Personal Protective Equipment (PPE): OSHA Requirements and Employer Obligations | SafetyRegulatory.com — Workplace Safety Certifications, Training & Careers

PPE is last in the hierarchy of controls. That’s not a suggestion. It’s the structure of how OSHA expects you to approach hazard control, and most employers have it backwards.

Elimination, substitution, engineering controls, and administrative controls all come before PPE. You try to remove the hazard first. If you can’t, you change the process. If you can’t do that, you engineer a barrier. Administrative controls come next, things like job rotation and warning systems. PPE is what you use when everything else has been tried and residual hazard remains.

In practice, PPE often gets handed out instead of fixing the actual problem. Gloves for chemical exposure when switching to a less hazardous product would eliminate the hazard. Hard hats for struck-by risk when a different work sequence would remove workers from the drop zone. The PPE isn’t wrong in those cases, but stopping at PPE without asking what’s above it in the hierarchy is where programs fail, and where injuries happen.

The Standards That Apply

OSHA’s general industry PPE requirements live in 29 CFR 1910 Subpart I. The core rule is 1910.132, which sets the general requirements for PPE including the hazard assessment obligation and employer payment requirements. The body part-specific standards hang off of that:

1910.133 covers eye and face protection. 1910.135 covers head protection. 1910.136 covers foot protection. 1910.138 covers hand protection. Respiratory protection is in 1910.134, which has its own written program requirements and is complex enough to warrant its own treatment. See the respiratory protection guide for that standard.

Construction PPE standards are in 29 CFR 1926 Subpart E, but they reference back to the general industry standards for most of the technical requirements.

The OSHA 30 General Industry certification covers all of Subpart I in depth if you want a more structured review.

The Hazard Assessment: The Document You Actually Need

Before you can know what PPE to require, you have to know what hazards are present. OSHA 1910.132(d) requires a workplace hazard assessment, and it’s not optional.

The assessment has to be written. It has to identify the hazards by job location or task category. It has to document what PPE was selected to address each hazard. And it has to be certified, meaning it needs the name of the person who performed the assessment, the job locations covered, and the date.

A blanket “hard hats and safety glasses required on all jobsites” policy isn’t an assessment. It’s a policy. The assessment is the analysis that supports the policy, and it needs to be specific enough that a reviewer could trace the connection from the hazard to the selected PPE.

For practical guidance on hazard identification, the job hazard analysis guide covers how to document hazards at the task level.

Walk each work area. List the potential hazards: falling objects, flying particles, chemical splash, electrical contact, laceration risk, foot impact. Then ask what PPE is needed to control the residual risk after engineering controls are in place. Document your answers. Date it and sign it.

That document is what protects you when an OSHA inspector asks why workers aren’t wearing a particular piece of equipment, or why they are wearing one type and not another.

Head Protection: More Than Just Hard Hats

Head protection under 1910.135 is required when workers are exposed to head injury from falling objects, bumps, or electrical hazards. The standard references ANSI Z89.1.

ANSI Z89.1 classifies hard hats by electrical rating. Class E (electrical) hard hats are rated for up to 20,000 volts and are the standard choice for most construction and industrial settings. Class G (general) hats are rated for 2,200 volts. Class C (conductive) hats provide no electrical protection and should only be used where electrical hazard has been specifically ruled out.

Bump caps are not ANSI Z89.1 rated. They offer minimal impact protection against minor scrapes from low-clearance overhead obstacles. They don’t meet the OSHA head protection standard. If you see bump caps on a site where falling objects are a hazard, that’s a citation.

A newer category worth knowing: safety helmets with integrated face shields and chin straps are replacing traditional hard hats on many sites. They meet or exceed ANSI Z89.1 requirements and add protection for falls, where a traditional hard hat often flies off. Some owner requirements now specify helmets rather than hard hats for elevated work.

Never paint a hard hat. Solvents in paint can degrade the shell material and compromise impact resistance. Check for cracks and discoloration regularly. Replace any hard hat that has taken a significant impact, even if it looks undamaged. The structural deformation that absorbs the impact is one-time.

Eye and Face Protection

OSHA 1910.133 requires eye and face protection against flying particles, molten metal, liquid chemicals, light radiation, and similar hazards. The technical standard is ANSI Z87.1.

The right type of protection depends on the hazard. Safety glasses with side shields protect against flying debris and particles from grinding, cutting, or chipping. They don’t seal against splash. Goggles seal against the face and protect against chemical splash, fine dust, and some light radiation hazards. A face shield protects the full face but should be worn over safety glasses or goggles, not instead of them, because it doesn’t protect the eyes from all angles.

Look for the Z87 marking on every piece of eye protection. Z87+ indicates the lens meets high-impact requirements. For grinding and power tool work, Z87+ is the right specification.

