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.

Download Center

HTML - No Current Item Deck
  • Free Safety Management Software Demo

    IndustrySafe Safety Management Software helps organizations to improve safety by providing a comprehensive toolset of software modules to help businesses identify trouble spots; reduce claims, lost days, OSHA fines; and more.

  • The Top 5 Safety and Technology Trends to Watch in 2019

    Get the latest on trends you can expect to hear more about in 2019, including continued growth of mobile safety applications, wearable technology, and smart PPE; autonomous vehicles; pending OSHA recordkeeping rulemaking; and increased adoption of international safety standard, ISO 45001.

  • Get the Ultimate Guide to OSHA Recordkeeping

    OSHA’s Form 300A posting deadline is February 1! Are you prepared? To help answer your key recordkeeping questions, IndustrySafe put together this guide with critical compliance information.

  • Safety Training 101

    When it comes to safety training, no matter the industry, there are always questions regarding requirements and certifications. We’ve put together a guide on key safety training topics, requirements for certifications, and answers to common training questions.

  • Conduct EHS Inspections and Audits

    Record and manage your organization’s inspection data with IndustrySafe’s Inspections module. IndustrySafe’s pre-built forms and checklists may be used as is, or can be customized to better suit the needs of your organization.

  • Industry Safe

OH&S Digital Edition

  • OHS Magazine Digital Edition - January 2019

    January 2019

    Featuring:

    • PREVENTING ERRORS
      Production vs. Safety 
    • EMERGENCY SHOWERS & EYEWASH
      Meeting the Requirements for Emergency Equipment
    • CONSTRUCTION SAFETY
      The State of Contractor Safety
    • FOOT PROTECTION
      The Three Keys to Effective Chemical Management
    View This Issue