, due to some nature of risk to the person handling equipment or performing task. The other controls are preferred, but not always practical or feasible depending on the task, frequency of task, or environment. Therefore, employers, supervisors, and safety professionals must be knowledgeable of the activities performed by employees to ensure the appropriate PPE is available for employees and that it fits.

PPE that’s not properly fitted places users at higher risk for injuries and can make the difference between an employee being safely protected or dangerously exposed. In some cases, ill-fitting PPE may not protect an employee at all, and in other cases it may present additional hazards to that employee, and to employees who work around them. Some examples of injuries that could be related to ill-fitting PPE are:

  • Gloves that don’t fit correctly can reduce the ability of the wearer to grip tools and machinery, can get caught or stuck in equipment or cause tools or materials to be dropped, and reduce dexterity.
  • Shoes that are too big or small can increase the chances of tripping and can also lead to foot injuries and back pain.
  • Fall-arrest harnesses that do not fit the user’s chest, hips, and thighs can affect the angles that straps fit and can hinder the user’s movements and/or rub against exposed skin.
  • Protective eyewear that is not correctly sized can leave gaps at the temples when worn by different size users and make it possible for flying debris to enter the eyes, impair vision, or allowing chemicals and airborne hazards to get into the eyes.
  • Respiratory protection equipment that is too big or too small and does not provide a comfortable fit and seal to the face may fail to provide adequate protection.
  • Hard hats designed that are too large could impair a user’s vision by falling over their eyes, compromising their balance and increasing the risk of slips, trips, and falls.

Finally, one of the most significant consequences of those who cannot find comfortable, well-fitting PPE is that employees may put themselves at increased risk of injury by not wearing any PPE at all.

Although OSHA stated in the notice of proposed rulemaking that PPE that does not properly fit is an issue for “smaller construction workers,” it follows that PPE that is too small for workers can also cause issues. What then can employers do to comply with the proposed standard and “do right” by their employees? The very first thing that should be done would be to start with the assumption that the current PPE that is issued to employees does not have a “universal fit” and then to focus on “proper fit” concerns through an audit of the current PPE program and choices.

Body proportions and configurations of the employee population should be considered. Size and proportions of employee body size will vary considerably between hips, chests, and thighs, and more significantly between male and female populations. Hands, feet, faces, ears, ear canals, weight, and height are also factors that need to be considered in PPE fit. Employers should form a PPE review committee that is diverse and, therefore, can render opinions that do not rely on anthropometric data relevant to the standard body (male or female).

According to OSHA, whatever employers do to assess the gaps in PPE fit and protection within the employee population, PPE must consider workers’ gender, race, age, shape, and size.  The Center for Disease Control (CDC)/National Institute for Occupational Safey and Health (NIOSH) has also indicated that workers with different disabilities, job functions, characteristics of occupational settings, and size of employers (e.g., small versus large employers) are other important factors that must be considered in an organization’s PPE program and employee outfitting.

Although the construction PPE fit language is still in the rulemaking stage, all PPE an employer purchases must consider the physical measures of a person’s size, form, and functional capacity (anthropometry) to ensure protection of the worker form the hazards and the employer from the risks of significant injuries and illnesses caused by exposures due to ill-fitting PPE. The demographics of the U.S. construction industry are changing rapidly and currently consist of approximately 11 million workers with increasing percentages of Latinx workers and female workers.

For more information about OSHA’s construction standard Notice of Proposed Rulemaking requiring that fit be considered in PPE programs, check out OSHA’s formal notice at the following link:  https://www.osha.gov/news/newsreleases/national/07192023

James A. Junkin, MS, CSP, SMS, ASP, CSHO is the chief executive officer of Mariner-Gulf Consulting & Services, LLC and the chair of the Veriforce Strategic Advisory Board. He is Columbia Southern University’s 2022 Safety Professional of the Year (Runner Up) and a much sought after master trainer, keynote speaker, podcaster, and author of numerous articles concerning occupational safety and health.