In my fifteen years as an Industrial Hygienist, I have walked onto countless shop floors where the safety cabinet was full, yet the facility was completely non-compliant. Purchasing gear is the easy part; understanding OSHA requirements for PPE (Personal Protective Equipment) and integrating them into a functional Safety Management System is where most operations fail.
Let’s be clear: PPE is the last line of defense in the Hierarchy of Controls. If you are relying solely on a hard hat to save a life, you have likely missed critical engineering or administrative controls. However, when hazards cannot be engineered out, 29 CFR 1910 requires specific, documented, and certified protection.
In this guide, I will strip away the bureaucratic fluff and walk you through exactly what standard 1910.132 and its sub-sections demand of you as an employer. We will cover the critical Hazard Assessment, the specific ANSI and ASTM standards for eyes, head, and feet, and the documentation you need to survive a compliance audit.
The Foundation: General Requirements (29 CFR 1910.132)
Before you buy a single pair of gloves, you must address 29 CFR 1910.132. This is the umbrella standard that dictates how PPE is selected and used. The most common citation I see isn't for a lack of equipment—it's for a lack of assessment.
The Hazard Assessment
OSHA mandates that the employer must assess the workplace to determine if hazards are present. You cannot simply guess. This assessment must be a written certification that identifies:
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The workplace evaluated.
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The person certifying the evaluation.
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The date(s) of the assessment.
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The document as a Certification of Hazard Assessment.
Training is Not Optional
Providing the gear is legally insufficient if the employee does not know how to use it. Under 1910.132(f), you must train every employee on:
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When PPE is necessary.
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What PPE is necessary.
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How to properly don, doff, adjust, and wear PPE.
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The limitations of the PPE.
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Proper care, maintenance, useful life, and disposal.
Dr. Thorne's Note: If you hand a worker a respirator but don't train them on seal checks, you are not just negligent; you are non-compliant. Documentation of this training is required.
Eye and Face Protection Standards
Eye injuries are among the most preventable yet devastating workplace accidents. 29 CFR 1910.133 dictates that protective eye and face devices must comply with consensus standards, specifically ANSI/ISEA Z87.1.
Decoding the Z87 Marking
Don't just look for "safety glasses." You need to verify the stamp on the frame or lens. As a specialist in additive manufacturing, I see high-velocity debris risks constantly. Standard spectacles are often insufficient.
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Z87: Basic Impact (plano).
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Z87+: High Velocity Impact rating (Crucial for grinding, machining, or 3D print post-processing).
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D3: Splash and Droplet protection (Required for chemical handling).
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D4: Dust protection.
Prescription Lenses
Employees who wear prescription lenses must either wear eye protection that incorporates the prescription in its design (and is Z87 rated) or wear eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.
Head and Foot Protection: Hard Hats and Boots
Protecting the extremities is about more than just buying "sturdy" gear. It is about impact ratings and electrical resistance.
Head Protection (29 CFR 1910.135)
Head protection must comply with ANSI/ISEA Z89.1. You must select the right Type and Class:
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Type I: Reduces force of impact resulting from a blow only to the top of the head.
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Type II: Reduces force of impact resulting from a blow which may be received off-center, from the front, or to the rear (lateral impact).
Classes:
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Class G (General): Voltage protection up to 2,200 volts.
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Class E (Electrical): Voltage protection up to 20,000 volts.
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Class C (Conductive): No electrical protection.
Foot Protection (29 CFR 1910.136)
Safety footwear must comply with ASTM F2413 (formerly ANSI Z41). In an industrial setting, we look for steel-capped boots or composite toes that are rated for compression and impact.
If your facility deals with static-sensitive electronics or explosive atmospheres, you must also look for SD (Static Dissipative) rated footwear. Conversely, electrical workers need EH (Electrical Hazard) ratings.
Hand Protection: Material Science Matters
There is no "universal" safety glove. 29 CFR 1910.138 requires employers to select hand protection based on the performance characteristics of the hand protection relative to the task. This is where materials science is critical.
Chemical Resistance: Nitrile vs. Latex
In my lab, we strictly monitor permeation rates.
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Latex: Good for biological pathogens but poor organic chemical resistance. It is also a high allergen risk.
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Nitrile: The industrial standard. Excellent resistance to oils, greases, and many solvents.
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PVA (Polyvinyl Alcohol): Vital for strong organic solvents where nitrile fails, but it dissolves in water.
Mechanical Risks
For cut resistance, look for ANSI/ISEA 105 ratings. A glove rated A1 is for light duty (paper cuts), while A9 is for extreme hazards (meat processing, heavy metal fabrication). Do not send a worker into a sheet metal shop with A1 gloves.
Who Pays for PPE? (Clarifying 1910.132(h))
One of the most frequent questions I receive from business owners concerns the budget. In 2008, OSHA clarified the payment rule.
The General Rule: The employer must pay for PPE required to comply with OSHA standards.
The Exceptions:
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Non-specialty safety-toe protective footwear (provided the employer permits such items to be worn off the job-site).
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Non-specialty prescription safety eyewear (provided the employer permits such items to be worn off the job-site).
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Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots.
If you require specialty items, such as metatarsal guards or non-prescription eyewear inserts, the cost falls on the company.
Conducting a PPE Compliance Audit
To maintain a compliant facility, you cannot rely on a one-time setup. You need a cyclical audit process. Here is the framework I use for my clients:
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Walkthrough Inspection: Physically walk the floor. Are employees wearing their safety glasses? Is the PPE in good condition?
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Review the Hazard Assessment: Has your workflow changed? Did you add a new 3D printer or CNC machine? If so, the assessment must be updated.
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Check Certification Dates: Hard hats have expiration dates (usually 5 years from the date of manufacture). Inspect the stamps inside the shell.
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Audit Training Records: ensure all new hires have signed documentation of their PPE training.
Summary of Required Documentation:
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Written Hazard Assessment Certification.
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Written PPE Training Certification.
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Respiratory Protection Program (if respirators are used).
If an OSHA inspector arrives, these are the first documents they will ask for. Having them organized proves you are managing safety proactively, not reactively.
Meeting OSHA requirements for PPE is not about checking a box; it is about ensuring that when an engineering control fails, your employee goes home safely. As safety officers and business owners, we must look beyond the price tag and focus on the specifications—ANSI ratings, material compatibility, and proper fit.
Remember, the most expensive PPE is the piece that fails because it was the wrong tool for the job. Conduct your hazard assessments with rigor, train your team relentlessly, and ensure your equipment meets the current consensus standards.
Stay safe, and keep your standards high.
