Personal protective equipment requirements

Under 1926 Subpart E, an employer must provide PPE whenever hazards in the workplace cannot be eliminated or controlled by other means. Employers must assess the worksite, identify hazards that could injure eyes, head, hands, feet, or body, and supply appropriate PPE to protect workers from those hazards per 1926 Subpart E. See the personal protective equipment requirements in 1926 Subpart E for the types of protection and general duty to provide PPE.

Workers must wear hard hats when they are exposed to potential head injuries from falling or flying objects, struck-by hazards, or electric shock. Under 1926 Subpart E employers are required to provide head protection when such hazards exist and to ensure employees use it correctly.

Eye protection is required whenever workers are exposed to flying particles, chemical splashes, molten metal, or other hazards that could injure the eyes or face. Employers must provide appropriate eye and face protection and ensure its use whenever such hazards are present, as required by 1926 Subpart E.

Employers must maintain PPE in a clean, sanitary, and reliable condition so it continues to protect workers. Under 1926 Subpart E employers must inspect, repair, replace, and store PPE properly and ensure it remains effective for the hazards present.

Respiratory protection must be used when engineering and work-practice controls cannot reduce airborne exposures to safe levels and the employer has determined that respirators are necessary for worker protection. Employers must select appropriate respiratory protection based on the contaminant and level of exposure and follow the applicable respiratory protection requirements in OSHA construction standards referenced in 1926 Subpart E.

Employers must train workers in how to use, wear, inspect, maintain, and store PPE, and when it is necessary to use it. Training needs to be in a language and vocabulary workers understand so they can properly inspect and use PPE and recognize when it needs repair or replacement as required by 1926 Subpart E.

A ladder alone is generally not considered adequate fall protection for tasks with significant fall risk; employers should provide additional measures such as secured ladders, work platforms, or personal fall arrest/positioning systems when appropriate. OSHA guidance has advised securing ladder bases and supporting top rails and, where practical, using platforms or lifelines with harnesses for connector work as discussed in the ladder interpretation at Ladder and fall protection requirements and consistent with 1926 Subpart E.

When a ladder is placed on a slippery concrete surface, the ladder base must be secured to prevent slipping and the rails at the top should be equally supported. This specific guidance comes from OSHA’s interpretation letter advising that employers secure the ladder base on slippery concrete per the ladder rules (see Ladder and fall protection requirements) and consistent with ladder provisions referenced within 1926 Subpart E.

OSHA recommended securing the ladder base, ensuring the top rails are equally supported, using a wide fork-like attachment at the top to prevent the ladder from sliding off columns, or using elevating/rotating work platforms; it also suggested rigging body belt/harness systems to lifelines attached to columns as an added precaution. This practical guidance is provided in the OSHA interpretation Ladder and fall protection requirements and should be used in conjunction with applicable requirements in 1926 Subpart E.

Yes. The construction beryllium standard applies to occupational exposure to beryllium in all forms, compounds, and mixtures in construction, except for specific articles and materials expressly exempted in the standard. This scope is described in the interim enforcement guidance memorandum 2020 Beryllium Standards Guidance and applies alongside applicable provisions of 1926 Subpart E.

Yes. The construction beryllium standard excludes certain articles and materials as listed in paragraphs (a)(2) and (a)(3) of the beryllium rule; those exemptions are discussed in OSHA’s interim guidance. For details on scope and the exemptions, see 2020 Beryllium Standards Guidance and consult the construction beryllium rule as implemented in conjunction with 1926 Subpart E.

If exposures might exceed permissible limits, the employer must implement controls (engineering and work-practice), and where those do not reduce exposures sufficiently, provide appropriate personal protective equipment and respiratory protection as required by the beryllium standard and related construction requirements. OSHA’s interim enforcement guidance explains these expectations for construction and is available in 2020 Beryllium Standards Guidance and must be applied alongside worker protection requirements in 1926 Subpart E.

OSHA’s 1991 interpretation suggested that body belt or harness systems could be rigged to lifelines attached to columns as an added precaution for ladder users, but this is practical guidance from that letter and must be considered alongside current fall protection rules. See the ladder guidance at Ladder and fall protection requirements and apply it together with the applicable provisions in 1926 Subpart E and other fall protection standards in Part 1926.

OSHA compliance safety and health officers (CSHOs) use the interim enforcement guidance for the 2020 Beryllium standards when conducting inspections until a formal beryllium compliance directive is issued. This enforcement direction is described in 2020 Beryllium Standards Guidance and applies to inspections addressing beryllium-related hazards in construction consistent with 1926 Subpart E.

Employers can install a wide fork-like attachment at the top of the ladder that overlaps the column sides, secure the top rails so they are equally supported, or use alternative access like elevating platforms to prevent ladders from sliding off columns. OSHA suggested these measures in the ladder interpretation Ladder and fall protection requirements and they should be implemented alongside the PPE and access requirements in 1926 Subpart E.

Employers should consider elevating and rotating work platforms when tasks cannot be performed safely from a ladder—for example, for prolonged work, work that requires both hands, or when initial connector tasks expose workers to elevated fall risks. OSHA recommended platforms as an alternative to ladders in the Ladder and fall protection requirements interpretation and such choices should align with the PPE and safety requirements in 1926 Subpart E.

Employers should follow the interim enforcement guidance and apply controls and PPE consistent with the 2020 beryllium standards as described by OSHA until a final compliance directive is issued. OSHA’s memorandum 2020 Beryllium Standards Guidance provides the interim guidance and is intended to be used for enforcement and protection of workers in construction together with 1926 Subpart E.

Employers should evaluate the specific beryllium exposure route and level (inhalation, skin contact), implement engineering and work-practice controls first, and then select PPE (including appropriate respirators, protective clothing, and gloves) to fill any remaining protection gaps. This approach follows the hierarchy of controls described in OSHA’s beryllium guidance 2020 Beryllium Standards Guidance and should be applied together with PPE requirements in 1926 Subpart E.

Yes. The interim memorandum encourages federal OSHA and strongly recommends that State Plan authorities adopt a similar enforcement policy for the 2020 beryllium standards. OSHA’s instruction to regional administrators and State Plan designees is described in 2020 Beryllium Standards Guidance and employers should anticipate consistent enforcement practices alongside 1926 Subpart E.