In July, the Department of Labor announced a proposed rule that would clarify that personal protective equipment (PPE) in the construction industry must fit properly to adequately protect workers. Current OSHA standards and numerous guidance documents note the need for proper PPE fit. However, federal OSHA’s proposal seeks to make this requirement more explicit and bring the construction industry in line with the general and maritime industries.
Proper PPE fit is vital because PPE is the last line of defense after other controls have been exhausted or deemed infeasible. PPE such as hard hats, gloves and safety goggles are considered daily wear for most workers in the industry, but these items are not one-size-fits-all. A range of factors, including gender, body shape and age can all affect how PPE fits an individual.
“Part of welcoming all kinds of workers to the construction industry is ensuring that every person feels safe on the job,” says LHSFNA Management Co-Chair David F. Rampone. “Making sure your safety gear fits so you’re protected from potential hazards is one of the most basic steps employers must take. It sends the message that worker safety matters and can also help make all workers feel like they belong.”
LHSFNA Efforts in Partnership with NABTU
North America’s Building Trades Unions (NABTU) submitted formal comments to OSHA in support of the proposed rule. The LHSFNA’s OSH Division works closely with NABTU’s Safety and Health Committee, and Ryan Papariello, the Fund’s Safety & Health Specialist, co-chaired the workgroup that developed these comments.
“Real-world stories from the field and larger data surveys really support the need for better fitting PPE in construction,” said Papariello. “Fortunately, there are a growing number of products on the market that are available in different sizes or can be adjusted to fit each worker properly. ”
The NABTU comments that Papariello helped develop strongly support OSHA’s proposal. They also include suggestions to ensure all types of PPE provide workers with a safe fit. OSHA’s draft proposal includes three types of PPE classifications:
- “Provided by the employer, not universal fit” – this would include items such as gloves, safety glasses, face shields and earmuffs
- “Provided by employee and reimbursed” – this would include items such as safety shoes and prescription safety glasses
- “Universal fit” – this would include items such as fall arrest harnesses, earplugs and hard hats
In reviewing this classification system, personal fall arrest harnesses in particular became a focus for the committee. “Particular items should not be classified as universal fit and need to be ‘completely adjustable and capable of fitting any and every worker’,” said Papariello. “There are very few harnesses available that are truly one-size-fits-all, which is why we recommended that type of PPE be classified differently.”
NABTU’s comments also note the importance of proper fit for construction footwear and cold climate accessories, ear protection, high-visibility clothing and flame-resistant clothing, among others.
Better Fitting PPE Avoids the “Illusion of Safety”
A survey conducted by the CPWR – The Center for Construction Research and Training – of over 2,500 tradeswomen and non-binary tradespeople in the U.S. includes many examples of ill-fitting fall harnesses. In that survey, 67 percent of participants said they had been exposed to falls unnecessarily because of improperly fitting PPE.
Female respondents in particular felt that universal fit harnesses were not designed with their bodies in mind. Here’s how one worker summed it up:
“[W]ith harnesses, I find the chest strap to be uncomfortable across my breast line. Mostly because it never stays in place, so when it slips down then comes back up, it pinches me until it passes my chest line [and] then [it] rockets into my throat…”
Another worker described her oversized harness as “an illusion of safety” that would not protect her in a fall situation.
Ill-Fitting PPE Is a Widespread Issue in Construction
The CPWR PPE Fit survey and other surveys make it clear how common poorly fitting PPE is in the industry. Only 19 percent of participants said they were always provided with gloves or safety equipment in sizes that fit them while working. In a different CPWR survey focused on female workers, 89 percent said they experienced difficulties getting PPE that fit them well.
In addition to putting workers at risk for on-the-job hazards, PPE that doesn’t fit properly can also cause pain or discomfort that makes workers less likely to wear the required PPE at all. This not only creates a safety risk for workers, it also creates a compliance risk for employers. Employers can take the following steps to provide PPE that fits workers well:
- Offer PPE in various sizes and styles to ensure a proper fit for all workers.
- Choose PPE with adjustable features, such as straps, buckles or fasteners, that allow workers to customize fit and improve comfort.
- Look for PPE designed with ergonomic principles, as these products are more likely to promote comfort and ease of movement.
- Train workers on how to wear and adjust PPE properly.
- Monitor and regularly update PPE based on workers’ feedback and technological advances.
By following these steps, employers can significantly improve comfort levels and encourage consistent PPE use on the job. The LHSFNA’s selection of Tools & PPE toolbox talks is available to LIUNA signatory contractors seeking additional information and resources.