OSHA requires a written PPE hazard assessment certification

Every employer must certify in writing that a workplace hazard assessment has been completed as required in 1910.132(d)(2). That certification must:

• Identify the workplace evaluated,
• Identify the person certifying that the evaluation was performed, and
• List the date of the assessment.

Since the hazard assessment provision appears in the general requirements for personal protective equipment (PPE), the employer will need to determine if PPE is necessary. Upon completing the assessment, however, employers should first consider engineering controls and work practice controls to reduce or eliminate any hazards identified. Mandatory PPE use should be the last line of defense.

Note that this hazard assessment provision does not apply to respiratory protection or to electrical protective equipment, but employers should evaluate those hazards as well.

Research and walkthrough

The first step is to collect and review information about hazards and potential hazards. The safety person should collect, organize, and review information such as:

• Reports from insurance carriers, OSHA, and consultants.
• Records of injuries and illnesses, and incident investigations.
• Exposure monitoring results and industrial hygiene assessments.
• Input from workers.

Some things to look for during the walkthrough include:

• Chemicals used.
• Sources of light radiation, such as welding.
• The potential for falling or dropping objects.
• Sharp objects that could poke, cut, stab or puncture.

After the walkthrough, analyze the data to determine the type of hazards, level of risk, and seriousness of potential injuries. Also, consider the possibility of exposure to several hazards simultaneously. If the hazards cannot be sufficiently mitigated through engineering or work practice controls, identify appropriate PPE.

Periodically reassess the workplace for changes in conditions, equipment, or operating procedures that could impact the hazard evaluation. This reassessment should include a review of injury and illness records to spot any trends or areas of concern, as well as a review of the PPE used (including an evaluation of its condition and age). If new hazards are identified, or previously identified exposures have changed, take appropriate corrective action.