You must provide your employees with personal protective equipment (PPE) when other methods higher in industrial hygiene’s “hierarchy of controls” like elimination, substitution, engineering controls, and administrative controls are not enough to protect their health and safety.
PPE protects workers’ eyes, faces, feet, hands, and heads, and protective clothing may protect the entire body from chemical or electrical hazards. Respirators protect workers from dust, gases, particles, and infectious diseases, and you can protect workers at your facility from falls from heights with personal fall arrest systems.
Many Occupational Safety and Health Administration (OSHA) standards require that employers provide protective equipment, including chemical protective clothing or equipment, face shields, fall protection equipment, gloves, goggles, hard hats, safety glasses, safety shoes or boots, and welding goggles and helmets.
OSHA’s enforcement guidance for PPE (CPL 02-01-050) outlines the agency’s interpretations of the general industry PPE standards (29 Code of Federal Regulations (CFR) Part 1910, Subpart I) and its procedures for enforcing them. The enforcement guidance clarifies what type of PPE employees must be provided at no cost, when employers must pay for PPE or replacement PPE, and when employers are not required to pay for PPE.
There are a few exceptions to OSHA’s requirement for employer payment for PPE—back belts, everyday clothing, nonspecialty footwear worn off the jobsite, ordinary cold weather or rain gear, and ordinary prescription eyewear.
Under OSHA regulations, you must pay for PPE required by OSHA standards. During an inspection, agency compliance safety and health officers (CSHOs) will determine employee-employer relationships at a facility or worksite, establishing who must pay for workers’ PPE.
Hazards, PPE selection
OSHA’s general requirements for PPE include assessing workplace hazards and selecting appropriate equipment, employer payment for PPE, training, and preventing the use of damaged or defective PPE.
You also must assess hazards that are present or likely to be present in the workplace. OSHA regulations require a written assessment verifying the hazard assessment, identifying the person performing the assessment, and the assessment date. Additionally, you must select appropriate PPE and communicate your selection decisions to your employees.
During an inspection, agency CSHOs will determine whether you have assessed all workplace hazards and selected appropriate PPE.
Your PPE training must cover:
- When and what PPE is necessary on the job;
- How to don, doff, adjust, and wear PPE;
- The limitations of PPE used; and
- The proper care, maintenance, useful life, and disposal of PPE.
You also need to ensure your employees understand their training and retrain if necessary, such as when there are changes in workplace conditions or the types of PPE used. An agency CSHO will assess the effectiveness of the training you provide during an inspection.
Eye and face protection
According to OSHA, thousands of workers are blinded each year from work-related eye injuries. Eye injuries can result from small objects or particles such as cement chips, dust, metal slivers, and wood chips scraping or striking the eye and chemical or thermal burns, and eye hazards include arc welding, chemicals, lasers, objects, and particles.
Proper selection and use of eye and face protection can prevent occupational eye injuries.
OSHA’s construction industry eye and face protection standard (29 CFR §1926.102) is the agency’s ninth most frequently cited standard. The agency cited 1,401 violations in fiscal year (FY) 2022. OSHA also has general industry (§1910.133), shipyard (§1915.153), and longshoring (§1918.101) standards for eye and face protection.
Eye protection must be maintained in good condition. If eye protection is reused, you must clean and disinfect it before issuing it for another employee’s use. If an employee wears prescription eyeglasses, the eye protection you provide must be a type that can be worn over glasses.
OSHA’s respiratory protection standard (§1910.134) is the agency’s third most frequently cited standard, cited 2,185 times in FY 2022. It requires a written respiratory protection program, medical evaluation for respirator use, initial and annual fit testing, respirator cleaning and disinfection, recordkeeping, and training.
Types of respirators include filtering facepiece respirators like N95s or P100s, elastomeric half-mask respirators, elastomeric full facepiece respirators, powered air-purifying respirators, supplied-air respirators, self-contained breathing apparatuses, and combination supplied-air/self-contained apparatuses.
An OSHA inspection for respiratory protection compliance will check whether your program addresses all the standard’s requirements, including respirator selection; equipment cleaning, maintenance, and repair; fit testing; and training.
Head protection includes hard hats or helmets to protect your employees from falling objects and helmets designed to reduce electrical shock for those working near exposed electrical conductors that could come into contact with the head.
Hard hats or helmets must meet the requirements of one of three industry standards: American National Standards Institute (ANSI) Z89.1-2009, “American National Standard for Industrial Head Protection”; ANSI Z89.1-2003, “American National Standard for Industrial Head Protection”; or ANSI Z89.1-1997, “American National Standard for Personnel Protection—Protective Headwear for Industrial Workers.”
ANSI Z89.1-1997 includes specifications for the electrical performance of Class G and Class E electrical helmets.
