Protective clothing and PFDs

Under 1917.95(a) the employer must direct employees who perform work that requires special protective clothing to wear it. Employers are required to identify tasks that need special clothing and ensure affected workers actually wear the required items; this is an active duty to direct and enforce use (1917.95(a)).

• Train workers on when and how to wear the clothing and supervise compliance.
• Keep records or procedures that show which tasks require which protective clothing.

Under 1917.95(a)(2) the employer must ensure previously worn protective clothing is cleaned and disinfected before reissue. Employers must remove contaminants and disinfect garments so they are safe for the next user (1917.95(a)(2)).

• If laundering is done off-site, use procedures that preserve disinfection; if done on-site, maintain proper cleaning equipment and records.
• Do not reissue clothing that cannot be adequately cleaned or that remains contaminated.

Under 1917.95(b)(1) employers must provide and require PFDs for employees (for example, line handlers) who are engaged in work where they may be pulled into the water in specific situations. Those situations include when employees are working in isolation, where limited space creates a fall hazard into the water, or where cargo/obstructions prevent safe footing (1917.95(b)(1)).

• The rule lists the conditions explicitly: 1917.95(b)(1)(i), 1917.95(b)(1)(ii), and 1917.95(b)(1)(iii).
• Employers should evaluate tasks near water against these criteria and require PFD use where any apply.

Under 1917.95(b)(2) PFDs worn by affected employees must be United States Coast Guard (USCG) approved under 46 CFR part 160 and must be marked for use as a work vest, for commercial use, or for use on vessels. Acceptable types include USCG Type I, II, III, or V PFDs (1917.95(b)(2)).

• Verify the USCG approval marking on the PFD and that the label indicates it is suitable as a work vest or for commercial/vessel use.
• Do not use recreational-only PFDs that lack the required USCG approval and markings.

Under 1917.95(b)(3) employers must maintain personal flotation devices in safe condition and consider them unserviceable when damaged so as to affect buoyancy or fastening capability. Damaged or degraded PFDs that compromise flotation or secure fastening must be removed from service (1917.95(b)(3)).

• Inspect PFDs before each use for rips, tears, broken straps, missing hardware, or visible foam deterioration.
• Tag and retire any PFDs showing damage that could reduce buoyancy or prevent secure fastening; replace promptly.

Under 1917.95(c) employers must provide and maintain emergency bathing, eyewash, or other facilities when employees are exposed to hazardous substances that may require such emergency decontamination. The requirement is exposure-based: if a work process can cause chemical or contaminant contact that necessitates immediate washing, facilities must be available and kept in good working order (1917.95(c)).

• Evaluate chemicals and tasks to determine if emergency wash or eyewash is needed (e.g., corrosives, irritants).
• Keep eyewash/showers operational, flushed, and accessible; train workers on their location and use.
• For guidance on first aid readiness and training implications, see OSHA's interpretation on first aid and bleeding control (https://www.osha.gov/laws-regs/standardinterpretations/2019-06-19).

No, Part 1917 (including 1917.95) does not apply to a designated waterfront facility used solely for bulk storage, handling, and transfer of liquids or gases. OSHA has interpreted that such facilities fall within the definition of a "marine terminal" that Part 1917 excludes from its scope in certain situations, so the Part's specific provisions would not apply (Applicability to waterfront facilities).

• If your facility is a designated waterfront facility, consult OSHA or applicable industry standards to determine which OSHA provisions, if any, apply.

Employers generally must provide required personal protective equipment at no cost to employees, though certain narrow exceptions and administrative arrangements (like deposits) are allowed if they do not effectively make employees pay for required PPE. OSHA has explained payment rules and acceptable deposit arrangements in its interpretation on employer PPE payment methods (Employee PPE payment methods).

• A deposit system may be used if the employer retains ownership and the system does not result in the employee bearing the cost of required PPE.
• Employers may require return of employer-owned PPE on termination and may attempt to recover the value of unreturned items consistent with federal/state law, but may not charge employees for wear and tear due to work conditions.

Yes, 1917.95(b)(2) allows PFDs that are USCG-approved Types I, II, III, or V, and specifically indicates that Type V work vests are acceptable if USCG-approved and marked for commercial or vessel use (1917.95(b)(2)).

• Always confirm the USCG approval and that the PFD is marked for work/commercial use before issuing it to employees.

Under 1917.95(b)(1)(ii) employers must provide and direct wearing of PFDs where the physical limitations of available working space create a hazard of falling into the water. If cramped or constrained footing increases the risk of a fall into the water, a PFD is required for employees working there (1917.95(b)(1)(ii)).

• Conduct a worksite assessment of space and footing; if safe footing cannot be guaranteed, issue and enforce PFD use.
• Engineering or administrative controls to improve footing can reduce the need for PFDs, but until hazards are corrected PFDs should be used.

Yes, under 1917.95(b)(1)(iii) employers must require PFDs when the work area is obstructed by cargo or other obstacles that prevent employees from obtaining safe footing. Obstructed work areas that increase the risk of falling into the water trigger the PFD requirement (1917.95(b)(1)(iii)).

• Clear obstructions where possible; where hazards remain, provide appropriate USCG-approved PFDs and enforce their use.
• Consider additional controls (e.g., temporary platforms, guardrails) to reduce reliance on PFDs alone.

Under 1917.95(b)(3) the employer is responsible for maintaining PFDs in safe condition, which includes inspection; PFDs must be removed from service when damage affects buoyancy or fastening capability (1917.95(b)(3)).

