There is growing momentum to ensure workers of all shapes and sizes are supplied with personal protective equipment that fits properly. Alex Minett, Head of Global New Markets at Veriforce CHAS, considers what lessons the UK can take from the US on this vital topic.
Personal protective equipment (PPE) is crucial to keep workers safe across a wide range of industries. If employers find that PPE is necessary following a risk assessment, they are obliged to provide it free of charge to all workers under the Personal Protective Equipment at Work Regulations (PPER) 2022.
However, PPE can only be considered effective if it fits the employee correctly. As the Health & Safety Executive’s guidance on the PPER regulations notes, there can be “considerable differences in the physical dimensions of different workers and therefore more than one type or size of PPE may be needed”.[1]
All too often, though, the appropriate sizes are not provided. There has been significant research in the UK and abroad showing that women in particular frequently fail to get PPE in the sizes and shapes they need. A Prospect survey published in 2020, for example, found that 48.5% of women and 16.6% of men said their PPE trousers did not fit well. In addition, 44.7% of women and 15.3% of men said their PPE overalls did not fit well.[2] In September 2023, a petition entitled “Add specific provision for women to regulations on PPE in the workplace” was launched on the UK Government website.
Drawing attention to this gender inequality represents an important step forward, but the issue is not limited to women. Young apprentices, for instance, often require smaller sizes than older coworkers. Larger workers can also face issues, particularly with items such as harnesses.
Risks of ill-fitting PPE
The consequences can be significant. If PPE doesn’t fit properly, it may not protect the employee and may even create additional hazards for the employee and those who work with them. Ill-fitting gloves may limit the worker’s ability to grip tools or machinery. Ill-fitting shoes may lead to trips and foot injuries. Ill-fitting eyewear may leave the wearer vulnerable to flying debris, chemicals, and other airborne hazards, while ill-fitting hard hats may obscure vision and increase the risk of slips, trips and falls. Any PPE that doesn’t fit comfortably also increases the risk of non-compliance.
In 2022, a systematic review explored the effect of PPE fit on performance. Of the 16 studies included in the review, 88% showed that the fit of PPE had a statistically significant effect on occupational performance.[3] The impacts of poorly sized PPE were shown to include slower or increased reaction time, decreased range of motion or mobility, decreased endurance or tolerance, decreased pulmonary function, and altered muscle activation.
We have a diverse workforce in the UK with wide-ranging PPE requirements. Failing to provide workers with the right fit can put them in danger and drive them away from particular industries. There is therefore growing momentum to ensure all workers are supplied with PPE that fits exactly as needed.
US sets new standards
In the US, the Occupational Safety and Health Administration (OSHA) – a regulatory agency of the United States Department of Labor – has specific standards that address PPE fit for general industry (29 CFR 1910.132(d)(1)(iii)) and maritime (29 CFR 1915.152(b)(3)).
These state that employers must “select PPE that properly fits each affected employee”.[4] Under the non-mandatory appendix B, the regulations add that “careful consideration must be given to comfort and fit” and “care should be taken to ensure that the right size is selected”.[5] In PPE with adjustable features, it says “adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position”.
On 20th July 2023, OSHA issued a notice of proposed rulemaking to modify 29 C.F.R. 1926.95(c) of the construction regulatory standard set to require construction employers to ensure that their employees also have PPE that fits properly.[6] “If personal protective equipment does not fit properly, an employee may be unprotected or dangerously exposed to hazards and face tragic consequences,” OSHA Assistant Secretary for Occupational Safety and Health Doug Parker explained.
Some questions have been raised about the proposed change. The Construction Industry Safety Coalition (CISC), for example, suggested that it “opens up construction employers to subjective standards of whether particular PPE fits properly and what steps employers must take to ensure that such PPE fits properly, particularly when most PPE does not come in exact sizing for employees”.[7]
OSHA, though, has emphasised that the phrase “properly fits” has been well understood across general industry.
Following the guidance
To comply with the proposed standards, construction employers must assess their current PPE programme and choices. This must consider workers’ gender, race, age, shape and size. Employees’ body size and proportions can differ significantly between hips, chests, and thighs. Hands, feet, faces, ears, ear canals, weight, and height are also factors to consider in PPE fit.
The Center for Disease Control (CDC)/National Institute for Occupational Safety and Health (NIOSH), meanwhile, highlights the importance of considering workers with disabilities, different job functions, and specific requirements of the occupational setting when determining PPE requirements.
Moving forward
PPER 2022 provides details on employers’ responsibilities regarding the provision, compatibility, assessment, maintenance and replacement of PPE, but there is no specific obligation to provide items that properly fit. Many in the UK may therefore welcome the guidance becoming more explicit, with the OSHA’s proposed regulation highlighting a positive path forward.
By embracing its principles, it’s possible to enhance worker safety and promote inclusivity within the industry, ultimately creating a safer and more supportive workplace for everyone involved. Employers therefore need to recognise that one size does not fit all and take action to ensure all workers have access to PPE that fits.
Find out more about Veriforce CHAS at: http://www.chas.co.uk/
References:
[1] https://www.hse.gov.uk/pubns/priced/l25.pdf
[2] https://prospect.org.uk/news/ppe-still-not-right-for-women-sue-ferns-blogs
[3] https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9710848/
[4] https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132
[5] https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910SubpartIAppB
[6] https://www.osha.gov/laws-regs/federalregister/2023-07-20
[7] https://www.osha.gov/laws-regs/federalregister/2023-07-20
