Wearables in OSH

Types of wearables and preventative applications

Exposure wearables measure physical and chemical agents in the environment directly on the wearer: noise dosimeters, personal gas and oxygen detectors, temperature and humidity sensors for heat stress, radiation dosimeters, and accelerometers for vibrations. Their advantage over ambient measurements is that they record each person’s actual exposure throughout the day and allow for immediate alerts when thresholds are exceeded, although they do not replace the standardized measurements required by specific regulations for exposure assessment.

Safety and location wearables include proximity tags and beacons that alert workers and drivers when someone approaches a vehicle or machine; dead man’s switch and fall detection devices for solo work, with automatic notification to a control center; and indoor location systems for emergencies, confined spaces, and evacuations. Ergonomic and physiological wearables record postures, movements, exertion, and, in some cases, heart rate or body temperature for analyzing physical workload, fatigue, and heat stress. Active or passive exoskeletons assist users in handling tasks or working with their arms raised and can integrate sensors.

Smart personal protective equipment integrates sensors into helmets, vests, footwear, or gloves to verify use, detect impacts or exposures, and communicate alerts. When the device serves a protective function, it must comply with Regulation (EU) 2016/425, and the electronic integration cannot reduce its protective performance.

Benefits, limitations and risks

• Real-time detection. Immediate alerts for exposures or risk situations that periodic measurements do not detect.
• Individual exposure. Data on each person’s actual exposure, useful for adapting tasks, breaks, and rotations.
• Vulnerable groups. Support for single workers, newly hired workers, older workers, or workers with disabilities.
• Data for prevention. Aggregated indicators to review risk assessment and prioritize measures.
• Accuracy and reliability. Consumption sensors do not always achieve the accuracy of standardized measuring equipment; the data must be validated and do not replace measurements required by regulations.
• Privacy and surveillance. The continuous collection of personal data, especially physiological and location data, generates risks of surveillance, misuse of data, and loss of trust.
• Psychosocial risks. The feeling of control, pressure to perform, and dependence on alerts can generate stress and reduce attention to risk.
• Device ergonomics. Weight, grip, battery life, compatibility with protective equipment, and comfort all influence actual use.
• Safety and maintenance. Calibration, batteries, upgrades, cybersecurity, and replacement.

Legal and governance requirements

• Risk assessment and consultation. The introduction of wearables is a new technology that requires consultation with worker safety representatives and a review of the assessment, including psychosocial risks.
• Data protection. Defined preventive purpose, legal basis, minimization, limited retention, information to individuals, impact assessment when there is systematic monitoring or processing of health data on a large scale, and separation of physiological data, which are considered health data and remain under the confidentiality of healthcare personnel.
• Digital rights. Article 20 bis of the Workers’ Statute and articles 87 to 91 of Organic Law 3/2018 on privacy in relation to digital devices, geolocation and video surveillance.
• Artificial intelligence regulations. Artificial intelligence systems intended to monitor and evaluate workers are high-risk, with obligations regarding risk management, human supervision, and transparency; emotion recognition in the workplace is prohibited except for medical or safety reasons.
• Personal protective equipment. Compliance with Regulation (EU) 2016/425 when the wearable is part of protective equipment.
• Voluntariness and non-discrimination. Use linked to the preventive purpose, without disciplinary or performance evaluation consequences, and with alternatives for those who cannot use them.
• Participation. Design, testing and evaluation with users and their representatives, as recommended by EU-OSHA.

Organizational application: how to implement wearables successfully

1. Define the specific preventive purpose (exposure, proximity, working alone, ergonomics) based on the risk assessment and verify that the previous technical and organizational measures are implemented.
2. Consult the project with the worker safety representatives and carry out the data protection analysis: purpose, minimization, retention, impact assessment, separation of health data and, if applicable, analysis in accordance with Regulation (EU) 2024/1689.
3. Select devices with validated accuracy, suitable ergonomics, compatibility with protective equipment and compliance with Regulation (EU) 2016/425 when they are part of protective equipment.
4. Conduct a pilot test with users, measure reliability, false positives and acceptance, and adjust thresholds, alerts and response procedures.
5. Clearly inform staff about what is measured, for what purpose, who has access and for how long the data is kept, and ensure the absence of disciplinary or performance evaluation use.
6. Integrate alerts and aggregated data into the preventive management system, with alert response, assessment review, and protocols for solo work and emergencies.
7. Maintain the devices (calibration, batteries, updates, cybersecurity) and periodically review the effectiveness, psychosocial effects and regulatory compliance.

Preventive management software allows the integration of alerts and aggregated data from wearables with risk assessment, exposed positions and people, management of resulting actions and solo work protocols, and maintenance of traceability, with separation of health data and recording of information and consultations carried out.

Limits and common mistakes

1. Replacing standardized exposure measurements with unvalidated consumption sensor data.
2. Implementing wearables without consulting representatives, without data protection analysis, or providing clear information to staff.
3. Treating physiological data outside of health confidentiality or using it to evaluate performance.
4. Relying on alerts without a response procedure or human supervision, especially in solo work.
5. Ignoring the ergonomics of the device and its compatibility with protective equipment leads to it not being used.
6. Failure to maintain or calibrate devices or review the psychosocial effects of continuous monitoring.

Specific data protection, artificial intelligence and protective equipment requirements must be analyzed on a case-by-case basis; this sheet is for informational purposes only.

Regulatory and reference framework

• Law 31/1995, of November 8. Law on the Prevention of Occupational Risks; risk assessment and consultation regarding new technologies.
• Regulation (EU) 2016/679 . General Data Protection Regulation; health data, impact assessment and processing principles.
• Organic Law 3/2018, of December 5. Protection of Personal Data and guarantee of digital rights; digital rights in the workplace.
• Regulation (EU) 2024/1689 . Artificial Intelligence Regulation; high-risk systems and prohibited practices in the workplace.
• Regulation (EU) 2016/425 . Personal protective equipment; conformity of smart equipment with protective function.
• EU-OSHA. Smart digital monitoring systems for occupational safety and health: uses and challenges (2022) . Report on uses, opportunities and challenges of smart monitoring systems, including wearables.
• EU-OSHA. Digitalization of work . Thematic portal on intelligent safety and health monitoring systems.

Royal Decree 773/1997 regulates the use of personal protective equipment in the company, and the specific standards for noise, vibrations, chemical agents and thermal stress establish the standardized measurement methods that wearables complement.