According to the 2024 OSHA 300 summaries 2,300,000 people are expected to receive disabling work-related injuries in 2025. More than 600,000 of these injuries will involve lack of PPE utilization in the construction industry with most of these injuries to the head, eyes, hands, or feet.
OSHA Standard Subpart C 1926.21(b)(2) The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.
- Not using PPE causes serious injuries even death. Common critical mistakes made are:
- Not knowing the hazards of the task to be completed.
- The perception about the seriousness of the hazardous / situation is the second leading critical mistake made of employees experiencing injuries and fatalities.
- The third critical mistake causing injuries and fatalities related to lack of PPE utilization comes from the belief that if you are only exposed for a short period of time – there is limited risk.
- Another critical mistake is not knowing that the PPE has an expiration period and has lost its effectiveness to protect.
- Using PPE incorrectly does not provide any protection.
- 45% of the use variance of the PPE utilization level on construction sites is accounted for by 25% of all employees.
- OSHA has a focus area on correct PPE utilization for 2025. Effective January 13, 2025, OSHA’s new rule mandates that all PPE in construction must “properly fit” each affected employee. This change addresses long-standing concerns, particularly among women and workers with diverse body types, about the inadequacy of standard-sized PPE. Ill-fitting attire and equipment can compromise safety, leading to an increased risk of injury. Another factor is the pretend utilization by many workers.
- Lack of improper employee training on PPE utilization will generate additional citations.
- Using PPE does not eliminate the hazard, therefore you are still exposed and not invincible.
- Overestimating the projection of the utilized PPE was the fourth leading cause of injuries and fatalities.
COMMONLY USED PPE IN THE CONSTRUCTION INDUSTRY
- Hard hats/protective or safety helmets: To avoid traumatic head injury. Work-related exposure includes falling off flying objects, overhead objects, collision, machine parts, etc.
- Safety glasses/goggles: To guard and protect eyes from anything that might affect them. Work-related exposure includes hot sparks, laser operations, hazardous liquid chemical mists, dust, UV light, flying particles/objects, etc.
- Earplugs/earmuffs: To protect ears from thunderous noise/or hearing loss. Work-related exposure includes working in a noisy environment, with a noisy machine, etc.
- Respirators/ dusk masks/ disposable particulate: To provide oxygen while working in a confined space and protect workers from inhaling toxic gases and other harmful substances in the air. Work-related exposure includes toxic air, chemical irritations (acids), welding emissions, paint spray, etc.
- Protective hand gloves: To protect hands from injuries or harmful substances. Work-related exposure includes tools or materials that can scrape, bruise, or cut a hand, life-threatening heat or cold, electric hazards, chemical irritants, etc.
- Safety belts/harness lanyards/personal fall arrest systems (PFAS): To prevent falls from height while
working. Work-related exposure includes working at a height greater than 1.8 m (6 feet) - Safety/protective boosts: To avoid foot injury and slithering on wet floors. Work-related exposure includes slippery surfaces, heavy equipment, impacts from objects, exposed electrical wiring or components, chemical penetration, etc.
- Protective clothing or bodysuits: To protect the body from physical injuries and increase comfort while working. Work-related exposure includes impacts from flying objects or materials, life-threatening heat or cold, sharp, or rough edges, etc.
- Reflective safety vest (high-visibility clothing): To ensure employees always remain visible on-site. Work-related exposure includes traffic or machine guide mostly, any hazardous work on-site.
COMMONLY USED PPE IN THE CONSTRUCTION INDUSTRY:
1. Risk perception about the hazardous situation. The employee does not believe that there is a hazard or exposure.
2. Enforcement and reinforcement from the top management are not expected or received.
3. Lack of on-site supervision expecting and enforcing PPE utilization.
4. Workers did not understand correct PPE utilization and protection.
5. On-site safety supervision expects production over compliance.
6. Following standard safety rules are not tied to promotions.
7. There are no safety incentives to encourage the use of PPE among workers.
8. Employment status (e.g., permanent staff) (long-term company employees comply more than short-term workers.
9. I am experienced and have never been hurt. Younger workers with families and female workers tend to wear PPE more than the single male or “seasoned” professional
10. Workers with family ties (e.g., wives, and children) wear PPE more than those without families.
11. Not enough PPE for workers in some companies.
12. Difficult to use while doing some tasks of the job.
13. Peer pressure! “I am not a WHIMP”.
14. PPE may be a source of discomfort while working.
Do any of you really believe that any of these excuses or reasons are worth losing your eyesight, extremity, your hearing, or your life?
REGULATIONS PPE BASICS:
OSHA Standard Subpart C Responsibilities – 1926.28(a): The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees.
