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OSHA 1915.152

General PPE requirements

Subpart I

23 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.152(a), who must provide PPE and when must it be used in shipyard employment?

Under 1915.152(a) the employer must provide appropriate PPE and ensure affected employees use it whenever hazards from work activities require PPE. Employers are responsible for supplying PPE that protects the eyes, face, head, extremities, torso, and respiratory system (including shields, barriers, fall protection and lifesaving equipment) where employees are exposed to hazards, per 1915.152(a).

Under 1915.152(b), what must an employer do to decide whether PPE is needed?

Under 1915.152(b) the employer must perform an occupational hazard assessment to determine whether hazards are present or likely to be present that require the use of PPE. If hazards exist, the employer must then select PPE to protect employees based on that assessment, communicate selections, ensure proper fit, and document the assessment (occupation, dates, and name of person who performed it), per 1915.152(b).

Under 1915.152(b)(1), how should employers choose the type of PPE after a hazard assessment?

Under 1915.152(b)(1) employers must select the type of PPE that will protect affected employees from the specific hazards identified during the occupational hazard assessment. Selections must match the hazard (for example chemical splash, particulates, impact, or radiation) and meet applicable requirements in Subpart I, per 1915.152(b)(1).

  • Make decisions based on the hazard type, exposure level, and task (e.g., splash-resistant goggles for chemical splashes, welding hoods for arc radiation).
  • Cite: 1915.152(b)(1).

Under 1915.152(b)(2), what must employers communicate to affected employees about PPE selection?

Under 1915.152(b)(2) employers must communicate their PPE selection decisions to all affected employees so they know what PPE is required and why, per 1915.152(b)(2).

  • Communications should include what PPE to use, the hazards it protects against, and any limits of the PPE.
  • Cite: 1915.152(b)(2).

Under 1915.152(b)(3), what does “select PPE that properly fits each affected employee” mean in practice?

Under 1915.152(b)(3) employers must ensure PPE is appropriately sized and adjustable so each affected employee receives equipment that fits and provides the intended protection, per 1915.152(b)(3).

  • Practical steps: provide different sizes, perform fit checks (e.g., respirator fit-testing where required by other standards), and allow time for employees to try on and adjust PPE before use.
  • Cite: 1915.152(b)(3).

Under 1915.152(b)(4), what specific information must be on the document that verifies the hazard assessment was performed?

Under 1915.152(b)(4) the document verifying the required occupational hazard assessment must include the occupation, the date(s) of the hazard assessment, and the name of the person performing the hazard assessment, per 1915.152(b)(4).

  • Note: A trade- or occupation-based assessment that addresses PPE-related hazards is acceptable (see NOTE 1 to paragraph (b)).
  • Cite: 1915.152(b)(4).

Under 1915.152(c), can defective or damaged PPE be used on the job?

Under 1915.152(c) defective or damaged PPE must not be used. Employers must remove from service and repair or replace PPE that is worn, damaged, or otherwise defective, per 1915.152(c).

  • Practical action: set up routine inspections, tagging or removal procedures, and replacement policies to prevent use of unsafe PPE.
  • Cite: 1915.152(c).

Under 1915.152(d) and (e), what are employers required to do before reissuing used PPE to another employee?

Under 1915.152(e) employers must ensure that all unsanitary PPE—including PPE previously used by other employees—is cleaned and disinfected before it is reissued. Employers should not reissue PPE that is defective or damaged, per 1915.152(e) and 1915.152(c).

  • Clean and disinfect according to manufacturer instructions or accepted workplace procedures to avoid disease transmission.
  • Cite: 1915.152(e) and 1915.152(c).

Under 1915.152(e)(1), what topics must PPE training cover?

Under 1915.152(e)(1) PPE training must cover when PPE is necessary; what PPE is necessary; how to properly don, doff, adjust, and wear PPE; the limitations of the PPE; and the proper care, maintenance, useful life and disposal of the PPE, per 1915.152(e)(1).

