Workwear Regulations and Standards in the United States: An Overview

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Workwear Regulations in the United States

Workwear in the United States are covered by various standards and other compliance requirements intended to ensure that these meet certain safety and performance criteria.

In this guide, we take a closer look at Occupational Safety and Health Standards, ASTM standards, 16 CFR Part 1610, and other compliance requirements relevant for workwear in the US.


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29 CFR Part 1910 – Occupational Safety and Health Standards

29 CFR Part 1910 is based on the Occupational Safety and Health Act and sets occupational safety and health standards for products used in the workplace to create a safe working environment for workers.

The Part contains requirements for personal protective equipment, including workwear. Here are the main requirements:

  • Standards that must be followed
  • Documentation requirements
  • Labeling requirements

Here are some of the types of workwear that is covered:

  • Eye and face protection
  • Respiratory protection
  • Head protection
  • Foot protection
  • Electrical protective equipment
  • Hand protection
  • Protective clothing (fire protection)

Standards

Here are some examples of standards mentioned in the part that are relevant for workwear.

Title Description
ASTM D120 – Standard Specification for Rubber Insulating Gloves This standard contains manufacturing and testing specifications for rubber-insulating gloves to protect the wearer from electrical shocks.

The regulation mentions this standard but we were not able to find information specifying if it is incorporated by reference.

ASTM D1051 – Standard Specification for Rubber Insulating Sleeves This standard contains manufacturing and testing specifications for rubber-insulating sleeves to protect the wearer from electrical shocks.

The regulation mentions this standard but we were not able to find information specifying if it is incorporated by reference.

ASTM F2412 – Standard Test Methods for Foot Protection This standard contains test methods for footwear products. The test methods are used to measure the effectiveness of the product against various hazards (e.g. falling objects, electric shocks).

This standard is incorporated by reference.

ANSI/ISEA Z87.1 – American National Standard for Occupational and Educational Personal Eye and Face Protection Devices This standard contains testing and marking requirements for eye and face protection devices. It can be used to ensure that protectors are designed to reduce or prevent the possible injuries resulting from impact, non-ionizing radiation, and chemical exposures in the workplace.

This standard is incorporated by reference.

ANSI/ISEA Z89.1 – American National Standard for Industrial Head Protection This standard covers protective helmets. The standard contains testing and performance requirements for such products.

This standard is incorporated by reference.

ASTM F496 – Standard Specification for In-Service Care of Insulating Gloves and Sleeves This standard covers gloves and sleeves. It contains testing requirements to ensure that the covered items protect the user from electrical shocks.

The regulation mentions this standard but we were not able to find information specifying if it is incorporated by reference.

Documentation requirements

The legislation contains documentation requirements such as the following:

a. Test reports

b. Other documentation showing that the product meets the appropriate test standards

c. Manufacturer instructions

Labeling requirements

Here are some of the labeling information requirements contained in this part:

  • Classification labels
  • Warning labels
  • Information for the purposes of traceability
  • A label or statement of certification, if applicable

16 CFR Part 1610 – Standard for the Flammability of Clothing Textiles

16 CFR Part 1610 based on the Flammable Fabrics Act contains flammability standards covering some types of clothing and textile products.

Note that this standard does not cover hats, gloves and footwear unless the products also cover part of the body.

Standards

The standard contained in this part requires the textile product to be classed into three flammability classes:

a. Class 1, Normal Flammability – which is acceptable for use in clothing

b. Class 2, Intermediate flammability – which may be used for clothing

c. Class 3, Rapid and intense burning – which must not be used for clothing

The test method described in the legislation is designed to measure the burn time of the textile product.

General Certificate of Conformity (GCC)

Importers and manufacturers of workwear that falls under the scope of this part are required to issue a General Certificate of Conformity.

The general certificate of conformity contains information about the product and manufacturer or importer and guarantees that the product complies with applicable safety standards.

Other documentation requirements

This standard contains other documentation requirements, including the following:

a. Documentation requirements concerning the furnishing guarantees (if applicable)

b. Documentation requirements for shipments of dangerously flammable articles

c. Record-keeping requirements

16 CFR Part 423 – Care Labeling of Textile Wearing Apparel and Certain Piece Goods as Amended

16 CFR Part 423 covers textile wearing apparel and certain piece goods.

Under this part, covered products must come with a label containing regular care information and instructions. This label is referred to as the care label.

Labeling requirements

The care label should contain information such as the following:

  • Care instructions
  • Care symbols

As explained in 16 CFR Part 423.2, any appropriate terms and symbols may be used on care labels or care instructions so long as they describe the regular care procedures and fulfill the requirements of the regulation. Standard terms can be found in Appendix A.

ASTM Standard D5489-96c – Guide to Care Symbols for Care Instructions on Consumer Textile Products

16 CFR Part 423 references the standard ASTM Standard D5489-96c, which contains care symbols for textile products. It states that the symbols contained in the above standard can be used on care labels or care instructions instead of the terms.

