Are employers performing masonry work required to wear gloves?

NOTE: The following is from a Letter of Interpretation dated February 2, 2010:

OSHA does not have a standard that specifically requires the use of gloves by masons. The applicable regulation is 29 CFR 1926.95(a), which is the general standard requiring the use of personal protective equipment (PPE) in construction work. That provision reads as follows:

“Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.”

As you can see from the language of the standard, PPE is only necessary when employees are exposed to the types of hazards that can be mitigated through the use of such protective equipment. Masonry cement typically consists of potentially hazardous components, e.g., calcium carbonate and portland cement with trace amounts of hexavalent chromium, and it is OSHA’s understanding that masons routinely work with wet cement. Evidence suggests that exposure to wet cement can cause serious skin injuries (e.g., caustic burns) and illnesses (e.g., contact or allergic dermatitis).

During OSHA’s recent rulemaking for the hexavalent chromium standards, OSHA looked at the dermal effects of exposure to cement and noted that “many workers develop cement dermatitis, including masons,” and that “[w]ork with cement is regarded as the most common cause of [hexavalent chromium]-induced dermatitis.”

To determine whether a particular task poses a hazard to employees’ hands, the employer should designate a safety officer or some other qualified person with expertise to assess work activity hazards and select appropriate PPE.

Although OSHA cannot take a position on the feasibility of wearing gloves during masonry work generally, to the extent a hazard assessment shows that gloves are necessary in a specific workplace, that particular masonry employer may be excused from compliance if it can establish: (1) that the use of gloves would be impossible or would prevent performance of required work; and (2) that it took reasonable alternative steps to protect employees or there are no alternative means of protection available.