Under 1915.152(e)(2) and (e)(3), when must an employer retrain an employee on PPE?

Under 1915.152(e)(2) and (e)(3) an employer must ensure each affected employee demonstrates ability to use PPE properly before performing work requiring PPE and must retrain any employee who does not demonstrate or retain that ability, per 1915.152(e)(2) and 1915.152(e)(3).

Under 1915.152(f), who pays for PPE and what common exceptions allow employers not to pay?

Under 1915.152(f)(1) employers must provide PPE used to comply with Part 1915 at no cost to employees, except where paragraphs (f)(2) through (f)(6) provide exceptions. Common exceptions include non-specialty safety-toe footwear and non-specialty prescription safety eyewear if the employer allows those items off the worksite, per 1915.152(f)(1) and 1915.152(f)(2).

Under 1915.152(f)(3), does an employer have to reimburse an employee who buys shoes or boots with built-in metatarsal protection?

Under 1915.152(f)(3) an employer need not reimburse an employee who requests to use their own shoes or boots with built-in metatarsal protection when the employer provides metatarsal guards, meaning no reimbursement is required in that scenario, per 1915.152(f)(3).

  • Employers may still provide and pay for metatarsal guards as necessary; if the employee uses their own appropriate equipment, the employer is not required to reimburse.
  • Cite: 1915.152(f)(3).

Under 1915.152(f)(4), what clothing and items are employers not required to pay for?

Under 1915.152(f)(4) employers are not required to pay for everyday clothing (like long-sleeve shirts, long pants, street shoes) or ordinary items used solely for weather protection (such as winter coats, ordinary sunglasses, sunscreen), per 1915.152(f)(4)(i)-(ii).

  • These exclusions clarify that normal work clothes and common weather gear are not PPE the employer must pay for under Part 1915’s payment rules.
  • Cite: 1915.152(f)(4).

Under 1915.152(f)(5), who pays for replacement PPE and are there exceptions?

Under 1915.152(f)(5) the employer must pay for replacement PPE, except when an employee has lost the PPE or intentionally damaged it, per 1915.152(f)(5).

  • Employers should have procedures to replace worn or damaged PPE and to document deliberate damage or loss if they intend to deny replacement at employer expense.
  • Cite: 1915.152(f)(5).

Under 1915.152(f)(6), can an employer allow an employee to use their own PPE and does the employer have to reimburse them?

Under 1915.152(f)(6) an employer may allow an employee to use appropriate protective equipment that the employee already owns, and the employer is not required to reimburse the employee for that equipment, per 1915.152(f)(6).

  • Important: If the employer requires PPE, the employer still must provide it at no cost unless the PPE falls under an exception in (f)(2)–(f)(5).
  • Cite: 1915.152(f)(6).

Under 1915.152(f)(7), when did the employer payment requirements for PPE become effective?

Under 1915.152(f)(7) the PPE payment provisions became effective on February 13, 2008, and employers had to implement the PPE payment requirements no later than May 15, 2008, per 1915.152(f)(7).

  • Note: The regulation’s note explains that when another OSHA standard specifies payment responsibility for specific equipment, that standard’s payment rule prevails.
  • Cite: 1915.152(f)(7).

Under 1915.152(f) and the 2014 Letter of Interpretation, is it acceptable for employers to use deposit systems to encourage return of employer-owned PPE?

Under 1915.152(f) an employer may use a deposit system to encourage return of employer-owned PPE, but the system must not result in employees effectively paying for PPE that the employer is required to provide. OSHA has said a deposit is acceptable if it does not circumvent the payment rule or involuntarily shift PPE costs to employees, per 1915.152(f) and the Letter of Interpretation on employee PPE payment methods at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

  • Practical approach: use a refundable deposit with a clear written agreement and prompt refund upon return, and do not charge for normal wear and tear.
  • Cite: 1915.152(f) and OSHA Letter of Interpretation (Employee PPE payment methods) at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

Under 1915.152 and the 2019 Letter of Interpretation about eye protection, does ordinary sunlight count as "potentially injurious light radiation" requiring welding-level eye protection?

