More Than Just Handing Out Glasses
CFR reference: 29 CFR 1910.132 / 1910.133 / 1910.138
Personal protective equipment hazard assessment, selection, training, and documentation.
Personal Protective Equipment is governed by 29 CFR 1910 Subpart I — primarily 1910.132 (general requirements), 1910.133 (eye and face protection), 1910.135 (head protection), 1910.136 (foot protection), and 1910.138 (hand protection). The standards' core requirement is straightforward: identify the hazards in your workplace, select PPE that protects against those hazards, train employees on proper use, and document everything. The execution is where small operations get cited.
The most-cited subsection across all PPE standards is 1910.132(d) — failure to perform and document a workplace hazard assessment. This is the requirement that OSHA inspectors look for first because it is the foundation of every other PPE decision. The written assessment must identify the workplace evaluated, the person who performed it, the date it was performed, and the hazards identified. Without it, there is no defensible reason for any of the PPE selections an employer has made. In small shops, the written assessment either does not exist or is a generic template downloaded years ago that does not reflect the actual equipment, chemicals, or processes in the facility.
The second most-cited subsection is 1910.132(f) — training. Employees must be trained on when PPE is necessary, what PPE is necessary, how to properly wear and adjust it, the limitations of the PPE, and the proper care, maintenance, useful life, and disposal of the PPE. Training must be verified in writing — date, names, topics covered. "We told them at the morning meeting" is not training. OSHA wants a sign-in sheet and a topic outline, signed by the trainer and the employee.
Eye and face protection — 1910.133 — is consistently in OSHA's top 10 most-cited general industry standards. The citation usually involves employees performing eye-hazard work without proper protection, or employees wearing the wrong type of eye protection for the hazard (regular safety glasses where a face shield is required, no side shields where impact protection is required, no chemical splash protection where chemicals are handled). The fix is rarely the PPE — most operations have it on the shelf — it is the assessment and training that connect the hazard to the right PPE.
Hand protection — 1910.138 — is the next most common gap. Employees wearing the wrong glove for the chemical they are handling (latex where nitrile is required, cotton where cut-resistant is required). The hazard assessment is the document that should determine the correct selection; without it, the wrong selection is the default. Burned, torn, or chemically degraded gloves continue to be worn because nobody owns the replacement schedule.
What an OSHA Compliance Officer checks during a PPE-focused inspection: they ask for the written hazard assessment under 1910.132(d). They observe whether the PPE in actual use matches the hazards visible on the floor. They review training records and confirm each employee has been trained on the specific PPE they wear. They check whether PPE is provided at no cost — they will ask employees directly. They examine the PPE in use for damage, expiration, or inappropriate substitution.
Corrective action: walk every work area in your facility with a printed PPE hazard assessment template. For each work area, list the hazards (impact, chemical, electrical, thermal, sharp edges, noise, particles), identify the PPE selected for each hazard, certify the assessment with date and signer name. Build a PPE training session, document it with a sign-in sheet, and file it. Audit your PPE inventory — replace expired or damaged items, ensure proper sizes are stocked. Add PPE compliance to your supervisor's daily walkaround. Total fix time: about 8 hours of focused work for a small operation. Total cost: usually under $300 in replacement PPE and zero in new documentation. The cost of getting it wrong: 1910.132(d) failure is its own citation; 1910.132(f) failure is its own citation; each specific PPE subsection (1910.133, 1910.138, etc.) is its own citation. They stack.
I see employees grinding without face shields, using the wrong gloves for the chemicals they are handling, and safety glasses so scratched they can barely see through them. When I ask about the hazard assessment, it is either a generic template downloaded years ago or it does not exist. The employer bought the PPE — but never documented why those specific items were selected, never trained anyone on when to use them, and never enforced it consistently. By the time I walk in, the PPE has become optional in practice, even though it is required on paper.
Under 29 CFR 1910.132(d), every employer must perform a workplace hazard assessment to determine whether PPE is necessary. The assessment must be in writing, identify the workplace evaluated, the person certifying the assessment, and the date. PPE must then be selected to protect against the identified hazards, employees must be trained on its use, and the employer must verify the training in writing.
Yes, with limited exceptions. Under 29 CFR 1910.132(h), the employer must provide all required PPE at no cost to the employee. Exceptions include non-specialty safety-toe footwear and non-specialty prescription safety eyewear that the employee may take off-site, plus everyday clothing like long pants or weather gear.
The most common PPE citation is failure to perform and document the written hazard assessment under 1910.132(d). Operations frequently provide the PPE but cannot produce the written assessment showing why specific PPE was selected for specific hazards. Eye and face protection (1910.133) is the most-cited specific PPE category.
Field Note by Vince Lawrence — GigLine Safety & Compliance — Kernersville, NC — (336) 329-8899