STSC Personal Protective Equipment in Construction 2 — Questions and Answers
Question 1: What is the employer's responsibility regarding PPE under OSHA 29 CFR 1926.28?
- Employers must recommend PPE but workers are responsible for purchasing their own
- Employers must provide and ensure use of appropriate PPE at no cost to employees (Correct answer)
- Employers must provide a PPE budget and allow workers to select their own equipment
- PPE requirements apply only when specific OSHA standards reference them
Correct answer: Employers must provide and ensure use of appropriate PPE at no cost to employees
OSHA 1926.28 and the PPE payment rule (29 CFR 1910.132(h)) require employers to provide PPE at no cost to employees, except for safety-toed footwear, prescription safety glasses, and logging boots (which employers may require workers to provide).
Per OSHA 1926.28 and 1910.132(h), employers must provide PPE required by OSHA standards at no cost to employees. Exceptions where the employer is not required to pay include: non-specialty safety-toed footwear (if the employee uses it off the job), non-specialty prescription safety glasses (if usable off the job), logging boots, and everyday clothing used as PPE. For all other required PPE — hard hats, safety glasses for job-specific hazards, hearing protection, fall protection harnesses, gloves, respirators — the employer must provide at no cost. The employer must also replace PPE worn out through normal use and must not use PPE costs as a mechanism to discourage PPE use.
Question 2: A worker is using a half-face air-purifying respirator (APR) with organic vapor (OV) cartridges in an environment with unknown contaminant concentration. Why is this potentially unsafe?
- Half-face APRs are not NIOSH-approved
- APRs cannot be used when contaminant concentration is unknown or may exceed 10 times the PEL (IDLH or above) (Correct answer)
- The worker needs to add a P100 prefilter to use an OV cartridge
- Organic vapor cartridges require powered air purifying for unknown concentrations
Correct answer: APRs cannot be used when contaminant concentration is unknown or may exceed 10 times the PEL (IDLH or above)
Air-purifying respirators require a known, non-IDLH atmosphere to be safely used. When concentrations are unknown, air-purifying respirators may not provide adequate protection — supplied-air or SCBA is required for unknown or IDLH atmospheres.
Per OSHA 1910.134(d)(1)(iii), APRs must not be used when the concentration of contaminants is immediately dangerous to life or health (IDLH), is unknown, or when the atmosphere contains less than 19.5% oxygen. APRs (cartridge respirators) work by passing contaminated air through sorbent media that removes specific contaminants — when concentrations exceed the cartridge's capacity or are unknown, breakthrough can occur without warning. IDLH conditions require atmosphere-supplying respirators (SCBA or supplied-air respirator with escape cylinder). This is particularly important in confined spaces, chemical spill response, and demolition of buildings with unknown hazardous materials.
Question 3: Under OSHA's respiratory protection standard (29 CFR 1910.134), what must be included in a written respiratory protection program?
- Only the types of respirators available and their storage locations
- Procedures for respirator selection, employee training, medical evaluation, fit testing, maintenance, and program evaluation (Correct answer)
- The site's OSHA compliance history and inspection records
- Workers' names and their specific respiratory sensitivities
Correct answer: Procedures for respirator selection, employee training, medical evaluation, fit testing, maintenance, and program evaluation
OSHA 1910.134(c) requires a written respiratory protection program containing: selection procedures, medical evaluation requirements, fit testing procedures, use requirements, maintenance and care, training, and program effectiveness evaluation.
Per OSHA 1910.134(c)(1), a written respiratory protection program must include procedures for: (1) respirator selection based on hazard assessment; (2) medical evaluation of employees required to wear respirators; (3) fit testing (quantitative or qualitative) for tight-fitting respirators; (4) proper use — including emergency use and limitations; (5) maintenance, cleaning, disinfecting, inspection, storage, and disposal; (6) ensuring adequate air quality for supplied-air respirators; (7) training on respiratory hazards and correct respirator use; (8) regular program evaluation. The written program must be specific to the workplace and updated as needed. A qualified program administrator must manage and update the program.
