The Real Cost of Noncompliance

Published

Comfort, Correct Wear, and the PPE Performance Gap in AR/FR Clothing Programs


Executive Summary

An arc-rated and flame-resistant clothing program can appear complete on paper. The employer has assessed the hazard, selected qualified PPE, issued garments, trained employees, and documented the process.

The field condition may tell a different story.

Workers may roll their sleeves, leave closures open, remove required layers, add unapproved clothing, or continue wearing garments that have changed after repeated laundering. The clothing may still meet its technical requirements, but the way it is worn no longer matches the protective system the employer evaluated and approved.

This difference represents the PPE performance gap: the distance between the protection established in the specification and the protection that remains correctly in place during actual work.

Comfort does not determine the protection an employee needs. Hazard assessments, exposure conditions, applicable requirements, and protective ratings establish that baseline. Fit, garment construction, fabric performance, layering, laundering, availability, and work conditions then influence whether qualified clothing remains correctly worn.

Research supports discomfort as one barrier to PPE use, but not the only one. A 2025 systematic review found that 27% of workers identified discomfort as a reason for PPE nonuse. PPE shortages, inadequate training, and pressure to save time also affected use.[8]

Safety teams should therefore look beyond technical qualification when comparing clothing options. Wear trials should reflect the work employees perform, the conditions they face, the layers they must wear, and the effects of repeated laundering. The evaluation should consider both what employees report and whether the clothing remains correctly worn in practice.

Protection on Paper and Protection in the Field

The shirt has the required rating. The worker completed training. The issue record is current.

The sleeves are still rolled above the forearms.

That contradiction is easy to treat as an enforcement problem. The supervisor corrects the behavior, safety repeats the rule, and the worker complies temporarily.

Then the sleeves go back up the following afternoon.

The employee may be disregarding a known requirement. But the behavior may also point to poor fit, restrictive garment construction, heavy fabric, moisture retention, layering, or changes after laundering. Limited availability, high work rates, heat exposure, production pressure, or inconsistent supervision.

Correcting the immediate behavior still matters. When the same workaround appears across several employees, crews, or shifts, however, repeating the rule does not explain why it continues.

The protective rating describes what a fabric, garment, or clothing system can do under defined test conditions. An effective program must also determine whether that protection fits the employee, remains serviceable, and stays correctly worn throughout the exposure.

A company can therefore select technically qualified clothing and still lose protection between the specification and the point of work.

The PPE Performance Gap

Every defensible protective-clothing decision begins with the hazard.

OSHA requires employers to assess workplace hazards, select appropriate PPE, provide equipment that properly fits affected employees, and train workers in its use and limitations. Electrical power work may carry additional requirements for incident-energy assessment and arc-rated clothing.[1][3]

Those obligations establish the required level of protection. Comfort cannot make clothing acceptable if it does not meet those protective requirements. The program must then carry that baseline through sizing, availability, training, care, maintenance, layering, and correct wear. A breakdown at any point can change the protection the employee receives.

A shirt may bind during climbing or reaching. Required layers may create excessive bulk. Laundering may change garment dimensions or feel. Employees may add unsuitable personal clothing because approved seasonal options are unavailable.

In each case, the specification remains unchanged. The field condition does not.

The visible result may be rolled sleeves, open closures, removed layers, unapproved outerwear, damaged clothing, or early garment removal. These behaviors do not create identical levels of risk, but they share one characteristic: the protective condition in use no longer matches the condition the employer evaluated and approved.

That is the PPE performance gap.

What the Evidence Says About Comfort and Correct Wear

Fit Affects Continued Use

Fit matters because PPE must remain in the correct position and allow employees to perform their work without creating another hazard.

OSHA requires general-industry employers to select PPE that properly fits each affected employee. Its nonmandatory selection guidance adds that poorly fitting equipment may not provide the necessary protection and that employees are more likely to continue wearing PPE when it fits comfortably.[1][2]

OSHA reinforced the importance of fit when it revised the construction PPE standard. Effective January 13, 2025, the rule explicitly requires properly fitting PPE for affected construction employees.[4]

Fit is therefore more than a preference. It affects whether a garment maintains coverage, supports movement, and remains in use.

Discomfort Is One Barrier, Not the Whole Explanation

A 2025 systematic review combined findings from 18 studies involving 7,612 workers in high-risk industries.

Among the studies that tracked discomfort separately, 27% of workers identified it as a reason for not using PPE. The review also identified PPE shortages, inadequate training, and pressure to save time as barriers.[8]

The takeaway is straightforward: discomfort matters, but it rarely operates alone.

A worker may adjust clothing because it feels hot or restrictive. That response may reflect the fabric, but it could also result from garment cut, incorrect sizing, required layers, environmental heat, physical effort, poor acclimatization, or inadequate recovery.

“This shirt is too hot” is useful information. It is not yet a root-cause determination.

