PunchDonning and Doffing: Is Time Spent Putting On Gear, Uniforms, and PPE Paid Time? (2026)
Donning and Doffing: Is Time Spent Putting On Gear, Uniforms, and PPE Paid Time? (2026)
The short answer: Often, yes. Under the Fair Labor Standards Act, time spent putting on and taking off gear is paid work when the gear is required by the employer or the job and cannot reasonably be put on at home. Once that first task begins, the workday has begun, and the walking and waiting that follow are usually paid too. The one real exception is narrow and depends on a union contract. For a small crew, the safe answer is to start the punch when the gear goes on.
Field crews wear things. Hard hats, harnesses, chainsaw chaps, respirators, rubber boots, hi-vis vests, tool belts, sealed coveralls. Someone has to put that gear on before the first task and take it off after the last one. If that time never reaches the timesheet, it is off the clock. This guide explains where the line sits and how to record it cleanly.
What Donning and Doffing Means
Donning is putting gear on. Doffing is taking it off. The terms come from wage-and-hour law, and the question they raise is simple: is that time hours worked?
The FLSA counts as work any activity that is "integral and indispensable" to the job you were hired to do. The Supreme Court used that phrase in Steiner v. Mitchell in 1956. In that case, workers at a battery plant had to change clothes and shower because of toxic materials. The Court held that the time was work, because the job could not be done safely without it.
The test is not whether the activity is pleasant or brief. It is whether the employer or the nature of the work requires it, and whether it is tied to the job itself. A uniform you choose to wear from home is not work. A respirator you must fit and seal at the site is.
The Continuous Workday Rule
Here is the part that catches small employers. In IBP, Inc. v. Alvarez in 2005, the Supreme Court confirmed that the workday starts with the first principal activity and ends with the last. Time between those two points is generally paid.
That means if donning required gear is a principal activity, the clock runs from there. The walk from the gear room to the work area is paid. Waiting for a truck to be loaded after you have suited up is paid. So is the walk back at the end, and the time spent taking gear off.
Time before that first activity, such as the ordinary commute, is not paid under the Portal-to-Portal Act. The line is the first principal activity, not the front door. The practical result for a crew: if the day begins with gearing up at the shop, the punch belongs at the shop.
The Exception, and Why It Is Narrow
Section 3(o) of the FLSA lets a collective bargaining agreement, or a custom or practice under one, exclude time spent changing clothes or washing at the start or end of the day. That is the exception employers cite.
It is narrower than it sounds. It applies to changing clothes and washing, and only under a union agreement. The Department of Labor's Administrator's Interpretation No. 2010-2 takes the position that "clothes" in that section does not include protective equipment such as hard hats, safety glasses, respirators, and similar gear. On that reading, the time spent putting on PPE stays compensable even where a union contract covers clothes.
Most small crews have no collective bargaining agreement at all. Without one, the exception does not apply, and gear time that is required and integral is simply work time.
A Quick Test for Your Crew
Ask three questions about any gear-up step.
Does the employer or the job require it? Safety rules, OSHA standards, client requirements, and company policy all count.
Can it reasonably be done at home? A plain uniform you can wear to the site often can. A harness that lives in the truck or a suit that must stay on site usually cannot.
Is it tied to the work? If the day cannot start without it, it is integral.
If the answers are yes, no, and yes, the time is paid. When the answers are unclear, treat the time as paid. The cost of paying eight minutes a day is small. The cost of an unpaid-gear claim is not. Back pay reaches two years, three if the violation is willful, and it can be doubled as liquidated damages. We cover that exposure in our guide to off-the-clock work.
Gear time also counts toward overtime. Eight unrecorded minutes a day is over half an hour a week that never reached the 40-hour count. See what counts as hours worked for the full standard.
How to Record Gear Time So It Is Never Off the Clock
Policy does not fix this. A handbook line that says "record all time" does not help when the crew suits up in a parking lot at 6:50 and the punch happens at 7:00. The fix is a system where punching first is the easy path.
Punch is built for that. It gives a crew a few things that make gear time visible.
Punch in at the job site. Punch in is geofenced to the job site, so the record shows the crew arrived and started there, not somewhere down the road. There is no camera and no photo at the punch. The check is a boundary around the site, which keeps the crew's faces out of it.
Punch in when the gear goes on. Set the crew rule once: the punch is the first thing. Because Punch works offline, a lot with no signal is not an excuse to wait.
One shared iPad at the shop. For crews that gear up at a central yard, kiosk mode with a PIN turns one iPad into the punch station. The crew punches at the door, then suits up.
Fix gaps with a manager approval. If someone forgot, a manager can add the shift and approve it. Bulk approve and reject make the weekly review fast.
Reports for the audit. Owner and manager reports export to QuickBooks or Excel, so the hours that reach payroll match the hours that were worked, gear time included.
Every plan includes every feature. Pricing is flat per organization, and owners are always free, so adding the whole crew does not raise the bill per head.
Put the Punch Where the Work Starts
Gear time is a small number on any single day. Over a season, across a crew, it is one of the most common ways real work goes unpaid. The law is settled enough to plan around: if the gear is required and the work cannot start without it, the workday has started.
Set the punch at the moment the gear goes on. Let the record prove it.
Start with Punch and give your crew a punch that starts where the work does.