OSHA’s new Enforcement Guidance for Personal Protective Equipment in General Industry (CPL 02-01-050) has been “on the street” for a few weeks and employers are still working through its details. While employers need to go through the directive carefully on their own and incorporate the aspects of the directive that are applicable to their facilities, after a closer review of the document, it is worth emphasizing a few pieces of information that may go unnoticed:

• OSHA states in the directive that body protection is required for employees who face potential bodily injury in the workplace of “any kind” that cannot be eliminated through other control measures. Examples given are radiation, temperature extremes, hot splashes from molten metals, and other hot liquids. According to OSHA, an employer can provide laboratory coats, coveralls, vests, jackets, aprons, surgical gowns, or full body suits to protect against these and other similar hazards, depending on their exact nature.
• Metatarsal guards are required when there is a potential for injury to the metatarsal portion of the foot from impact or compression hazards. “Examples include handling heavy pipes or similar activities where loads could drop on or roll over an employee’s foot.”
• Employees who work in actual or potentially explosive and hazards locations “must wear” conductive shoes to reduce the risk of static electricity buildup on the body. However, employees exposed to electrical hazards must never wear conductive shoes.
• For employers who have instituted a reimbursement policy for PPE (i.e., an employee initially purchases the PPE and is then reimbursed by the employer), the employer should reimburse the employee within one billing cycle or one pay period.

With enforcement guidance out, employers should expect CSHOs to focus more on PPE and PPE payment in the course of inspections. Employers should review their PPE policies, hazard assessments, training, and payment practices to ensure they are fully compliant.