The evidence also has limits. The studies varied by industry, country, PPE type, and reporting method. Because they were cross-sectional, they cannot prove that discomfort directly caused PPE nonuse or incidents. The findings cannot be converted into an FR-specific compliance rate or used to claim a defined reduction in injuries.

Comfort Is Not the Same as Heat Control

NIOSH defines occupational heat stress as the combined effect of metabolic heat, environmental heat, clothing, and PPE. Some clothing and PPE ensembles can reduce normal heat loss, hold heat and moisture near the body, and raise core temperature faster than less burdensome ensembles.[5][6]

Three concepts should remain distinct:

  • Thermal comfort: how hot, wet, heavy, or restricted a worker feels
  • Heat stress: the total heat load created by the environment, work, clothing, and PPE
  • Heat strain: the body’s physiological response to that load

A lighter or faster-drying garment may improve the worker’s experience without independently controlling occupational heat exposure. Fabric selection should complement, not replace, engineering controls, work practices, acclimatization, hydration, recovery, scheduling, and emergency planning.[7]

The Cost of an Unstable Clothing Program

The financial consequences of a workplace injury can be substantial. The National Safety Council estimates that work injuries cost the U.S. economy $181 billion per year, with an average cost of $48,000 per medically consulted injury and $1.54 million per work-related death.[12]

Those figures reflect the broader economic impact of workplace injuries, not the cost of a specific incident to an individual employer. But they show what can be at stake when protection breaks down.

The costs of an unstable clothing program can also appear much earlier. Repeated workarounds create extra work for safety teams, supervisors, procurement, and uniform-program managers. They can also signal that the protection selected on paper is not holding up in the field.

When Protection Breaks Down

Rolled sleeves, open fronts, removed layers, and unapproved outerwear can reduce the coverage the employer intended to provide. Poorly fitting clothing may also shift, pull open, restrict movement, or interfere with other equipment.

The garment may still be technically qualified. But if it is not being worn as intended, the employee may not be receiving the protection the program was designed to provide.

If an incident occurs, the financial impact can expand quickly. Employers may face medical costs, lost productivity, workers’ compensation, and additional time spent investigating the event and keeping operations moving.[13]

The Cost of Repeated Corrections

Problems do not have to result in an injury to consume resources. Supervisors may repeatedly correct the same behavior. Safety teams may investigate complaints or recurring fit issues. Garments may need to be exchanged or replaced earlier than expected.

Each response may seem minor on its own. When the same problems continue across crews or over time, however, the organization is spending more effort to keep the clothing program working as intended.

When Workarounds Become Normal

The risk increases when repeated exceptions stop attracting attention. An experienced technician opens a shirt during a brief task in a hot area. The supervisor allows it because the work is routine and no incident has occurred. Another employee sees the practice and does the same.

Over time, the organization can end up with two standards: the clothing requirements written into the program and the practices accepted in the field. At that point, the issue is no longer a single compliance lapse. It is a sign that the clothing program needs to be examined more closely.

Diagnosing the PPE Performance Gap

A visible behavior points to a problem, but it does not identify the cause.

A single rolled sleeve may call for an immediate correction. When the same workaround appears across several employees, crews, or shifts, use the pattern to decide where the investigation should begin.

Area to Review Signs the Problem May Be Here Questions to Answer
Protective requirements Employees wear inconsistent layers, leave areas uncovered, or use unapproved combinations Is the required clothing system clearly defined? Do employees understand the required layers, closures, and coverage?
Fabric, garment design, and fit Clothing feels heavy or wet, restricts movement, pulls open, or changes after laundering Is the issue caused by the fabric, garment construction, sizing, or a combination of factors?
Care and availability Employees trade garments, wear personal outerwear, keep damaged clothing in use, or lack seasonal options Are correct sizes, replacements, approved layers, and care processes available when needed?
Work and management conditions Adjustments increase during hot weather, demanding work, long shifts, or production pressure Are heat, work rate, recovery, training, supervision, or operational expectations encouraging shortcuts?

The table helps the safety team move from correcting the visible behavior to identifying the part of the system that may be driving it. More than one area may require attention.

Fabric and finished-garment performance should also be separated during the investigation. Fabric affects weight, moisture management/dry time, durability, and color retention. The finished garment adds cut, seams, closures, pockets, reinforcement, and interaction with other PPE.

A lightweight fabric cannot correct a garment that binds during reaching. Moisture management cannot compensate for an unsuitable outer layer. Safety teams must evaluate each component separately enough to identify the cause, but together enough to understand the complete system.

Worker feedback adds another source of evidence. It can reveal when a garment becomes restrictive, where moisture accumulates, which movements cause binding, and what changes after cleaning.

Compare that feedback with observed behavior, task requirements, garment condition, environmental data, care records, and technical requirements.

The goal is not to make PPE selection a popularity contest. It is to determine why the approved system does or does not remain workable.

Evaluating Qualified FR Clothing Options

A wear trial should begin only after the hazard requirements have narrowed the field to qualified options.

Its purpose is not to determine which shirt employees prefer during a fitting. It is to determine how a qualified clothing system performs during representative work.