Under 1915.152 (and the eye protection rules in Subpart I), ordinary sunlight is not considered the "potentially injurious light radiation" referred to for welding and cutting operations; that phrase targets intense sources like electric arc welding and torch cutting. OSHA’s shipyard eye-and-face protection interpretation confirms ordinary sunglasses are not substitutes for welding filters, per [1915.152] (https://www.osha.gov/laws-regs/regulations/standardnumber/1915/1915.152) and the Letter of Interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2019-12-30.

  • If employees perform welding or torch cutting, provide appropriate shaded welding helmets or goggles that meet the radiation-protection requirements in the welding standard (see 29 CFR 1915.153 and the 2019 LOI).
  • Cite: 1915.152 and OSHA Letter of Interpretation (Shipyard eye and face protection) at https://www.osha.gov/laws-regs/standardinterpretations/2019-12-30.

Under 1915.152, can a competent person decide PPE when no OSHA PEL exists for a chemical exposure?

Under Part 1915 a competent person may specify necessary protection when exposures present a hazard even if there is no OSHA PEL; the competent person must be capable of recognizing and evaluating hazardous exposures and specifying necessary protection, per the competent person guidance and 1915.152. OSHA’s Letter of Interpretation on competent persons confirms that competent persons can specify protections based on other occupational exposure limits or professional judgment where no PEL exists, see https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

  • Practical note: document the competent person’s evaluation and the PPE chosen as part of the employer’s hazard assessment.
  • Cite: 1915.152 and OSHA Letter of Interpretation (Competent person requirements in shipyards) at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18.

Under 1915.152(e)(2), is an employee allowed to perform PPE-required work before demonstrating they can use the PPE properly?

Under 1915.152(e)(2) no—an employer must ensure each affected employee demonstrates the ability to use PPE properly before being allowed to perform work that requires PPE, per 1915.152(e)(2).

  • Employers should include hands-on practice and checks in training so employees can demonstrate correct donning, doffing, adjustment, and limitations awareness.
  • Cite: 1915.152(e)(2).

Under 1915.152(c) and (e), what must employers do if PPE is contaminated with biological material before reissuing it?

Under 1915.152(e) and 1915.152(c) employers must clean and disinfect unsanitary PPE before reissuing it and must not reissue PPE that is defective or damaged, per 1915.152(e) and 1915.152(c).

  • Follow manufacturer cleaning instructions or established disinfection procedures appropriate for the contaminant to ensure safety and prevent disease transmission.
  • Cite: 1915.152(e) and 1915.152(c).

Under 1915.152(f) and the 2014 LOI, may employers deduct a refundable deposit from pay for PPE the employer will ultimately provide?

Under 1915.152(f) employers may use a refundable deposit system as long as it does not result in the employee bearing the cost of PPE that the employer is required to provide; OSHA’s 2014 Letter of Interpretation explains that deposits are acceptable if they don’t effectively require the employee to pay for PPE or circumvent the payment rule, see 1915.152(f) and https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

  • Make deposits refundable and documented, and do not deduct amounts that would make the employee effectively pay for required PPE or charge for normal wear and tear.
  • Cite: 1915.152(f) and OSHA Letter of Interpretation (Employee PPE payment methods) at https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13.

Under 1915.152, can an employer require an employee to provide their own PPE for use on the job?

Under 1915.152(f) employers shall not require an employee to provide or pay for their own PPE unless the PPE falls within the listed exceptions (such as non-specialty safety-toe footwear or ordinary clothing used for weather protection), per 1915.152(f).

  • If an employer allows employee-owned PPE to be used, the employer may permit it under 1915.152(f)(6), but the employer is not required to reimburse the employee.
  • Cite: 1915.152(f) and 1915.152(f)(6).