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Revised 2/19/02

What Does OSHA Mean When They Say "Appropriate?"
Understanding the Personal Protective Equipment Standard

By Kimberly Dennis
Research Scientist
Kimberly-Clark Safety Division

Choosing the most appropriate protective apparel can be a tough job. Many purchasers – looking for direction – turn to OSHA’s Standard 29 CFR Part 1910.132, the General Requirements for Personal Protective Equipment. While the standard does an admirable job of requiring employers to provide protective equipment for employees, it remains vague on exactly what is considered to be "appropriate" PPE and provides no criteria for helping purchasers determine what is appropriate.

Even hazard-specific standards like 29 CFR 1910.1001, OSHA’s General Industry Asbestos Standard and 29 CFR 1910.1910.1025, OSHA’s General Industry Lead Standard, while attempting to provide direction specific to those two hazardous materials, still only call for the employer to provide "appropriate" protective work clothing. Specifically, 29 CFR 1910.1001 states, in part, "if an employee is exposed to asbestos…the employer shall provide at no cost to the employee and ensure the employee uses appropriate protective work clothing and equipment such as, but not limited to: coveralls or similar full-body work clothing." The lead standard, 29 CFR 1910.1910.1025 similarly states, in part, "if an employee is exposed to lead…the employer shall provide at no cost to the employee and assure that the employee uses appropriate protective work clothing and equipment such as, but not limited to: coveralls or similar full-body work clothing."

Appropriateness, therefore, is left for the employer to decide, creating uncertainty at best and, at worst, opening the employer up to potential OSHA citations. With this in mind, there are several things employers can do to avoid OSHA citations and provide the "appropriate" protective apparel for employees.

Risk Assessment
Identifying and understanding all the potential hazards to which a worker may be exposed is the first step. What hazardous substances are present in the workplace? Are the hazardous substances particulates, liquids, gases or a combination? Is the route of potential exposure respiratory, dermal, ingestion or a combination? What is the frequency and duration of exposure? Answering these questions will help to identify the process controls and work practice changes that need to be made to eliminate or minimize the hazards.

Answers to these questions also will help to determine if there is anything specific to the worker task(s) that will require protective apparel. Knowledge of the hazardous material will direct the employer to the appropriate OSHA standard for the hazardous material, as covered under 29 CFR 1910 Subpart Z.

Interestingly, a common hazardous material – mold – is currently not covered by any OSHA standards. With the recent explosive growth of the mold abatement marketplace, it is reasonable to anticipate that an OSHA standard will be created at some point to address the mold issue. However, the new guidance may not be any more explicit than that previously offered for asbestos and lead abatement. Until the risk is fully understood and clear OSHA or consensus standards are developed, the employer is left to determine the appropriate protective apparel on their own. These circumstances warrant a conservative approach to selection of PPE for this application.

Fabric Performance
In general, the nature of the hazard will guide the employer to the appropriate clothing. Again, it is up to the employer to determine which fabrics and/or garments will provide protection against the hazards found in their workplace. OSHA does not, as some employers erroneously believe, certify protective apparel for specific applications. Nor does it provide test methods or criteria against which employers can measure the appropriateness of a particular fabric construction or garment. However, there are several fabric/garment performance attributes and related tests that can help employers make an informed decision:

• • Penetration and permeation data – Penetration (the flow of bulk liquid through a material, or through seams or closures) is measured using ASTM F903, a standard test method that visually determines material barrier performance against liquid chemicals under conditions of continuous contact. Permeation (the process by which a chemical moves through protective clothing on a molecular level) is measured by ASTM F739, which tests the resistance of protective clothing materials to permeation by liquid or gaseous chemicals under conditions of continuous contact.
  • Tensile strength and durability – ASTM D5034 tests the force required to break or damage fabric. INDA (Association of the Nonwoven Fabrics Industry) IST 100.2 measures the force required to tear fabric. And ISO 13938-1 measures the strength of fabric to hydraulic pressure. Results of these tests will provide the data employers need to determine the durability of the garment.
  • Breathability – This property is crucial to the comfort the garment affords. ASTM D737 measures the rate and volume of air flow through a fabric, while ASTM E96 determines the water vapor movement (i.e., sweat) through the fabric. Good performance in these tests means less chance of heat stress and a more comfortable and productive worker.
  • Dry Particulate hold-out – While there is currently no industry-standardized test for particulate hold-out, all major fabric and garment suppliers should have data measuring a variety of different size particulates that can pass through the fabric/garment. Look for how much barrier is provided against particulates of a specific size in relationship to the size of the hazardous particles in your environment. This point of reference is particularly applicable in asbestos, lead and mold abatement. For example, since OSHA (in 29 CFR 1910.1001) states that asbestos fibers measure 5 micrometers or longer, with a length-to-diameter ratio of at least 3 to 1, the garments chosen to protect against this hazard should have particulate hold-out that measures accordingly.

Fabric and garment manufacturers should have data on these and other performance attributes readily available. When looking at such data, be sure to ask the following questions about reported results:

• • How recent is the data? Continual improvements in testing methods and detection may make recent testing more accurate.
  • How confident can you be in the data? More tests improve the accuracy of reported results. Repeated testing ensures that the results are representative of current product performance.
  • How reliable is the data? Was the testing done by an independent laboratory? How are the results reviewed for accuracy?

Garment Construction and Design
In addition to fabric performance, much of what constitutes "appropriate" apparel may be found in the garment’s design and construction. Sizing and cut are critical. If the garment doesn’t fit, the apparel itself may expose the wearer to a hazard due to rip-outs or users modifying the garment to be more comfortable (i.e., not zipping up properly, ripping out airholes, etc.).

Look for a generous cut (one that exceeds ANSI minimum sizing standards), especially across the shoulders and key stress areas like knees and crotch. A fuller cut will help to enhance the comfort of the garment and will help reduce pulls, tears and ripouts. Other apparel design features that help to make for a more comfortable, wearable garment include an elastic waist, which can act as a belt for a better fit and a concealed zipper, which offers added strike-through protection.

Seam construction is another important garment design factor to consider. Seams on a garment are as important as the fabric, because they are the most vulnerable part of the garment. Look for garments with seams on the back instead of the front. This provides more protection up front, where it’s needed most.

Serged seams -- a basic stitched seam -- are most common in general protection apparel, where resistance to hazardous substances is not intended. Look for a three-thread overlap stitching for the strongest, most durable seam. A bound seam is reinforced with binding for strength and tear resistance. A taped seam is serged, then reinforced with a film tape designed to be resistant to water and many liquid chemicals. Taped seams are most often found in garments designed to protect against liquid chemicals.

Also consider the range of accessories available from the apparel supplier. If the exposure potential is low, risk may be isolated to specific body areas. In this case all you may need are sleeve protectors or an apron. Or, these accessories may be used to increase the protection afforded by a full-body suit or coverall.

In conclusion, it is important to remember that if the garment is not worn correctly, the employer may be open to an OSHA citation. And even the best protective garment won’t provide the required protection once it’s damaged. It is therefore crucial for safety professionals to not only select the appropriate protective apparel for each work task, but also to properly train workers in appropriately wearing the apparel.