OSHA Announces Proposed Rule to Clarify PPE Fit for Construction Workers

OSHA Announces Proposed Rule to Clarify PPE Fit for Construction Workers

Abby Ferri, CSP Abby Ferri, CSP
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The road to properly fitting PPE for women construction is paved with good intentions but minimal action. Keen readers of this blog will remember that significant concerns on this topic have been raised since 1999 with the “Women in the Construction Workplace: Providing Equitable Safety and Health Protection” report from OSHA. The report described problems with PPE that are echoed by many today, “Ill-fitting personal protective equipment may be due to unavailability (i.e., manufacturers don't make or distributors don't stock), limited availability, or lack of knowledge among employers and workers about where equipment designed for a woman's body structure can be obtained. Personal protective equipment intended for use by women workers should be based upon female anthropometric (body measurement) data.”

Recently, OSHA announced a proposed rule to clarify the construction PPE standard to include mentions of fit. While the announcement calls out “physically smaller construction workers,” the proposed rule has further reaching impact for not only women of all shapes and sizes but also men who are outside of the average measurements that current PPE is based on.

Several resources and research exist to explain the need for PPE to properly fit and the specific size differences between men and women and amongst different ethnicities:

  • The American Society of Safety Professionals (ASSP) Women in Safety Excellence (WISE) common interest group held a Women’s Workplace Safety Summit in 2018 calling out PPE fit as one of the top three concerns for women in the safety profession. You can read the high level takeaways on the PPE fit discussion here and download the entire post-event report here.
  • The psychosocial safety impact for women has been discussed amongst safety professionals over the past five years, which may lead to increased support for OSHA’s proposed rule changes.
  • When similar rulemaking was proposed in 2016, the Construction Industry Safety Coalition submitted formal comments to OSHA in opposition to the rule at that time citing “significant new obligations and costs” to construction employers to comply. Note pages 6-8 in the Coalition’s submitted comments here.

One resource due out soon attempts to pull together multiple sources of anthropometric data on women to identify why fit should be considered for PPE selected for women. In late 2019, several ASSP WISE members joined a drafting committee to write a technical report, ASSP/ISEA TR-Z590.6 Guidance of Personal Protective Equipment for Women. This report is a joint effort between ASSP and the International Safety Equipment Association (ISEA) that will cover the state of available PPE for women, anthropometric data from head to toe, and impacts of PPE fit including physical considerations and psychological hazards. The report is geared towards end users of PPE, those who procure PPE, and others involved in the selection of PPE.

It’s important for safety professionals, tradespersons, and anyone else in support of including fit in the proposed changes to provide their comments by September 18, 2023. You can read more about the proposed rulemaking and comment here, and type in “Docket No. OSHA-2019-0003” in the search bar.  

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