What the standard requires
29 CFR 1910.132 — the general PPE standard — requires employers to assess the workplace for hazards that necessitate PPE, select appropriate PPE, provide training, and pay for most PPE. Companion standards cover specific body parts:
- 1910.133 — eye and face protection.
- 1910.135 — head protection.
- 1910.136 — foot protection.
- 1910.138 — hand protection.
- 1910.140 — personal fall protection systems.
The written hazard assessment
The foundation of PPE compliance is a written certification of hazard assessment — required by 1910.132(d)(2). The certification must identify the workplace evaluated, the person certifying the evaluation, the date of the hazard assessment, and identify the document as a certification of hazard assessment.
A typical assessment walks each area of the workplace, identifies impact, penetration, compression, chemical, heat, harmful dust, light radiation, and biological hazards, and documents the PPE selected to address each. It is not a generic form filled out once and never revisited. Update whenever equipment, processes, or chemicals change.
Employer duties
- Perform and certify a written hazard assessment.
- Select appropriate PPE — properly fitted, meeting ANSI/other consensus standards.
- Communicate PPE selection decisions to affected employees.
- Provide training and require employees to demonstrate understanding.
- Retrain when there's a change in the workplace, PPE, or evidence the employee doesn't retain the training.
- Maintain PPE in a reliable, sanitary, and safe condition.
- Pay for PPE, with limited exceptions.
Who pays for PPE
Since 2008, employers must pay for most PPE required to comply with an OSHA standard. Narrow exceptions employers may require the employee to provide or pay for:
- Non-specialty safety-toe protective footwear (steel-toe boots).
- Non-specialty prescription safety eyewear.
- Everyday clothing (long-sleeve shirts, long pants, street shoes, sunglasses).
- Ordinary clothing worn for weather protection.
- PPE the employee has lost or intentionally damaged (may be charged back).
- PPE the employee brings from a previous job (voluntary — cannot be required).
When an employer permits employees to use their own PPE, the employer remains responsible for ensuring its adequacy.
Training requirements
Each employee required to use PPE must be trained on:
- When PPE is necessary.
- What PPE is necessary.
- How to properly don, doff, adjust, and wear PPE.
- Limitations of the PPE.
- Proper care, maintenance, useful life, and disposal.
Training must be certified in writing — employee name, dates of training, and subject matter. Retraining is required when workplace changes render prior training obsolete or when the employee shows inadequate knowledge or use.
Common citations
- 1910.132(d)(1) — no hazard assessment performed.
- 1910.132(d)(2) — no written certification of hazard assessment.
- 1910.132(f)(1) — inadequate employee training.
- 1910.133(a)(1) — no eye/face protection where hazards present.
- 1910.138(a) — no hand protection where hazards present.
Documentation checklist
- Written certification of hazard assessment (per work area).
- PPE selection rationale linked to the hazard assessment.
- Training records with employee names, dates, and subjects.
- Retraining records tied to workplace or PPE changes.
- Receipts or purchase records demonstrating employer payment.
- PPE inspection and replacement logs where applicable.
Common mistakes we see
- No written hazard assessment. The most common PPE citation by far.
- Making employees pay for required PPE. Even a $5 pair of safety glasses required for their task.
- PPE that meets the wrong standard. Impact-rated eyewear is Z87+, not just Z87. Cut-resistant gloves have ANSI cut levels A1–A9 — pick for the actual hazard.
- Signing off training without demonstrating understanding. OSHA requires the employee demonstrate understanding, not just attendance.
How CSPC helps
Our Baseline Blueprint assessment includes a walk-through PPE hazard assessment with a signed certification you can put on file. We also deliver PPE training that satisfies 1910.132(f) documentation requirements.