Protective clothing and PFDs

The employer must provide and require special protective clothing whenever employees are doing work where protective clothing is necessary to protect them from hazards. Employers are obligated under 1918.105(a)(1) to both supply and enforce use of special protective clothing for employees engaged in tasks that present a need for such clothing.

Yes. Protective clothing that will be reissued must be cleaned and disinfected when necessary before it is given to another employee. The regulation states that "when necessary, protective clothing shall be cleaned and disinfected before reissuance" under 1918.105(a)(2). You should follow manufacturer guidance and any workplace infection-control procedures when cleaning and disinfecting.

The employer must provide and require PFDs for any employee engaged in work in which the employee might fall into the water. The rule is explicit in 1918.105(b)(1)—if a worker could fall into water during their tasks, the employer must supply and enforce wearing an appropriate PFD.

Acceptable PFDs are those that are United States Coast Guard (USCG) approved (Type I, II, III, or V) and are marked for use as a work vest, for commercial use, or for use on vessels. The standard requires USCG-approved devices per 1918.105(b)(2). Make sure each PFD has the appropriate USCG approval markings and any additional markings such as "work vest" or "commercial use."

A PFD is unserviceable when it is damaged in a way that affects its buoyancy or its fastening capability. The standard defines unserviceable condition as damage that compromises buoyancy or fastening in 1918.105(b)(3). Inspect PFDs regularly and remove any device with torn fabric that exposes flotation material, ruptured bladders (for inflatable types), broken buckles or straps, or any other damage that could prevent it from keeping a person afloat or secured.

Employees may use PFDs only if the device is USCG-approved and marked for commercial/vessel use or as a work vest; recreational-only devices that lack appropriate USCG commercial markings do not meet the standard. 1918.105(b)(2) requires USCG approval and marking for work or commercial use, so recreational PFDs without those markings are not acceptable for covered maritime work.

Yes—inflatable PFDs are allowed only if they are USCG-approved under the appropriate USCG classification (for example, as a Type V or other approved type) and are marked for use in commercial or vessel operations. The rule requires that PFDs meet USCG approval and marking criteria in 1918.105(b)(2). Follow the manufacturer's service and inspection guidance for inflatables because they have specific maintenance and inflation-system checks.

The employer is responsible for maintaining PFDs in safe condition and ensuring unserviceable devices are taken out of service. The standard states that "Personal flotation devices shall be maintained in safe condition and shall be considered unserviceable when damaged" in 1918.105(b)(3). Employers should establish inspection, maintenance, and replacement procedures and train employees to report damaged PFDs.

If protective clothing or PFDs are required by the employer for the job, the employer must provide and pay for them unless a specific regulatory exception applies. OSHA's payment interpretation explains that where the employer retains ownership of PPE and the PPE is required by the employer, the employer generally must provide it at no cost to the employee; reasonable deposit systems are allowed only if they do not make the employee involuntarily pay for PPE (see OSHA's Employee PPE payment methods interpretation and 1918.105(a)(1)).

Yes, an employer may require return of employer-owned protective clothing and may take reasonable steps to recover employer property or charge for items the employee fails to return, provided the practice complies with federal, state, and local law and does not result in employees effectively paying for required PPE. OSHA's Employee PPE payment methods interpretation explains that employers may retain ownership and recover unreturned PPE, but they may not charge employees for wear and tear caused by workplace conditions.

No—the standard does not prescribe specific cleaning methods, but it requires that protective clothing be cleaned and disinfected when necessary before reissuance (1918.105(a)(2)). Employers should follow manufacturer instructions and applicable infection-control guidance when cleaning garments and document procedures that ensure garments are safe to reissue.

The regulation specifically requires that the employer provide and require PFDs for employees engaged in work where they might fall into water (1918.105(b)(1)). While the text refers to "each employee," employers should also protect non-employees (visitors, contractors) from hazards; as a best practice, provide and require appropriate PFDs for anyone exposed to fall‑into‑water risks on the worksite, even though the citation language focuses on employees.

You should look for U.S. Coast Guard (USCG) approval markings and wording indicating the device is for use as a work vest, for commercial use, or for use on vessels. 1918.105(b)(2) requires PFDs to be USCG-approved pursuant to 46 CFR part 160 and to carry such markings; absence of those markings means the device does not meet the standard's requirement.

Only repairs that restore a PFD to its original, USCG‑approved condition and do not affect buoyancy or fastening may be acceptable; any damage that affects buoyancy or fastening renders the PFD unserviceable and it must be taken out of service. The standard directs that PFDs be maintained in safe condition and treated as unserviceable when damage affects buoyancy or fastening capability (1918.105(b)(3)). Follow manufacturer guidance and USCG rules for approved repairs.

While 1918.105 does not specify exact inspection intervals, employers must maintain PFDs in safe condition and clean/disinfect protective clothing before reissuance, which implies a program of regular inspections. Implement a documented inspection and maintenance schedule tailored to the device type and work conditions to ensure compliance with 1918.105(a) and 1918.105(b)(3).

Type V PFDs may be acceptable if they are USCG‑approved for the specific work use and are marked appropriately; however, Type V devices are often for special uses and may not provide equivalent general buoyancy. The standard requires USCG approval and proper marking in 1918.105(b)(2), so employers must confirm the Type V device's approval covers the intended work task and follow manufacturer and USCG guidance.

Yes. OSHA standards set minimum requirements and do not prevent employers from adopting more stringent protective clothing or PFD policies. The agency recognizes that employers can impose stricter controls to address workplace hazards beyond the baseline of 1918.105(a) and 1918.105(b). Implementing stricter PPE or inspection measures is a compliant and often prudent practice.

Yes, an employer may use a deposit system as an incentive to ensure return of employer‑owned PFDs, provided the system does not result in employees effectively paying for required PPE and complies with applicable laws. OSHA's Employee PPE payment methods interpretation explains that deposit systems are acceptable if they don't circumvent the rule that employers provide required PPE at no cost; employers must avoid charging employees for wear and tear caused by workplace conditions.

Yes. A PFD must be considered unserviceable if damage affects the fastening capability even if buoyancy is otherwise intact. The regulation explicitly states PFDs are unserviceable when damaged in a manner that affects buoyancy or fastening capability in 1918.105(b)(3); broken buckles, torn straps, or other fastening failures must be corrected or the PFD removed from service.