OSHA’s PPE rules set a clear floor: employers must assess hazards, select PPE that fits, train workers on its use, and maintain it in safe condition. That’s codified in 29 CFR 1910 Subpart I and, specifically, 1910.132’s general requirements and hazard-assessment provisions.
But even with a common baseline, different facilities interpret and apply the rules unevenly. In fenestration, where workers cut, lift, and install glass, those inconsistencies show up quickly: a missed hazard assessment for a new line; cut-resistant gear that isn’t suited to handling large lites; or training that overlooks how heat and dexterity push many workers to “down-class” their PPE.
The result is a gap between theory and practice—and preventable injuries.
Where Gaps Really Emerge
- Paper assessments, real hazards: OSHA requires a documented hazard assessment to determine what PPE is necessary (eye/face, hand/arm, body, feet, hearing) based on tasks and exposures, and to ensure selected PPE fits affected employees. Too often, assessments exist as static binders rather than living documents that track process changes (new glass sizes, automated cutters, different sealants).
- “Good enough” gloves that aren’t: In glass manufacturing and glazing, sleeves and gloves with adequate cut and puncture resistance, as well as grip, are essential. Inadequate selection (e.g., high cut rating but poor grip, or sleeves that shed irritating fibers) can increase risk or reduce compliance if workers remove PPE. NIOSH has documented fiber shedding from certain sleeves, highlighting why material choice and user feedback matter.
- Comfort and climate trade-offs: Workers under heat stress may unzip jackets or switch to lighter gear, creating neck and forearm exposure, critical regions in glass handling incidents. Industry safety experts emphasize correct wear (high collars, proper sleeves) and using cooling garments that maintain comfort, so workers keep wearing their PPE
- "We’ve always done it this way.” Even when PPE is present, habits lag. OSHA injury reports in glass handling repeatedly show lacerations during lifting, staging, and moving panes -- tasks that look routine until something breaks or shifts. These events often involve PPE being present but not optimized (e.g., wrong glove for the grip required, no forearm protection), or training not refreshed to reflect actual handling dynamics.
- Cost-sharing confusion. OSHA’s interpretations clarify that employers must ensure protective equipment is provided and used; payment policies can vary by item type (e.g., everyday safety-toe footwear). Misunderstandings here can delay procurement or lead to ad-hoc substitutions that undermine protection.
Practical Fixes That Stick
A hazard assessment should be treated as a living process, not a one-time exercise. Using OSHA’s 1910.132 framework, companies should re-run task-based assessments whenever glass sizes, lifting equipment, or line speeds change. In fenestration plants, for example, each task (i.e., cutting, edge-seaming, IGU assembly, tempering or annealing transfer, and crate loading) carries its own distinct risks to the hands, face, and body. Building “trigger points” into the safety program, such as a new supplier, a new jig, or a summer heat plan, ensures that reassessment happens automatically whenever working conditions shift.
PPE should also be specified by task, not just by rating. In glass handling, this means using cut-resistant gloves and sleeves with proven grip for vertical carries and staging; mandating mesh-backed cut-protective garments for neck and torso protection in hot environments; and standardizing forearm protection when large lites are handled. Comfort must also be validated; if sleeves itch or trap heat, workers are less likely to wear them properly.
Experimenting with multiple materials and gathering user feedback before standardizing can significantly improve compliance.
Training should close the loop by focusing on the “why.” Instead of relying solely on annual videos, supervisors should conduct quick, five-minute, line-side refreshers that analyze near-misses: what broke, what edges were exposed, how grip failed, or where sleeves rode up. Each lesson should tie back to the hazard assessment and the PPE choice that could have prevented the incident. OSHA’s non-mandatory Appendix B provides a useful template, but the content should be tailored to each facility and updated continuously.
Regular audits should focus on real work, not just documentation. Quarterly “PPE reality checks” conducted during active shifts can help identify gaps between policy and practice. Are jackets zipped? Are sleeves the right length for the task? Comparing what’s observed on the floor with what’s written in the assessment allows immediate correction. OSHA’s own injury data show that many lacerations occur not because of missing PPE, but because equipment was worn incorrectly or unsuited for the task.
Procurement should also balance standards with comfort. OSHA and e-CFR language provide the legal minimums, but user-tested comfort criteria should be added. Pairing ANSI/ASTM cut levels with proven grip performance and thermal strategies (such as breathable sleeves or cooling base layers) ensures that PPE remains effective and wearable year-round, not just in cooler months. Referencing glazing and fenestration-specific standards can further strengthen selection criteria.
Finally, it’s essential to clarify who pays for what before rollout. Employers should define their responsibilities versus those of employees for borderline items, such as general-use safety-toe boots, in accordance with OSHA interpretations. Keeping a rapid-replacement pool for damaged PPE eliminates delays and ensures that protection is never compromised while waiting for new gear.
The Bottom Line
OSHA sets the baseline, but injury prevention happens in the weeds: task by task, sleeve by sleeve, and habit by habit. Fenestration facilities that treat PPE as an adaptable system, grounded in living hazard assessments, task-specific specs, comfort-driven choices, and visible coaching, will shrink the gap between compliance on paper and protection in practice.