During an OSHA inspection, agency CSHOs will look for protective helmets that resist penetration by objects, absorb the shock of a blow, are water-resistant, and have slow-burning properties. They also will check that you are following the manufacturers’ instructions for proper adjustment and replacement of the helmet suspension and headband.
Wherever there is a danger of foot injuries from falling or rolling objects or objects piercing the sole, you must ensure your employees have and use protective footwear.
Footwear must meet the specifications of one of the following industry consensus standards:
- ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005,” Standard Specification for Performance Requirements for Protective Footwear”;
- ANSI Z41-1999, “American National Standard for Personal Protection—Protective Footwear”; or
- ANSI Z41-1991, “American National Standard for Personal Protection—Protective Footwear.”
During an OSHA inspection, a CSHO will first confirm that you have completed an assessment of foot injury hazards. If foot injury hazards are present in your facility, the CSHO will confirm that workers have footwear that meet the requirements of one of the industry consensus standards.
The CSHO may also check for the following:
- Metatarsal guards to protect the top of the foot;
- Toe guards;
- Combination foot and shin guards;
- Safety shoes or boots that protect against impact, compression, and puncture hazards or that have heat-resistant soles that protect against hot work surfaces;
- Electrically conductive shoes to protect against the buildup of static electricity;
- Electrical hazard, safety-toe shoes or boots; or
- Foundry shoes to insulate the feet from the extreme heat of molten metal.
Hazards requiring hand protection include skin absorption of harmful substances; chemical burns; harmful temperature extremes; punctures; severe abrasions, cuts, or lacerations; sharp objects; and thermal burns.
Moreover, you must provide employees with hand protection appropriate for the working conditions and hazards identified in your facility. An agency CSHO will check during an inspection that all affected workers have appropriate hand protection whenever hazards cannot be eliminated through engineering, work practice, or administrative controls.
You must provide hearing protection whenever workplace or worksite noise levels exceed permissible noise exposure levels (PELs) and feasible administrative or engineering controls cannot reduce the noise level to below the PEL. You can find a table of permissible noise exposures in §1910.95(b)(2).
Moreover, you must have an ongoing hearing conservation program that includes exposure monitoring; baseline and annual worker audiogram testing; hearing protectors, such as single-use earplugs, preformed or molded earplugs, and earmuffs; and training and recordkeeping programs.
Agency CSHOs will assess noise exposures and the effectiveness of all elements of your hearing conservation program and hearing protector use.
Electrical protective equipment
Electrical protective equipment includes rubber insulating blankets, rubber insulating covers, rubber insulating gloves, rubber insulating line hoses, rubber insulating matting, and rubber insulating sleeves.
During an OSHA inspection, the CSHO will check for the following:
- That insulating equipment has been inspected for damage before each day’s use and immediately following any incident that can reasonably be suspected of having caused damage;
- Whether protective equipment has been maintained in a safe, reliable condition and whether electrical protective equipment has been periodically tested;
- Whether employees’ clothing does not increase the extent of an injury when exposed to flames or electric arcs; and
- Whether safeguards, such as shields, barriers, or insulating material, are used to protect employees from shocks, burns, or other electrically related injuries.
OSHA’s construction industry fall protection standard is the agency’s most frequently cited standard. In FY 2022, OSHA cited 5,260 fall protection violations—more than double the number of violations (2,424) of its second most frequently cited standard (hazard communication).
Fatalities caused by falls from elevation remain a leading cause of death for construction workers, according to the Bureau of Labor Statistics (BLS). Falls from height are one of the construction industry’s “Fatal Four” safety hazards, along with caught-in or -between, electrocution, and struck-by hazards.
The construction fall protection standard requires guardrails, safety nets, or personal fall arrest systems. Safety net systems can be installed underneath trusses to prevent workers from falling to a lower level but also must prevent worker contact with a surface or structure in the event of a fall.
A personal fall arrest system consists of three components:
- An anchor that other parts are rigged to,
- A full-body harness worn by a worker, and
- A lanyard or lifeline connecting the worker’s harness to the anchorage point.
Workers also must be trained in the nature and hazards of falls and the use and limitations of fall protection equipment.
OSHA’s general industry fall protection also requires personal fall arrest systems composed of an anchor, a harness, and a lifeline to protect workers from falls from height. The general industry standard also contains fall protection requirements for linemen and window cleaners.
What you face during an OSHA inspection
If an OSHA inspector identifies workplace hazards not adequately controlled by administrative and engineering controls or work practices, the inspector will check that employees have been provided PPE.
Inspection guidelines include checking that:
- PPE is necessary to protect employees from hazards.
- Employee-owned equipment is adequate, properly maintained, and sanitary.
- PPE used is safe in design and construction.
- A hazard assessment has been performed, and PPE has been selected accordingly.
- Employees have received PPE training.
- PPE required by OSHA standards is provided at no cost to employees.