Personal protective equipment requirements

Under 1926.954(a), personal protective equipment must meet the requirements of Subpart E of 29 CFR Part 1926. Employers must ensure PPE used under this section conforms to the general PPE rules in 1926 Subpart E and the specific provisions in 1926.954(a).

Under 1926.954 and 1926.95(d), the employer is responsible for payment obligations for PPE required by this subpart unless another specific provision says otherwise. The note to paragraph (a) of 1926.954 specifically cross-references employer payment obligations in 1926.95(d).

Under 1926.954(b)(1)(i), personal fall arrest systems must meet the requirements of Subpart M (Fall Protection). The rule states that personal fall arrest systems shall meet the requirements of Subpart M of 29 CFR 1926 and the specific reference in 1926.954(b)(1)(i).

Under 1926.954(b)(1)(ii), personal fall arrest equipment used by employees exposed to hazards from flames or electric arcs must pass an arc-exposure drop test and then still meet the drop-test requirement equivalent to paragraph (b)(2)(xii). Specifically, it must be capable of passing a drop test equivalent to 1926.954(b)(2)(xii) after exposure to an electric arc with a heat energy of 40±5 cal/cm2; see 1926.954(b)(1)(ii).

Under 1926.954(b)(2)(i), hardware for body belts and positioning straps must be made of drop-forged steel, pressed steel, formed steel, or equivalent material, have a corrosion-resistant finish, and have smooth surfaces free of sharp edges. These requirements are stated in 1926.954(b)(2)(i)(A)-(C).

Under 1926.954(b)(2)(ii)–(iv), buckles must withstand an 8.9 kN (2,000 lbf) tension test with limited permanent deformation; D-rings must withstand a 22 kN (5,000 lbf) tensile test without cracking or breaking; and snaphooks must withstand a 22 kN (5,000 lbf) tension test without failure. See 1926.954(b)(2)(ii), 1926.954(b)(2)(iii), and 1926.954(b)(2)(iv).

Under 1926.954(b)(2)(v)–(ix), top-grain leather or leather substitutes may be used but not as the sole load-bearing component, plied fabric must have no exposed raw edges or separating plies, the cushion part of a body belt must have no exposed rivets and be at least 76 mm (3 in) wide, and tool loops must be located so that the central 100 mm (4 in) of the back (from D ring to D ring) is free of attachments. See 1926.954(b)(2)(v), 1926.954(b)(2)(vi), 1926.954(b)(2)(viii), and 1926.954(b)(2)(ix).

Under 1926.954(b)(2)(vii) and Table V-1, positioning straps must pass: a dielectric test of 819.7 VAC per cm (25,000 V/ft) for 3 minutes with no visible deterioration; a leakage test of 98.4 VAC per cm (3,000 V/ft) with leakage current ≤ 1 mA (DC tests at equivalent voltages are acceptable); tension tests of 20 kN for sections without buckle holes and 15 kN for sections with buckle holes; a buckle-tear test at 4.4 kN; and a flammability test where a 500 mm length of strap supporting 100 kg is exposed to a 76 mm flame and any flames must self-extinguish (see 1926.954(b)(2)(vii) and Table V-1.

Under 1926.954(b)(2)(xi)–(xi)(C), snaphooks must be of a locking type where the locking mechanism must be released (or the keeper destructively forced) before the keeper opens; the locking mechanism must require 6.7 N to 17.8 N (1.5–4 lbf) to release; and with the locking mechanism released and force applied against the face of the nose, the keeper may not begin to open with a force of 11.2 N (2.5 lbf) or less and must begin to open with a maximum force of 17.8 N (4 lbf). See 1926.954(b)(2)(xi)(A)-(C).

Under 1926.954(b)(2)(xii), drop tests must use a rigid steel (or equivalent) test mass of 100 kg (220.5 lb) (increased proportionally for employees over 140 kg), with body belts fitted snugly to the test mass and attached to the anchorage by wire rope, or positioning straps adjusted to shortest length and attached between test structure and mass; the mass must be dropped unobstructed 1 meter (39.4 in) from a supporting structure that will sustain minimal deflection. See 1926.954(b)(2)(xii)(A)-(D).