• While the standard does not set a specific interval, best practice is to inspect PFDs before each use and perform documented periodic inspections (weekly or monthly depending on exposure).
• Keep records of inspections and retire any PFDs showing compromised flotation or fastenings.

Yes, 1917.95(b)(2) requires that PFDs be USCG-approved and marked for use as a work vest, for commercial use, or for use on vessels. Employers should not issue PFDs lacking those markings for maritime work tasks (1917.95(b)(2)).

• Check label/stitching for USCG approval and the words indicating suitability for work or commercial use before issuing a PFD.

Under 1917.95 the employer must provide and shall direct the wearing of PFDs where required, so the employer must enforce PFD use and take appropriate actions when an employee refuses. Employers should correct the behavior through supervision, training, and discipline as needed to ensure compliance (1917.95(b)(1)).

• Retrain the worker on the hazard and the PFD requirement, and document the refusal and corrective actions.
• If refusal continues, take progressive disciplinary steps per company policy to protect the worker and others.

1917.95 does not require PFDs to be personally assigned; it requires that protective clothing be cleaned and disinfected before reissuance and that PFDs be maintained in safe condition. Therefore employers may reissue cleaned and serviceable PFDs, provided they are properly cleaned, disinfected, inspected, and remain USCG-approved (1917.95(a)(2); 1917.95(b)(3)).

• Track cleaning and inspection cycles; do not reissue a PFD that shows damage affecting buoyancy or fastenings.

OSHA requires emergency bathing and eyewash facilities under 1917.95(c) when exposures warrant them, but OSHA's broader guidance on first aid readiness (including bleeding control) is provided in its interpretation on first aid and bleeding control. Employers should ensure on-site first-aid capability matches workplace hazards and exposures (1917.95(c); First aid and bleeding control).

• Evaluate workplace hazards to determine appropriate first-aid kits, trained personnel, and emergency response equipment.
• For detailed guidance on training and kit contents, consult OSHA's first-aid interpretation linked above.

Under 1917.95(b)(3) a PFD is unserviceable when damaged so as to affect buoyancy or fastening capability; a torn outer shell alone does not automatically make a PFD unserviceable if the foam flotation and fastenings are unimpaired. However, any tear that allows foam loss, waterlogging, or compromised fastenings means the PFD must be removed from service (1917.95(b)(3)).

• Inspect for foam compaction, exposed foam, or water saturation; if any of those are present, retire the PFD.
• When in doubt, tag the PFD out of service and replace it.

Yes, employers may use a deposit system for employer-owned protective clothing so long as the system does not effectively require employees to pay for PPE that must be provided at no cost; OSHA permits deposits but warns against administering them in a way that circumvents the payment rule (Employee PPE payment methods; see also 1917.95(a)).

• Use a written agreement and clear return policy; do not charge employees for wear and tear related to the work.
• Ensure deposits are refundable on return of the PPE or of no greater value than the employer-owned item if unreturned, consistent with federal and state law.

No, 1917.95(b)(2) requires PFDs worn by affected employees to be USCG-approved pursuant to 46 CFR part 160 and marked for work vest, commercial use, or use on vessels; many recreational-only life jackets lack the required commercial/work markings and are therefore not acceptable (1917.95(b)(2)).

• Verify the PFD's approval and marking before use; when in doubt choose a USCG-approved work vest or commercial PFD.

Modifying safety equipment can affect its approved performance; for PFDs, employers should avoid unauthorized modifications that could affect buoyancy or fastenings. While 1917.95 does not specify modification approval, employers must ensure PFDs remain USCG-approved and serviceable per 1917.95(b)(2)–(3).

• If modification might affect safety, consult the PFD manufacturer or a qualified expert and document approval before applying changes.
• Do not remove or alter USCG approval marks or labels.

Although 1917.95 does not spell out a specific training schedule, employers who must provide and direct the wearing of PFDs are responsible for ensuring employees know how to use and inspect them safely; this follows the standard’s duty to provide and maintain PFDs in serviceable condition (1917.95(b)(1)–(3)).

• Provide hands-on training on donning, adjustment, inspection, and limitations of the PFD.
• Retrain when new PFD models are introduced or when inspections reveal misuse or defects.

Yes, under 1917.95(b)(3) PFDs must be maintained in safe condition and unserviceable PFDs (those damaged so as to affect buoyancy or fastenings) must be removed from service and replaced to maintain worker safety (1917.95(b)(3)).

• Employers should keep spare, USCG-approved PFDs available for immediate replacement during shifts.

1917.95(b)(1) requires employers to provide and direct the wearing of PFDs for employees engaged in work where they may be pulled into the water under the listed conditions; this calls for wearable PFDs for those employees rather than relying solely on throw rings. Employers must provide USCG-approved wearable PFDs when the standard's conditions apply (1917.95(b)(1)–(2)).

• Throw rings and rescue devices are useful supplemental equipment but do not substitute for wearable PFDs when wearable PFDs are required by the standard.

Under 1917.95(c) the employer must provide emergency decontamination facilities when employees are exposed to hazardous substances that may require emergency bathing or eyewashing; the employer must assess workplace hazards and decide if such facilities are necessary (1917.95(c)).

• Use safety data sheets (SDSs), industrial hygiene assessments, and manufacturer guidance to determine the need for eyewash/showers.
• When in doubt about first-aid readiness or equipment needs, consult OSHA's first-aid interpretation for additional context (First aid and bleeding control).