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OSHA 1910SubpartIAppB

PPE hazard assessment guidelines

Subpart I

19 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.132(a), who must do the PPE hazard assessment and what role does Appendix B to Subpart I of Part 1910 recommend for the safety officer?

The employer must ensure a workplace hazard assessment is performed, and Appendix B recommends that the safety officer use common sense and appropriate expertise to carry it out. Employers are responsible for conducting the assessment under 1910.132(a), and Appendix B to Subpart I of Part 1910 explains that the safety officer should exercise common sense and appropriate expertise when surveying and selecting PPE (1910SubpartIAppB).

  • Do a documented walk-through survey, organize and analyze data, and select PPE accordingly as described in Appendix B.
  • The safety officer acts as the person who leads the assessment and makes reasoned selections based on the hazards found.

Under 1910.132(b), what hazards must be considered during the initial PPE survey recommended in Appendix B?

You must consider the basic hazard categories including impact, penetration, compression (roll-over), chemical, heat, harmful dust, and light (optical) radiation during the walk-through survey. Appendix B lists these categories for employers to inspect during the survey step and they support compliance with 1910.132(b).

  • Inspect machinery motion, high temperatures, chemical exposures, dust sources, light/radiation (welding, cutting), falling or sharp objects, rolling/pinching hazards, layout and coworker locations, and electrical hazards as Appendix B directs.
  • Review injury/accident data to help identify problem areas.

Under Appendix B to Subpart I of Part 1910, what specific items should you observe during the walk-through survey?

During the walk-through survey you should observe sources of motion, high temperatures, chemical exposures, harmful dust, light radiation (e.g., welding), falling and sharp objects, rolling or pinching hazards, workplace layout and coworker locations, and any electrical hazards. Appendix B provides this checklist and recommends these observations to identify hazards for PPE selection (1910SubpartIAppB).

  • Watch for moving parts or particle motion that could strike workers.
  • Note hot surfaces, sparks, or sources of optical radiation.
  • Identify potential splash, dust, or piercing hazards and areas where coworkers could be struck by materials.
  • Include electrical hazards in your assessment and review past injury records.

Under Appendix B and 1910.132, how should you organize and analyze data after the walk-through survey?

After the walk-through, you should organize the collected observations and records to estimate the potential for injuries and determine the type, level, and seriousness of risks so you can choose appropriate PPE. Appendix B directs employers to organize and analyze survey data to prepare for PPE selection, which supports meeting the employer obligations in 1910.132 (1910SubpartIAppB).

  • Create a hazard inventory that links tasks to hazards and probable injuries.
  • Consider simultaneous exposures (e.g., chemical plus heat) and frequency/duration of tasks.
  • Use injury logs and exposure measurements to prioritize controls and PPE.

Under Appendix B, how should employers choose PPE once hazards are identified?

Employers must select PPE that provides a level of protection greater than the minimum needed by comparing the environment's hazards to PPE capabilities and then fit and instruct users on care and use. Appendix B outlines a four-step selection process—become familiar with PPE, compare hazard parameters to device capabilities, choose equipment that exceeds minimum protection needs, and fit and train the user—which supports compliance with 1910.132 (1910SubpartIAppB).

  • Match impact velocities, radiation intensities, or chemical splash potential to PPE performance.
  • Provide fitting, training, and warning/limitation information to end users.

Under Appendix B, when choosing eye and face protection, must faceshields be worn alone or over other eye protection?

Faceshields must be worn over primary eye protection such as spectacles or goggles; they are not adequate as standalone eye protection for most hazards. Appendix B explicitly states that faceshields should only be worn over primary eye protection and cites lens and filter requirements that align with 1910.133 and 1910.133(a)(5).

  • Use faceshields for splashes, hot sparks, or when full-face coverage is required, but always combine them with goggles or safety spectacles for impact protection.
  • Follow filter shade requirements for tasks involving optical radiation as required under 1910.133(a)(5).

Under Appendix B and 1910.133(a)(5), how should you select lens shade for welding and similar tasks?