Question 4: A construction worker needs eye protection for grinding operations. Which eye protection is the MINIMUM required?
- Safety glasses with side shields meeting ANSI Z87.1 (Correct answer)
- Indirect-vent chemical goggles
- A full-face shield worn over safety glasses
- Safety glasses without side shields if the worker faces away from the grinder
Correct answer: Safety glasses with side shields meeting ANSI Z87.1
For grinding, OSHA 1926.102 requires eye protection against flying particles. Safety glasses with side shields meeting ANSI Z87.1 are the minimum requirement for grinding, though goggles may be preferable for fine particle operations.
OSHA 1926.102(a)(1) requires eye protection for operations that create flying particles, sparks, or fragments. For grinding operations, the minimum is safety glasses with side shields marked Z87 or Z87+. However, for heavy grinding producing significant particle spray, close-fitting impact goggles (indirect vent) provide better protection. Face shields provide splash and impact protection for the face but do not replace safety glasses — they must be worn over safety glasses because the gap at the top and bottom of the face shield allows particle ingress. The appropriate level of eye protection should be determined by the grinding application and particle characteristics.
Question 5: What is the correct action if a hard hat sustains a significant impact, even if no visible damage is evident?
- Continue using it if there are no cracks or dents
- Remove it from service and replace it — internal damage may compromise protection (Correct answer)
- Apply a manufacturer-approved protective coating to reinforce it
- Submit it for inspection by the safety officer within one week
Correct answer: Remove it from service and replace it — internal damage may compromise protection
Hard hat shells can absorb impact energy through internal structural damage invisible to the naked eye. Any hard hat that sustains a significant impact must be removed from service and replaced, regardless of external appearance.
Hard hat shells are made of high-density polyethylene (HDPE) or similar thermoplastic materials that absorb impact energy through controlled deformation of the crystalline polymer structure. After a significant impact, this microstructural damage reduces the shell's ability to absorb subsequent impacts — but the damage is typically invisible from outside. OSHA 1926.100 and ANSI Z89.1 both state that hard hats that have received significant impacts must be replaced. This same principle applies to helmets in general: the energy-absorbing system can be compromised without visible evidence. Regular inspection should also check for cracks, chalking, and UV degradation — replace hard hat shells every 2–5 years depending on use and exposure.
Question 6: A construction site supervisor is developing a heat stress prevention program. Which PPE consideration is MOST IMPORTANT when workers must wear extensive body-covering PPE (chemical suits, high-visibility vests, coveralls) in hot weather?
- Ensuring PPE color is lighter to reflect heat
- Accounting for heat burden added by PPE in the heat stress assessment and implementing work-rest cycles (Correct answer)
- Requiring workers to drink water before donning PPE
- Selecting PPE made of natural fibers only
Correct answer: Accounting for heat burden added by PPE in the heat stress assessment and implementing work-rest cycles
PPE adds a metabolic heat burden (clothing heat correction factor) because it traps body heat and may impair sweat evaporation. Heat stress assessments using WBGT or heat index must account for PPE heat burden, and work-rest cycles must be adjusted accordingly.
Per NIOSH and ACGIH standards, PPE ensembles add a Clothing Adjustment Factor (CAF) to the Wet Bulb Globe Temperature (WBGT) reading used in heat stress assessments. Examples: single-layer work clothing (baseline 0°C adjustment); coveralls add +2°C; impermeable suits add up to +11°C to the effective WBGT. When workers must wear encapsulating or impermeable PPE in hot conditions, the heat stress threshold is reached at much lower ambient temperatures. Work-rest cycles and water/shade breaks must be shortened proportionally. This is a critical consideration for STSC supervisors managing workers in chemical PPE during summer construction.
STSC Personal Protective Equipment in Construction 2
What is the employer's responsibility regarding PPE under OSHA 29 CFR 1926.28?