February 2025
Ensuring Proper PPE Fit For Construction Worker Safety
Unlike OSHA’s General Industry PPE standards, the previous Construction PPE requirements in section 1926.95 didn’t explicitly require that PPE properly fit workers until now.
OSHA 1926.95 only required employers to ensure PPE is safe in design and construction. However, it left ambiguity about the proper fit of PPE. As a result, workers often choose among standardized PPE that doesn’t fit properly or adequately protect them from hazards.
For example, standard PPE sizes may not adequately protect smaller construction workers. Ill-fitting PPE, such as standardized fall protection harness sizes, can also affect larger workers.
What’s changed?
On December 6, 2024, the Office of Management and Budget (OMB) approved OSHA’s new PPE rule for construction, officially published in the Federal Register on December 12. As of January 13, 2025, employers must comply with these updated guidelines.
OSHA’s revisions include:
1. Amending section 1926.95(c) to have the requirement in subparagraph (c)(2) that employers select PPE that properly fits each affected employee,
2. Moving the current language in section 1926.95(c) about safe design and construction to subparagraph (c)(1), and
3. Including language in paragraph (c) requiring employers to ensure that both requirements in subparagraphs (c)(1) and (c)(2) are met.
Contractors are likely addressing fit problems by buying assorted sizes of PPE (small through extra-large). However, such sizes only fit some workers, limiting their options to choosing the best fitting rather than properly fitting PPE.
Ill-fitting PPE is like wearing uncomfortable shoes—it’s both unsafe and impractical. A loose helmet or tight harness can increase risks. Ensuring a proper fit is vital to keeping workers fully protected.
Manufacturer’s instructions and recommendations about proper fit
OSHA recognizes that PPE manufacturers’ instructions and recommendations can provide valuable guidance on ensuring proper fit for PPE. The Agency encourages employers to consult these instructions to determine the correct fit of PPE for workers.
However, OSHA is not making it a mandatory requirement in its construction standard, as doing so could limit employers’ flexibility in selecting PPE that best meets their employees’ specific needs. The clarified requirement for employers to provide PPE that fits properly applies regardless of whether the manufacturer offers fit instructions or recommendations.
If the manufacturers’ guidance on proper fit is unavailable, employers can refer to consensus standards for additional direction on fitting PPE appropriately. Employers also have the option to select PPE for which fit guidance is available, whether from the manufacturer or other sources, rather than opting for products without such information.
Enforcement
When an OSHA inspector observes a violation related to improper PPE fit, the Agency can issue a citation under 1926.95, Criteria for personal protective equipment, for construction.
OSHA expects employers to choose properly designed and sized PPE to protect workers from hazards without introducing new risks. The Agency asserts that this performance-based interpretation of “properly fits” strikes a balance, offering clear guidance while allowing employers the flexibility to select the appropriate PPE needed to protect their workers.
OSHA believes that comfort is a key factor in ensuring that PPE fits properly. Comfortable PPE is more likely to be worn consistently by workers, whereas uncomfortable PPE may be discarded or left unused. Additionally, discomfort can often signal an improper fit.
Employers should take employee complaints about discomfort seriously, as they may indicate that the PPE needs further evaluation to ensure it provides adequate protection and does not introduce additional risks.
FREE PROPER FIT COMPLIANCE BRIEF
Learn more about OSHA’s PPE rule for construction addressing fit, as well as common proper fit issues and the hazards they may cause.