Select the darkest filter shade that still allows the worker to perform the task safely; filter lenses must meet the shade-designation requirements in 1910.133(a)(5) and Appendix B advises choosing the darkest shade consistent with task performance (1910SubpartIAppB).

  • For electric arc welding typical shades are 10–14; gas welding and cutting have different typical shade ranges identified in Appendix B.
  • Remember tinted lenses are not filter lenses unless marked; follow the standard's marking and shade rules.

Under Appendix B, what should employers do about workers who need prescription (Rx) lenses?

Employers must ensure employees who require prescription lenses wear either protective devices fitted with prescription lenses or protective devices designed to be worn over regular prescription eyewear. Appendix B states this requirement and supports compliance with the eye-protection portion of 1910.133 (1910SubpartIAppB).

  • Provide prescription safety eyewear or qualified over-the-glasses protectors so the employee's vision remains correct while protected.
  • Ensure the chosen device also meets impact, splash, or optical radiation protection as needed.

Under Appendix B, what guidance is given about workers who wear contact lenses in hazardous environments?

Workers who wear contact lenses must also wear appropriate eye and face protection because contact lenses do not replace PPE and may present additional hazards in dusty or chemical environments. Appendix B explicitly says contact lens wearers must still wear suitable protection and cautions about dusty/chemical conditions; this supports the employer's obligations under 1910.133 (1910SubpartIAppB).

  • Evaluate whether the work environment (dusts, chemical splashes, fumes) could increase risk for contact lens wearers and select sealed goggles or faceshields as needed.
  • Train contact lens wearers on emergency procedures for contamination.

Under Appendix B, how should employers choose head protection when electrical hazards are present?

When electrical hazards are present, employers must select helmets with the appropriate electrical class (Class G, E, or C) based on the expected voltage exposure, and where falling-object hazards exist, helmets must be worn. Appendix B describes helmet classes and explains that Class G provides protection up to 2,200 volts, Class E up to 20,000 volts, and Class C provides no electrical protection; these selection guidelines support compliance with 1910.132 and the head protection standard 1910.135 via 1910SubpartIAppB.

  • Choose Class E helmets for higher-voltage areas and avoid conductive Class C helmets around electrical hazards.
  • If lateral impacts are a hazard, select Type II helmets per Appendix B (ANSI guidance noted).

Under Appendix B and the head-protection Letter of Interpretation (2024-06-06-2), when must crane operators wear protective helmets?

Crane operators must wear protective helmets when the employer's hazard assessment determines there is potential for head injury from falling objects or overhead hazards; Appendix B and OSHA's Letter of Interpretation on head protection for crane operators reinforce that requirement. Appendix B explains head protection selection (1910SubpartIAppB), and OSHA's interpretation clarifies that 29 CFR 1910.135(a)(1) applies when overhead falling-object hazards exist, including crane lifts (see OSHA Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06-2).

  • The employer must assess the workplace under 1910.132(d)(1) and require helmets if the assessment shows risk.
  • Ensure helmets meet applicable ANSI standards as referenced in the interpretation.

Under Appendix B, what guidance does OSHA give for selecting foot protection like safety shoes?

Employers should select safety shoes or boots that match the hazards—impact, compression, puncture, metatarsal, conductive or insulating—based on the workplace risks identified in the hazard assessment. Appendix B describes when impact or compression protection, puncture-resistant soles, metatarsal guards, or electrically conductive/insulating footwear are appropriate and this selection supports the PPE requirements in 1910.132 (1910SubpartIAppB).

  • Use impact-rated footwear for handling heavy tools or materials that could be dropped on feet.
  • Use puncture-resistant soles where nails or scrap metal may be stepped on.
  • Provide electrical-hazard footwear as supplementary protection where hazardous step or touch potentials exist.

Under Appendix B, what factors should employers consider when selecting gloves for chemical protection?

Employers should determine the chemicals' toxic properties (local and systemic effects), select gloves based on the chemical with the shortest breakthrough time in mixtures, and ensure employees can remove gloves without contaminating skin. Appendix B gives detailed glove-selection factors for chemical hazards and notes that manufacturers' performance data should be requested before purchase to ensure appropriate protection, supporting compliance with 1910.132 (1910SubpartIAppB).

