Don’t Have Any Doubts About PPE Requirements

Does OSHA specify the frequency of replacement of PPE, especially hard hats?

OSHA does not specify the frequency of replacement of PPE. It is up to the employer to determine when PPE needs to be replaced. OSHA recommends that each employer establish a policy concerning what will constitute normal wear and tear (expected service life).

It is recommended that hard hats be replaced after 2 years when they are worn in work environments that include sunlight, chemicals, or temperature extremes. Most manufacturers mold date codes or symbols into the underside of the brim of a hard hat to indicate when it was made. Learn how to interpret the code or symbol or check with your supplier for recommended expiration dates.

Does a PPE hazard assessment need to be documented per 1910.132?

Yes, you the employer must certify in writing that the PPE hazard assessment has been performed. The written certification must identify:

• The workplace evaluated
• The date of the assessment
• The person certifying that the evaluation has been performed
• The hazards found
• The PPE selected

See Subpart I, Appendix B for more information about hazard assessments.

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If employees lose their PPE and need it to be replaced, does that come at our expense or theirs?

The employee must pay to replace lost PPE:

1910.132(h)(5). Employers must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.

Are there any exceptions to OSHA’s requirement that employers pay for PPE?

Yes. You do not have to pay for:

• Modifications that simply personalize PPE do not require employer payment (for example, shoe inserts for fatigue). If modifications are needed for proper fit or appropriate protection, the employer must pay. (For example, prescription inserts that employees need for protection.)
• If metatarsal protection is needed per the hazard assessment, integrated metatarsal shoes are not required to be paid for. An employer can pay for external guard attachments. They do not work as well as integrated ones, but OSHA standards allow them.
• “Everyday" clothing that might also serve as PPE, such as long-sleeve shirts and pants, rain gear, and winter clothing, is not something employers have to pay for. An employer may require everyday clothing to be worn that may have some protective value, but may not have to pay for it if it must be worn regardless of the hazards. However, if everyday clothing is not sufficient to protect employees, then the employer must pay for PPE (for example, PPE for working in freezers).

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