The need for PPE: Have you performed a workplace hazard assessment?

Machine guards, automated equipment, operating procedures, and other efforts make jobs safer, but they don’t always protect employees from all hazards in the workplace. Employees must wear appropriate personal protective equipment (PPE) when engineering and administrative controls can’t completely keep them out of harm’s way. PPE includes hard hats, gloves, high visibility vests, respiratory protection, safety boots, hearing protection, and other similar items. 

Top industries cited in FY 2023

OSHA’s PPE requirements generally apply to all employers who have employees exposed to the hazard, necessitating the need for the protection. In fiscal year (FY) 2023, the industries cited most often under 1910.132, General requirements for PPE, were:

1. Manufacturers of metal, machinery, computers, electrical equipment, transportation equipment, furniture, and medical equipment and supplies;
2. Manufacturers of wood and paper products, petroleum and coal products, chemicals, and plastics and rubber products;
3. Administrative and support and waste management and remediation services;
4. Accommodation and food services; and
5. Wholesale trade, which includes merchant wholesalers of durable and nondurable goods.

Note: There are additional regulatory requirements for various types of specific PPE, such as respiratory, hearing, face, head, and foot protection. These are found in 1910.132 - .140.

Workplace hazard assessment

The first step in determining whether employees need to wear PPE is to perform a workplace hazard assessment, as required at 1910.132(d)(2): “The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE.” Failure to conduct a hazard assessment was the top PPE violation in FY 2023.

Employers should conduct a detailed assessment of the facility to identify hazards such as:

• The risk for falling or dropping objects;
• Sources of machine motions;
• Sharp objects that could poke, cut, stab, or puncture;
• Sources of temperature extremes that could result in burns;
• Sources of light radiation, such as welding, cutting, furnaces, etc.;
• Flying sparks or particles, or harmful dusts;
• Harmful chemicals being used;
• Bloodborne pathogens or other biological hazards encountered during cleaning; or
• Sources of electricity.

Once this is completed, the employer must then verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

If it’s determined there’s a need for employees to wear PPE, the next step is to evaluate available PPE options and select equipment that will be effective for the job’s tasks, conditions present, duration of use, and the hazards identified. PPE must properly fit each employee and selection decisions must be communicated to affected employees.