Q: Is the wearing of shorts in a parts warehouse permitted by OSHA?
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A: Wearing shorts in a parts warehouse is not expressly prohibited by OSHA, but a safety professional should take the following considerations into account.
Under OSHA’s general requirements for personal protective equipment (PPE) (29 CFR 1910.132), employers are required to assess the workplace to determine if hazards are present that necessitate the use of PPE, including protective clothing. However, under 29 CFR Appendix B to Subpart I of Part 1910, OSHA instructs that PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound manufacturing practices. Common hazards include chemical hazards, environmental hazards such as machinery or sharp materials, radiological hazards, and irritants. Safety officers should use common sense and their expertise to assess the hazards present in the workplace and to address them appropriately, whether it is through the use of PPE or through a dress code. Consequently, if wearing shorts presents a safety hazard in the parts warehouse, they should be prohibited under a facility dress code.
Additionally, under the OSH Act’s General Duty Clause (GDC), employers are required to provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.…” Employers violate the GDC if they fail to keep the workplace free of a hazard to which employees are exposed; a hazard was recognized as a hazard by the employer or the employer’s industry; a hazard was causing or was likely to cause death or serious physical harm; or there was a feasible and useful method to correct the hazard. In your situation, if wearing shorts in the warehouse would create a hazard that could cause death or serious physical harm to workers, they should not be permitted.
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