Under 1926.954(b)(2)(xii)(E)–(F), body belts must successfully arrest the fall of the test mass and be capable of supporting the mass after the test, and positioning straps must arrest the fall without breaking with an arrest force not exceeding 17.8 kN (4,000 lbf); additionally, snaphooks on positioning straps may not distort so the keeper would release. See 1926.954(b)(2)(xii)(E)-(F).

Under 1926.954(b)(3)(i), work-positioning equipment must be inspected before use each day to determine it is in safe working condition, and any equipment not in safe condition may not be used. The provision and its inspection guidance note are in 1926.954(b)(3)(i); Appendix F to the subpart contains inspection guidelines.

Under 1926.954(b)(3)(ii), personal fall arrest systems must be used in accordance with the fall protection requirements in 1926.502(d). The standard states that fall protection equipment rigged to arrest falls is considered a fall arrest system and must meet applicable 1926.502(d) requirements.

Under 1926.954(b)(3)(iii)(A), each employee working from an aerial lift must use a fall restraint system or a personal fall arrest system; the provision explicitly states that paragraph (b)(2)(v) of 1926.453 does not apply. See 1926.954(b)(3)(iii)(A).

Under 1926.954(b)(3)(iii)(B)–(C), each employee working more than 1.2 meters (4 ft) above ground on poles, towers, or similar structures must use a personal fall arrest system, work-positioning equipment, or fall restraint unless the employer provides other fall protection meeting Subpart M. The rule provided a temporary exception for qualified employees climbing or changing location on these structures until March 31, 2015; on and after April 1, 2015, qualified employees must use fall protection unless the employer demonstrates that using fall protection while climbing or changing location is infeasible or creates a greater hazard. See 1926.954(b)(3)(iii)(B) and 1926.954(b)(3)(iii)(C); note that employees are not "qualified" for this purpose until trained under 1926.950(b)(7).

Under 1926.954(b)(3)(iv), on and after April 1, 2015, work-positioning systems must be rigged so that an employee can free fall no more than 0.6 meters (2 feet). See 1926.954(b)(3)(iv).

Under 1926.954(b)(3)(v), anchorages for work-positioning equipment must support at least twice the potential impact load of a fall or 13.3 kN (3,000 lbf), whichever is greater. The note to the paragraph also deems certain wood-pole fall-restriction devices that meet ASTM F887-12e1 and the manufacturer's instructions as meeting this anchorage requirement. See 1926.954(b)(3)(v).

Under 1926.954(b)(3)(vi), unless the snaphook is a locking type and specifically designed for the connection, snaphooks on work-positioning equipment may not be engaged directly to webbing/rope/wire rope, to each other, to a D ring already attached to another connector, to a horizontal lifeline, or to any incompatibly shaped object that could allow accidental disengagement. See 1926.954(b)(3)(vi)(A)-(E).

Under the note to paragraph (b)(2), body belts and positioning straps that conform to ASTM F887-12e1 are deemed in compliance with 1926.954(b)(2) when used by employees weighing no more than 140 kg (310 lb) fully equipped. See the note in 1926.954(b)(2).

Under 1926.954(b)(2)(vii)(A)-(B), positioning straps that pass direct-current (DC) tests at voltages equivalent to the specified alternating-current voltages are considered to meet the dielectric and leakage requirements. The standard explicitly notes DC tests at equivalent voltages are acceptable; see 1926.954(b)(2)(vii)(A)-(B).

Under the March 28, 2024 Letter of Interpretation, employers must assess the workplace to determine if hazards are present that necessitate PPE and must prepare a written certification of the hazard assessment when PPE will be required. OSHA interprets 29 CFR 1910.132(d)(1) to require the employer perform the hazard assessment and, where PPE is required, provide a written certification of the assessment; see the OSHA interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28.

According to OSHA's January 4, 2024 Letter of Interpretation, employers must provide full facepiece supplied-air respirators (SARs) operated in pressure-demand mode with an auxiliary positive-pressure SCBA whenever exposures exceed 1 f/cc as an 8-hour TWA; when exposures are at or below 1 f/cc (and not a negative exposure assessment), employers must provide either tight-fitting PAPRs or full facepiece SARs in pressure-demand mode with HEPA egress cartridges or an auxiliary SCBA. See OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04 and the asbestos-in-construction requirements in 29 CFR 1926.1101 referenced in that interpretation.