  • For mixtures, choose gloves based on the component with the shortest breakthrough time unless specific test data show otherwise.
  • Consider dexterity needs, duration/frequency of exposure, and physical stresses when selecting glove material and thickness.
  • Ask manufacturers for documented test results for the specific chemicals you expect to encounter.

Under Appendix B, are there gloves that protect against all hand hazards and all chemicals?

No—OSHA notes employers should be aware there are no gloves that protect against all hand hazards or all chemicals, so glove selection must be hazard-specific and based on performance testing. Appendix B expressly states that commonly available glove materials provide limited protection and recommends selecting gloves using standard test procedures and manufacturer documentation consistent with 1910.132 (1910SubpartIAppB).

  • Select gloves that are tested and proven for the precise hazard (cut, chemical, thermal, etc.).
  • Plan for replacement intervals and consider cost-effectiveness (disposable vs. durable) while ensuring protection.

Under Appendix B, how should employers fit PPE and why is fit important?

Employers must ensure PPE fits comfortably and correctly because poorly fitting PPE will not provide necessary protection and users are less likely to wear it. Appendix B emphasizes careful consideration of comfort and fit, availability of sizes, and making individual adjustments (e.g., chin straps, adjustable features) to maintain protective position, supporting compliance with employer duties under 1910.132 (1910SubpartIAppB).

  • Adjust helmets, eye protection, and face seals individually; follow manufacturers' fitting instructions.
  • Use chin straps when necessary to keep helmets on, but ensure they will break at a reasonably low force to reduce strangulation risk as Appendix B advises.

Under Appendix B, what does OSHA say about reassessing PPE needs?

Employers must reassess workplace hazards and the suitability of selected PPE whenever new equipment, processes, accident records, or other changes indicate a reassessment is necessary. Appendix B makes reassessment the safety officer's responsibility and directs reevaluation when conditions change to maintain compliance with 1910.132 (1910SubpartIAppB).

  • Reassess after process changes, incident investigations, or when new hazards are introduced.
  • Document reassessments and update PPE selections, training, and fit as needed.

Under Appendix B and 1910.132(a)/(b), how often and why must PPE be inspected, cleaned, and maintained?

PPE must be inspected, cleaned, and maintained at regular intervals so it continues to provide the required protection, and contaminated PPE that cannot be decontaminated must be disposed of safely. Appendix B states these maintenance expectations and ties them to compliance with 1910.132(a) and 1910.132(b) (1910SubpartIAppB).

  • Clean eye and face protection frequently to avoid vision impairment from dirt or fogging.
  • Set routine inspection schedules, retire damaged PPE, and properly dispose of non-decontaminable contaminated PPE.

Under Appendix B, how should employers handle multiple simultaneous hazards (e.g., chemical plus impact) when selecting PPE?

Employers must select PPE that provides adequate protection against the highest level of each simultaneous hazard present, ensuring combined protection where needed. Appendix B explicitly warns about multiple and simultaneous exposures and instructs employers to provide adequate protection against the highest level of each hazard, which supports meeting 1910.132 obligations (1910SubpartIAppB).

  • If a task has both splash and impact hazards, use goggles/spectacles for impact plus a faceshield for splash.
  • Verify compatibility of PPE components (e.g., respirators with face shields) and ensure they don't interfere with protective functions.

Under Appendix B and 1910.133, what ventilation and splash-protection considerations apply to eye and face protection?

Eye and face protection must provide adequate ventilation while preventing splash entry, and employers should choose devices that balance ventilation and protection for the hazard. Appendix B states eye/face protection should be designed and used to provide ventilation and protect against splash, consistent with 1910.133 (1910SubpartIAppB).

  • Use vented goggles with indirect vents or specially designed splash goggles where splash is a hazard but some ventilation is needed.
  • Provide faceshields plus goggles for severe splash exposures, and ensure ventilation does not allow contaminants to enter.