1. Establish the Protective Baseline

Document the requirements that cannot be compromised:

  • Hazard and exposure
  • Required protective performance and body coverage
  • Approved base and outer layers
  • High-visibility or other combined requirements
  • Care, repair, and replacement criteria

This baseline defines which options can enter the trial.

2. Test Representative Work

Include representative employees, body types, job roles, work rates, shifts, and garment sizes. Focus on the movements and conditions most likely to produce adjustments, such as climbing, reaching, kneeling, harness use, sustained outdoor work, heavy physical effort, and seasonal layering.

Testing only average conditions can hide the point at which clothing becomes difficult to keep correctly worn.

3. Measure Experience and Behavior

Instead of asking only whether the garment was comfortable, ask:

  • Where did it restrict movement?
  • When did it begin to feel hot or wet?
  • Did closures, cuffs, collars, or seams create problems?
  • Did the employee want to adjust or remove part of the system?

Pair those answers with observation:

  • Did the garment maintain coverage?
  • Did sleeves, closures, and layers remain in place?
  • Did employees substitute layers or exchange sizes?
  • Did workarounds increase under specific conditions?

Feedback explains what the employee experienced. Observation shows whether that experience changed how the protection was used.

4. Reevaluate After Laundering

Use the laundering method expected in the program and reassess fit, dimensions, flexibility, closure performance, moisture behavior, worker acceptance, and correct wear.

The final specification should also identify changes that require review, such as a supplier substitution, different fabric, new garment model, altered laundry process, revised work condition, or recurring compliance pattern.

A successful trial cannot prove that future noncompliance will never occur, but it can expose problems before a broad rollout and provide stronger evidence for the specification decision.

Putting the Framework to Work With GlenGuard

When the investigation points to weight, moisture management/dry time, durability, or post-laundry performance, fabric selection becomes part of the corrective strategy.

GlenGuard AR/FR fabrics are inherently flame resistant, solution-dyed, and available in multiple weights. The Wickzz Moisture Management System is designed to move moisture away from the skin and disperse it across the fabric to support evaporation and drying.[9][11]

GlenGuard also reports testing its fabrics for arc exposure, flash fire, industrial laundering, incidental chemical contact, and UV fade resistance.

This information provides a technical basis for comparing qualified fabric options. It does not replace evaluation of the finished garment.

A specification sheet cannot show whether a shirt binds during climbing, how the system performs with required outerwear, or whether workers begin adjusting the garment as heat and moisture build. Those questions must be tested under actual working conditions.

A GlenGuard wear trial allows employers to evaluate garments made with GlenGuard fabric during representative tasks, environmental conditions, layering arrangements, and laundering processes.[11]

Before renewing the same FR specification, identify where employees adjust, substitute, or struggle with the current clothing. Then use a GlenGuard wear trial to determine whether a different qualified fabric and garment combination can better support correct wear in the field.

Conclusion: Protection Depends on What Remains Worn

The hazard assessment establishes the level of protection employees need. The effectiveness of the clothing program then depends on whether that protection remains properly fitted, available, maintained, and correctly worn under the conditions employees actually face.

Repeated workarounds should not be treated only as enforcement problems. They can reveal where the approved clothing system is losing performance. Correcting the immediate behavior matters, but a lasting solution requires safety teams to understand what is driving it.

A strong FR clothing decision must answer two questions:

  1. Does the clothing provide the required protection?
  2. Can the complete system support correct wear throughout the work?

The first establishes technical qualification. The second determines whether that protection is likely to remain intact at the point of exposure.

The main takeaway is simple: compliance does not end when a qualified garment is selected or issued. It depends on choosing a complete clothing system that workers can wear correctly, consistently, and as intended in the field.

References

  1. Occupational Safety and Health Administration. 29 CFR 1910.132, General Requirements.
  2. Occupational Safety and Health Administration. Appendix B to Subpart I of Part 1910, Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.
  3. Occupational Safety and Health Administration. 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution.
  4. Occupational Safety and Health Administration. Personal Protective Equipment in Construction Final Rule. Published December 12, 2024. Effective January 13, 2025.
  5. National Institute for Occupational Safety and Health. Heat Stress and Workers.
  6. National Institute for Occupational Safety and Health. PPE Heat Burden.
  7. National Institute for Occupational Safety and Health. Workplace Recommendations for Heat Stress.
  8. Santos, Weiner, Alejandro Lorente, Carmen Rojas, Gonzalo Mariscal, and Rafael Lorente. “Impact of Personal Protective Equipment in Preventing Occupational Injuries: A Systematic Review and Meta-Analysis.” Frontiers in Public Health. December 5, 2025.
  9. GlenGuard. Arc-Rated Flame-Resistant Fabrics.
  10. GlenGuard. Product Testing.
  11. GlenGuard. Request a Wear Trial.
  12. National Safety Council. Work Injury Costs. 2024 data.
  13. Occupational Safety and Health Administration. $afety Pays: Background of Cost Estimates.