Much Ado About PPE

I’d like to know the true cost of OSHA’s final rule on paying for PPE, which was issued the same day I wrote this column (Nov. 15, 2007). Federal agency rules contain economic impact estimates; this one estimates total compliance costs of $85.7 million for all establishments, with the biggest chunks of that going for abrasion-resistant gloves ($27.8 million), chemical-resistant footwear ($17.6 million), metatarsal guards for footwear ($13.3 million), and chemical-resistant gloves ($10.2 million). But employers usually say the estimates are way off. They’ve said so this time, and I believe them.

OSHA solved this as I expected. You’d be wise to read the rule, but here are the highlights:

• OSHA discarded the “tools of the trade” approach that could have left employees paying for virtually any protective item they wear.

• It refused to require employers to pay for all PPE, refused to exempt “high turnover” industries, and did not exempt protective gloves.

• It did not exempt welding PPE, including masks, aprons, and gloves.

• It told us how many U.S. workers wear PPE (24.9 million under OSHA jurisdiction) and what kinds (11.3 million, nonprescription safety eyewear; 9.2 million, abrasion-resistant gloves; 6.5 million, goggles; 5.8 million, chemical-resistant gloves; 5.7 million, hard hats).

• It said employers in nearly all industries already pay for 96.5 percent of their workers’ PPE, with the chief exception being foot protection at 50-55 percent. Thus, steel-toe footwear is this final rule’s biggest exemption.

• “Basic,” minimal PPE for the hazards at hand is all the employers must pay for.

• All five industries—general industry, construction, shipyards, longshoring, and marine terminals—have one rule taking effect at the same time.

• Self-employed independent contractors aren’t covered.

• Employers don’t have to pay for “lost” or “intentionally damaged” PPE, but they do have to pay for replacement PPE when the original item wears out.

• Protective apparel worn by employees who are doing jobs covered by OSHA’s 1910.269(l)(6), the Electric Power Generation, Transmission and Distribution Standard, is exempt—but the rule notes if OSHA requires clothing in a revised 1910.269, employers would have to pay for it.

How will it play out? Current practices won’t change: Employers will keep paying for almost everything, and who pays for PPE will be collectively bargained in union operations. Here and there, workers will grumble when told it’s up to them to buy ordinary raincoats, snow boots, steel-toe footwear, and voluntarily used dust masks.

OSHA is candid: Achieving this rule’s entire estimated benefit of 21,789 averted injuries and illnesses per year won’t budge the national injury and illness rate of 4.6 per 100 full-time workers by even 0.1. If it succeeds, in other words, we won’t be able to see it.

This article originally appeared in the January 2008 issue of Occupational Health & Safety.

About the Author

Jerry Laws is Editor of Occupational Health & Safety magazine, which is owned by 1105 Media Inc.

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