News & Information Blog

Simplified Personal Protective Equipment Compliance

By Susen Trail | 08/23/2018

In this article we'll present a simplified summary of Personal Protective Equipment (PPE) Compliance. We'll outline what is covered, what is not covered, what is and is not required of you, the employer.

Standard, 1910.132, addresses protective equipment, including personal protective equipment for:

  • Eyes, 1910.133
  • Face, 1910.133
  • Head, 1910.135
  • Extremities:
    • Feet, 1910.136
    • Hands, 1910.138
    • Body, personal fall protection, 1910.140
    • Respiratory system, 1910.134
  • Protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of:
    • Processes
    • Environment
    • Chemical hazards
    • Radiological hazards
    • Mechanical irritants
  • Where the above hazards are encountered in a manner capable of causing injury or impairment in the function of any part of the body through:
    • Absorption, [skin and/or respiratory tract]
    • Inhalation
    • Physical contact [including sharps or corrosives that damage skin]

What it does not cover:

  • Things you cannot wear, such as fume hoods (you?d be surprised what Compliance Officers find)
  • Hearing Protection, 1910.95
  • Safety vests for traffic flaggers and workers in traffic areas
    • This may seem counter-intuitive, but is illustrated with the following example:
      • If a hammer falls on your head while you are wearing a hard hat will your head be protected?
      • If a car hits you while your body are wearing a safety vest will your body be protected?

What you are required to do:

  • OSHA 1910.132 requires a written Certification of Hazard Assessment. This is the only paper or electronic document required by OSHA.
  • The Certification of Hazard Assessment is a very simple document, but must follow these basic rules:
    • Identified as the Certification of Hazard Assessment
    • Identify the workplace evaluated
    • Identify the person conducting the evaluation
    • Signed by that person and dated

What you are NOT required to do:

  • Develop or implement a written Personal Protective Equipment Program.

What you no longer have to do:

  • You are no longer required to have a written Certification of Training.

Although the written Certification of Training as proof that training has been completed is no longer required by OHSA, we still STRONGLY recommend tracking your employee training.

Consider, if you will, should you not document who has been trained on what, as well as the content of the training, how do you verify to an OSHA inspector, your insurance company, the government branch for Workforce Development investigator, that:

  • The specific employee was trained
  • The training included all of the PPE required for his specific exposures
  • The employee demonstrated knowledge and ability to use the PPE properly at the conclusion of the training
As an additional benefit, if you have a new employee or an employee transferring to a new position it's much easier to bring them up to speed if you can look at the training provided to the previous employee.

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