16 CFR Part 300, Part 301, Part 303 – Textile, Wool and Fur Acts and Rules

16 CFR Part 300, Part 301, and Part 303 cover textile, wool, and fur products. The applicable part depends on the type of material that is used on the product.

The parts contain labeling requirements to disclose information concerning the identity of the material used and its composition (e.g. 100% cotton). They also contain further documentation and labeling requirements which are elaborated on below.

Documentation

The documentation requirements that are mentioned in these Parts include the following:

  • Requirements relating to the maintenance of records
  • Requirements for the issuance of guarantees (if applicable)
  • Invoicing requirements

Labeling requirements

Here are some examples of labeling information that are mentioned in the parts:

a. Generic names and percentages by weight of the constituent fibers

b. Name under which the person is doing business or registered identification number

c. Country of origin for which the product was processed or manufactured

16 CFR Part 24 – Guides for Select Leather and Imitation Leather Products

16 CFR Part 24 contains a guide that addresses misrepresentations about the composition and characteristics of certain leather and imitation leather products.

It contains examples of terms that can be unfair or deceptive. In general, you should not be making unqualified claims that a product contains “leather”.

For example, it would be deceptive to market a product as containing leather when it contains imitation leather. In this scenario, it should be disclosed that the product contains imitation leather.

ASTM Standards

Numerous ASTM standards are not incorporated or mentioned in the regulations mentioned above, and applications of such standards in general would be on a voluntary basis. However, as products must be safe, voluntary standards that are relevant to workwear must be considered out of practical necessity.

Here we present some examples of ASTM standards and their respective descriptions for workwear.

Title Description
ASTM F1342/F1342M – Standard Test Method for Protective Clothing Material Resistance to Puncture This standard covers protective clothing materials which may include:

  • Plastics or elastomeric films
  • Coated fabrics
  • Flexible materials
  • Laminates
  • Textile materials

The test method described in the standard tests the puncture resistance of protective clothing materials.

ASTM F1359/F1359M – Standard Test Method for Liquid Penetration Resistance of Protective Clothing or Protective Ensembles Under a Shower Spray While on a Manikin This standard covers protective clothing or protective ensembles. It contains test methods that are designed to evaluate the product’s resistance against liquid penetration.
ASTM F2892 – Standard Specification for Performance Requirements for Soft Toe Protective Footwear (Non-Safety / Non-Protective Toe) This standard covers footwear that is used in environments that typically contain workplace hazards.

It contains performance requirements for footwear products such that they possess certain protective properties:

  • Conductive properties
  • Electric hazard protection
  • Static dissipative properties
  • Puncture resistance
  • Slip resistance
ASTM E3109 – Standard Specification for Protective Gloves Worn by Law Enforcement and Corrections Officers This standard covers protective gloves used by law enforcement and corrections officers.

This standard specifies performance requirements for various properties of the glove, including:

  • Cut and puncture resistance
  • Resistance to abrasion and tearing

Lab Testing

Some requirements contained in regulations have testing requirements that necessarily involve approaching a lab testing company. By engaging in testing services, you will receive test reports that can be used to show that your product is compliant with the applicable regulations.

Below we present regulations and standards that contain testing requirements and provide descriptions of the kinds of tests that are needed.

Regulation Lab testing
29 CFR Part 1910 Depending on the type of workwear, testing requirements could include:

  • Tear resistance tests
  • Puncture resistance tests
  • Chemical tests
16 CFR Part 1610 The standard contained in the Part requires the textile to be exposed to a standardized flame, and for the time and distance for the flame to proceed up the fabric to be recorded.

It describes the testing procedure and contains information about the apparatus that must be used.

ASTM standards ASTM standards for workwear typically contain testing specifications and testing methods.

Depending on the product, testing requirements could include:

  • Impact resistance test
  • Compression resistance test
  • Puncture resistance tests

Workwear testing companies

As many regulations and standards contain testing requirements for workwear, a lab testing company should be engaged. Here are some lab testing companies that offer testing services for workwear:

  • Eurofins
  • Hohenstein Americas
  • Vartest Laboratories

Additional requirements

There are other regulations that contain requirements that are relevant to workwear.

Regulation Description
California Proposition 65 This regulation requires products, including workwear, to come with information about harmful substances that may be present (unless you are sure that the product does not contain any restricted substance above the permitted limited).

Satisfying the requirement usually involves testing the product for such substances and applying the required warning label if the product contains harmful substances like PFOA and formaldehyde above the set limit.

Country of origin This regulation requires imported products and/or their packaging to disclose the country of origin of the product.
Toxic Substances Control Act This Act regulates chemicals such as persistent, bioaccumulative, and toxic (PBT) chemicals which may be present in textile products like workwear.

Thus, testing is generally necessary to comply with relevant substance restrictions.

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    Sources: Our articles are written in part based on publicly available information, and our own practical experience relating to product compliance. These are some of the primary sources we use:

    • ec.europa.eu
    • echa.europa.eu
    • ecfr.gov
    • cpsc.gov
    • ftc.gov
    • fcc.gov
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