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Shirts as construction protective equipment

Summary A builders’ group asked about construction workers working bare-chested. OSHA said a shirt could be required as protective equipment where sunburn, dermatitis, or abrasion hazards were recognized. It said an employer could be cited for failing to require that protection under the cited rule.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1975-09-18-0
Date issued
September 18, 1975
Status
Active
Status last verified October 10, 2026

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September 18, 1975

Mr. Stephen Schaurer
Associated Builders and Contractors, Inc.
[Recipient address omitted]
Dear Mr. Schaurer:

This is in response to your letter requesting a clarification of OSHA standards in relation to employees working stripped to the waist (bareback).

The OSHA standards 1926.28(a) is written in such manner that it requires protection against all known and recognized hazards. Considering the potential for sunburn, dermatitis and skin abrasion, a shirt would be considered personal protective equipment in the same manner as goggles, hard hats or respirators.

The employer could be cited for failure to require and enforce the use of personal protective equipment including shirts as protection against "bareback" injuries.

Sincerely,
Alfred Barden
Assistant Regional Director
Occupational Safety and Health

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