PPE Selection Guide
Personal Protective Equipment
Selecting, using, and managing PPE based on OSHA requirements, hazard assessments, and industry standards
PPE and the Hierarchy of Controls
Personal protective equipment is the last line of defense in the hierarchy of controls. Before relying on PPE, employers must first attempt to eliminate the hazard, substitute a less hazardous process, implement engineering controls (ventilation, guarding, isolation), and establish administrative controls (procedures, rotation, signage). PPE is used when these higher-level controls are not feasible, are being implemented, or do not fully protect the worker 1910.132(a).
Key Principle: PPE does not eliminate the hazard — it only reduces the worker's exposure. A malfunctioning respirator, an improperly rated glove, or a scratched face shield can give a false sense of security. PPE must be properly selected, fitted, maintained, and used in conjunction with other controls.
Hazard Assessment and Certification
OSHA requires the employer to perform a hazard assessment of the workplace to determine if hazards are present or likely to be present that require PPE 1910.132(d)(1). The assessment must survey all work areas for sources of hazards including impact, penetration, compression, chemical exposure, harmful dust, light radiation, heat, electrical hazards, and falling objects.
After completing the assessment, the employer must produce a written certification that includes the workplace evaluated, the person performing the assessment, the date(s) of the assessment, and identification of the document as a hazard assessment certification 1910.132(d)(2). This written certification is one of the most commonly cited deficiencies during OSHA inspections — many employers perform the assessment but fail to document it.
PPE Selection by Body Region
Electrical PPE and NFPA 70E
Electrical work introduces unique PPE requirements governed by both OSHA 1910.137 and NFPA 70E. Arc flash hazards require arc-rated (AR) clothing and face protection based on the incident energy analysis or the arc flash PPE category method.
Rubber insulating gloves must be tested before first use, every 6 months thereafter, and after any suspected damage 1910.137(c)(2). Glove classes range from Class 00 (500V AC) to Class 4 (36,000V AC). Leather protector gloves must always be worn over rubber insulating gloves to prevent physical damage.
Training and Documentation
Each employee required to use PPE must be trained to know 1910.132(f):
- When PPE is necessary and what PPE is necessary.
- How to properly don, doff, adjust, and wear PPE.
- The limitations of the PPE.
- The proper care, maintenance, useful life, and disposal of the PPE.
Retraining is required when the employer has reason to believe the employee does not have the necessary understanding, when changes in the workplace render previous training obsolete, or when changes in PPE make earlier training inadequate. The employer must certify in writing that training has been completed — including the employee name, date of training, and subject of certification.
Employer Payment Obligations
With limited exceptions, employers are required to provide PPE at no cost to employees 1910.132(h). The employer is not required to pay for:
- Everyday clothing (long pants, street shoes) or weather-related gear not used for workplace hazards.
- Ordinary prescription eyeglasses or sunglasses (but prescription safety glasses with side shields are employer-provided).
- Logging boots and prescription safety eyewear when the employee provides the equipment and the employer does not require specific brands or features.
- Items that employees are allowed to take home and use for personal purposes.
Replacement and Maintenance
The employer is responsible for maintaining PPE in a sanitary and reliable condition. This includes cleaning, disinfecting, repairing, and replacing PPE as necessary. If an employee's PPE is damaged, defective, or has reached the end of its useful life, the employer must provide a replacement at no cost. Employees have a responsibility to report damaged or defective PPE promptly.
References
1. OSHA 29 CFR 1910 Subpart I — Personal Protective Equipment (1910.132–.140).
2. ANSI/ISEA Z87.1-2020 — Occupational and Educational Personal Eye and Face Protection Devices.
3. ANSI/ISEA Z89.1-2014 — Industrial Head Protection.
4. NFPA 70E: Standard for Electrical Safety in the Workplace, 2024 Edition.
5. OSHA Publication 3151: Personal Protective Equipment.
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Discussion (2)
The hazard assessment certification is the document OSHA looks for first during a PPE inspection. 29 CFR 1910.132(d)(2) requires a written certification that a workplace hazard assessment has been performed, with the name of the certifier, the date, and the areas assessed. I have seen companies spend thousands on premium PPE and still get cited because they never documented the assessment that determined what PPE was needed in the first place.
This is one of those citations that is entirely preventable with a one-page form. The hazard assessment does not need to be a 50-page binder — it needs to identify the hazards present, the body parts at risk, and the PPE selected to address each hazard. We walk clients through a simple matrix: task, hazard, body part, PPE required. Sign it, date it, keep it on file. That document is your defense if OSHA asks why your workers are wearing what they are wearing.
Do not overlook PPE fit. Safety glasses that slide down, gloves that are too bulky for the task, and hearing protection that workers remove because it is uncomfortable — these all defeat the purpose. OSHA expects employers to provide PPE that fits properly. When I do site walks, the first thing I check is whether people are actually wearing their PPE correctly, not just whether it was issued. Issuance records mean nothing if the equipment is hanging around their neck.