OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

September 18, 1975

Mr. Stephen Schaurer
Associated Builders and Contractors, Inc.
Empire State
Chapter 214 East Fayette Street
Suite 700
Syracuse, New York 13202

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.


Alfred Barden
Assistant Regional Director
Occupational Safety and Health