While the use of Personal Protective Equipment (PPE) is a general requirement within the construction environment, it is worth reminding employers, and our members, that from the hierarchy of hazard control options available, PPE should be the last option chosen. In fact, most OSHA regulations specifically require the use of engineering and administrative controls before PPE options are selected.
When identifying overall risk of injury relative to a task, or working environment, two primary factors are measured. Probability of exposure to the hazard and Severity of outcome (injury). When PPE is selected, it only reduces the potential severity of injury. It doesn’t eliminate the hazard and, in some cases, it can arguably increase the probability of exposure. The use of voltage rated gloves and leather protectors during energized work tasks comes to mind.
One of my first experiences with V-rated gloves during energized work was with a pair of class 2 gloves that were way too big for my hands. We were exposed to 480 volts of electrical potential however, not only were the gloves too big, they were rated for 17000 volts and were too thick to allow the basic manual dexterity needed to manipulate tools and conductors.
The Center for Disease Control (CDC) / National Institute for Occupational Safety and Health (NIOSH) have ongoing research studies with a focus on improper fitment of PPE as a causal factor of injuries. NIOSH is the agency under the Department of Labor that conducts research and makes recommendations to OSHA for the prevention of work-related injury and illness.
In response to these recommendations regarding improper fit, OSHA again is proposing new regulations aimed at construction employers, those working under 29 CFR Part 1926 Subpart E, to clarify exactly what is required when PPE is chosen to mitigate risks. OSHA last updated their PPE rules in 2008 when they clarified exactly what types of PPE had to be provided and paid for by employers. This time, the focus is on adding language requiring proper fitment of PPE.
Currently, the construction regulations only hint at proper fitment compared to language found in OSHA’s General Industry PPE regulations, Subpart I. Here, it specifically states that employers must perform and document a written PPE Hazard Assessment and then select PPE that is appropriate for the hazard and properly fits each employee.
Public hearings wrapped up in late September and I would expect OSHA to adopt clarifying language before the end of 2023. As with the adoption of any new OSHA regulation, local OR – OSHA and WA-DOSH compliance officers will have a renewed interest in our employer’s PPE selection, including proper fitment, and training programs.