Prescription eyeglass wearers need prescription safety glasses or safety glasses worn over their regular glasses (over-specs). Regular prescription glasses are not safety glasses and don’t comply with the standard.

Hand Protection

OSHA 1910.138 requires employers to select and provide hand protection based on hazard assessment. Unlike some other standards, OSHA doesn’t specify glove types for most applications. The obligation is on you to assess the hazard and provide appropriate protection.

For cut hazards, the ANSI/ISEA 105 standard rates gloves from A1 (minimum cut resistance) through A9 (maximum). An A1 glove won’t protect against a sharp blade. An A4 or A5 glove is appropriate for sheet metal handling or blade work. Know the cut level your hazard presents, then match the glove rating to it.

For chemical hazards, cut resistance is irrelevant. You need to select gloves based on the specific chemical and permeation data from the manufacturer. A glove rated for petroleum solvents won’t protect against strong acids. Reference the Safety Data Sheet for each chemical and match it to manufacturer compatibility charts.

For electrical work, insulating rubber gloves are rated by voltage class (00, 0, 1, 2, 3, 4) and must be tested regularly. They’re also worn over leather protector gloves. This is a more complex area covered under the electrical protective equipment standard.

The one thing OSHA is consistent about: you must assess the hazard first, then select the glove. Handing out general-purpose cotton work gloves for every task isn’t a program. It’s a placeholder.

Foot Protection

Foot protection under 1910.136 is required where there’s a danger of foot injury from falling objects, rolling objects, or penetrating objects, as well as where workers are exposed to electrical hazards.

The governing standard for foot protection is ASTM F2413. Safety-toe footwear is marked with F2413 plus the protection level. Steel toes are the traditional choice. Composite toes (carbon fiber, fiberglass, or plastic composites) are lighter and won’t conduct cold the way steel does, which matters for outdoor work in winter. Both are tested to the same impact and compression requirements under ASTM F2413.

Electrical hazard (EH) rating is separate from toe protection. EH-rated footwear has soles that provide secondary protection against open circuits up to 600 volts. It’s not designed for high-voltage work, but it provides a secondary barrier for electricians and workers in electrical environments.

Puncture resistance is a separate rating under ASTM F2413. For roofing, demolition, or work around exposed fasteners, require PR-rated footwear.

Who Pays for PPE

OSHA 1910.132(h) is clear: the employer pays for PPE required under OSHA standards. The main exceptions are non-specialty safety-toe footwear and non-specialty prescription safety glasses, where the employer may require employees to provide their own if the employer permits wearing them off the job.

Logging boots and metatarsal guards are employer-paid. Hard hats are employer-paid. Gloves are employer-paid. High-visibility vests are employer-paid.

If you’re requiring it for the job, you’re paying for it. Don’t make the mistake of building a program around employee-provided PPE without confirming the legal basis.

Training Requirements

Buying the right PPE isn’t enough. OSHA 1910.132(f) requires training for each employee required to use PPE. The training has to cover when PPE is needed, what PPE is needed, how to properly put on, take off, adjust, and wear it, the limitations of the PPE, and the proper care, maintenance, useful life, and disposal of PPE.

Training has to be verified in writing. Keep records. If someone is retrained, document the retraining and the reason.

This is an area where companies cut corners and then get surprised. A worker who doesn’t know how to properly don a half-face respirator, a worker who wears a hard hat backwards, a worker who uses the wrong glove for a chemical because no one told them, those are training failures, and they’re cited under 1910.132(f), not just under the equipment-specific standard.

Common Mistakes That Lead to Citations

Modified PPE is one of the most common. Drilling ventilation holes in a hard hat seems harmless but it compromises the structural shell. Painting a hard hat can degrade the resin. Cutting straps on a respirator for comfort defeats the seal. OSHA requires PPE to be maintained in a sanitary and reliable condition. Modified equipment isn’t reliable.

Expired PPE still in use is another one. Hard hats have manufacturer-recommended replacement schedules, typically five to ten years from the manufacture date stamped on the inside of the shell, and two to five years from first use. Chemical-resistant gloves degrade over time even if they look fine. Check dates.

Using PPE as the only control is a broader failure. If the process creates a hazard that engineering could eliminate and your response is just to add PPE, you’re leaving risk on the table and potentially failing to meet the hierarchy of controls. OSHA inspectors know the hierarchy. If you can’t explain why engineering controls weren’t feasible, that question gets harder to answer.

Start With the Assessment

PPE selection, training, and payment obligations all flow from the hazard assessment. If the assessment is solid, specific, and current, the rest of the program has a foundation.

If an OSHA inspector walks in and asks why workers in a particular area aren’t wearing chemical splash goggles, the answer is in the assessment: the chemicals present were evaluated, the splash risk was assessed, and this PPE selection was the documented outcome. Without the assessment, you’re explaining a decision that was never documented, and that’s a much harder position to defend.

Do the assessment first. Everything else follows from it.

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