OSHA Standard Subpart E Electrical – 1926.95(a): Application – Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impalement in the function of any part of the body through absorption, inhalation or physical contact.
OSHA Standard Subpart E Head – 1926.100(a): Employees working in areas where there is a possible danger of head injury from impact, falling or flying objects, or electrical shock and burns, shall be protected by protective helmets.
OSHA Standard Subpart E Hearing – 1926.101(a) – Wherever it is not feasible to reduce the noise levels or duration of exposures to those specified in Table D-2, Permissible Noise Exposures, in § 1926.52, ear protective devices shall be provided and used.
OSHA Standard Subpart E Hand – Deferred to 1910.138: standard, employers must require employees to wear the appropriate hand protection when their hands are exposed to hazards. These hazards include Harmful temperature extremes, Thermal burns, Chemical burns Punctures.
OSHA Standard Subpart E Eye and Face – 1926.102(a)(5)(i): shall provide adequate protection against the particular hazards for which they are designed.
OSHA Standard Subpart E Foot and Leg – 1926.96: Safety-toe footwear for employees shall meet the requirements and specifications in the American National Standard for Men’s Safety-Toe Footwear, Z41.1-1967.
OSHA Standard Subpart E Body Injury – Section 5(a)(1): requires employers to provide a safe and healthy workplace free from recognized hazards that could cause death or serious physical harm to employees.
OSHA Standard Subpart E Respirator – 1926.103: Deferred the requirements applicable to construction work under this code are identical to those set forth at 29 CFR 1910.134 general industry.
OSHA Standard Subpart E Personal Protective and Life Saving Equipment – 1926.104(a): Lifelines, safety belts, and lanyards shall be used only for employee safeguarding. Any lifeline, safety belt, or lanyard actually subjected to in-service loading, as distinguished from static load testing, shall be immediately removed from service and shall not be used again for employee safeguarding.
OSHA Standard Subpart E Working Near Water – 1926.106(a): Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jackets or buoyant work vests.
REGULATIONS PPE BASICS:
OSHA’s standards for personal protective equipment, also known as PPE, are designed to help protect you from the hazards of exposures from harmful levels of chemicals, noise, or radiation, as well as from injury due to hazards such as, but not limited to; falls, caught between equipment, struck by flying objects, hot or sharp objects, and electrical exposures.
- Our workplaces and individual jobs evolve over time. Therefore, you need to perform a hazard assessment daily to specifically address any SOP (standard operating procedures changes) or new tasks assigned and inform your supervisor and SRMS immediately of specific concerns or needs.
Key Focus Areas:- A non-routine job or task (one performed on very few occasions) that we may have been unaware of when conducting our PPE hazard assessments.
- If you know of a recently revised job or task you need to perform and believe you may not have or it will necessitate PPE that has not already been provided. STOP work and contact your supervisor and SRMS immediately.
- A non-routine job or task (one performed on very few occasions) that we may have been unaware of when conducting our PPE hazard assessments.
- Utilization of PPE is not optional if a hazard has been identified and PPE is provided.
WHAT YOU NEED TO KNOW ABOUT TRENCHING EXPOSURE:
Important Do’s to keep in mind when tasks require PPE:
- Know that if PPE fails, injury is likely.
- PPE is not a substitute for engineering, work practice, or admin controls—consider rotation, duration limits, exposure limits, or design changes first.
- All tasks may involve hazards like chemicals, falling objects, heat, radiation, moving parts, or sharp edges.
- Plan PPE needs for new or unusual tasks—ask what’s needed, if training is required, and how PPE will be maintained/disposed of.
- Understand the steps for PPE selection, training, and use based on the hazards of each task.
- Protect others with hard barricades or controlled access zones (CAZ) and proper signage.
- Follow manufacturer guidelines for all PPE.
- Inspect all PPE regularly.
- Use warning signs and barricades when the top of an area isn’t visible.
- Keep untrained and unnecessary personnel clear of the area.
- Have a rescue plan in place for medical or environmental emergencies.
- Always wear and enforce the use of high-visibility vests.
- Expect PPE use to be a focus during site inspections and reviews.
Important Do’s to keep in mind when tasks require PPE:
- Don’t assume that PPE eliminates the hazard.
- Don’t assume because it performed a task in the past without the proper PPE it is safe to do it again.
- Don’t assume that all PPE is of a durable design and the correct PPE for the task being performed (one size does not fit all and may at times certain hazards require special accommodations or equipment).
- Don’t ignore the required PPE.
- Don’t perform any task that requires additional PPE without receiving it and appropriate training.
- Don’t perform or allow anyone else to perform a task if training for the specific hazards and the SOPs for the tasks being performed have not been provided.
- Don’t “MacGyver” any PPE. We are committed to providing the correct protection for every task you are assigned to perform.
