Have you performed your PPE hazard assessment?

Machine guarding, exhaust ventilation, and other measures make jobs safer, but they don’t always fully protect your employees from hazards. When engineering and administrative controls aren’t feasible or can’t completely keep employees out of harm’s way, you must examine if personal protective equipment (PPE) can help close the gap. If so, PPE is mandatory in general industry.

PPE hazard assessment provision

No matter the operation and the controls you put in place, OSHA’s General PPE standard at 29 CFR 1910.132 requires you to assess the workplace to determine if hazards are present, or are likely to be present, that require your employees to use PPE. This includes eye, face, head, foot, hand, and personal fall protection. The assessment provision is found at paragraph (d) of the standard.

Note that this paragraph does not apply to respiratory protection or to electrical protective equipment. Employers should reference 1910.134 and 1910.137, respectively, for requirements specific to selection of that equipment and abatement of respiratory and electrical hazards.

What to look for

When performing a hazard assessment, the question may be, “Where do you start?” As a first step, consider reviewing injury and illness records, incident investigation records, exposure monitoring results, and industrial hygiene assessments. These should help you determine where hazards exist.

Next, conduct a walk-through survey of your facility and look for hazards such as:

• Sources of falling objects or potential for dropping objects;
• Sources of motion;
• Sharp objects that could poke, cut, stab, or puncture;
• Sources of extreme heat or cold;
• Sources of light radiation, such as welding, cutting, and furnaces;
• Flying sparks or particles;
• Harmful dusts;
• Chemical exposures; or
• Sources of bloodborne pathogens or other biological agents.

Following the walk-through survey, prepare an analysis of the hazards to help you select the appropriate PPE. This should include an estimate of the potential for injuries. Determine the type, level of risk, and seriousness of potential injury from each hazard found in the area. It’s also important to consider the possibility of exposure to several hazards at once.

Select PPE for the hazards identified

Your second step is to evaluate your PPE options and select equipment that will be effective for the job’s tasks, conditions present, duration of use, and the hazards identified. The PPE selected must properly fit each affected employee. With a few exceptions, you must also pay for required PPE.

Communicate your PPE selection decisions

Third, paragraph 1910.132(d) also requires you to communicate selection decisions to each affected employee. This ensures the employees are aware that the PPE selected will protect them from the hazards the assessment identified.

Certify the hazard assessment in writing

You must certify in writing that a workplace hazard assessment has been completed. This is your fourth step. The assessment verification must:

• Identify the workplace evaluated,
• Identify the person certifying that the evaluation was performed,
• List the date of the assessment, and
• Contain a statement which identifies the document as certification of hazard assessment.

Reassess hazards in the workplace

Be sure to 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.

As an employer, you determine the frequency for PPE hazard reassessments. OSHA estimates that employers will need to conduct these, on average, once every five years. While reassessment is not specifically called out as a fifth step in 1910.132(d), it is an understood requirement when new hazards pop up or hazards change.  

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