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OSHA 1915.157

Hand and body protection

Subpart I

18 Questions & Answers
10 Interpretations

Questions & Answers

Under 1915.157(a), when must an employer ensure employees use hand protection and other protective clothing?

Employers must provide and ensure employees use hand protection and other protective clothing whenever workers are exposed to hazards like skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, harmful temperature extremes, or sharp objects. See the Use requirement in 1915.157(a).

  • The rule is performance-based: it lists typical hazards that trigger the requirement rather than prescribing specific glove models.
  • For exposures that are not specifically covered by a permissible exposure limit, a competent person may specify appropriate protection as noted in OSHA guidance about duties of a competent person in shipyard standards (see OSHA Letter of Interpretation on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Under 1915.157(a), how do I decide what type of glove or protective clothing to provide for a specific hazard?

Choose hand and body protection based on the specific hazard (e.g., chemicals, cuts, heat, punctures) and on a competent evaluation of exposure; the employer must ensure the protection is appropriate for the hazard. See 1915.157(a) and OSHA's interpretation that a competent person must be capable of specifying necessary protection under Part 1915 (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Assess the hazard type (chemical, thermal, mechanical, electrical) and exposure severity.
  • Have a qualified or competent person select glove materials and clothing that resist the identified hazards.
  • Document the selection rationale and replace or upgrade PPE when conditions or exposures change.

Under 1915.157(b), may an employee wear clothing impregnated with grease or oil while doing hot work or working near an ignition source?

No — employees must not wear clothing that is impregnated or covered, in whole or in part, with flammable or combustible materials (such as grease or oil) while engaged in hot work operations or working near an ignition source. See 1915.157(b).

  • “Hot work” includes operations that produce sparks, molten metal, or open flames (e.g., welding, cutting).
  • Remove, clean, or replace contaminated clothing before performing hot work to prevent ignition or flash burns.

What counts as "hot work operations" for purposes of 1915.157(b) clothing restrictions?

Hot work operations are tasks that create ignition hazards from sparks, molten metal, flames, or other high‑temperature radiant energy (for example, welding, cutting, brazing, or torch work), and clothing contaminated with flammable substances is prohibited during those operations under 1915.157(b).

  • Use flame-resistant garments or clean, uncontaminated work clothes during hot work.
  • If uncertain whether an operation is “hot work,” treat it as such and remove contaminated clothing or isolate the ignition source.

Under 1915.157(c), when are electrical insulating gloves and sleeves required?

Electrical insulating gloves and sleeves (or other electrical protective equipment) are required whenever an employee is exposed to electrical shock hazards while working on electrical equipment. See 1915.157(c).

  • The employer must evaluate electrical hazards and provide appropriate insulating equipment rated for the voltages involved.
  • A competent person should specify the correct insulating class and any additional protective measures (see OSHA letter on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Can employers use protective electrical equipment other than insulating gloves and sleeves to protect workers from shock under 1915.157(c)?

Yes — 1915.157(c) allows the use of protective electrical insulating gloves and sleeves or other electrical protective equipment as appropriate to protect employees from electrical shock hazards. See 1915.157(c).

  • The choice of protective equipment should be based on the specific electrical hazard and made by a knowledgeable or competent person (see OSHA Letter of Interpretation on competent persons: https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).
  • Ensure electrical PPE is inspected, maintained, and rated for the maximum system voltage encountered.

Who is responsible for specifying the appropriate hand and body protection when OSHA standards don't list a specific PEL or detailed PPE?

A competent person designated by the employer is responsible for recognizing hazards, evaluating exposures, and specifying the necessary protection and precautions when the standards do not prescribe specific limits or PPE. This responsibility is described in OSHA’s shipyard competent person interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18) and supports the employer’s duty under 1915.157(a).

  • The competent person must be capable of recognizing and evaluating the hazard and specifying adequate PPE and controls.
  • Employers must ensure the competent person’s decisions are implemented and updated as hazards change.

Does OSHA require employers to pay for hand and body PPE provided under 1915.157 in shipyard employment?

Yes — OSHA’s employer payment rule requires employers to pay for PPE that OSHA standards require, including PPE required under shipyard standards like 1915.157. OSHA's interpretation on PPE payment methods discusses the general rule and exceptions and explicitly references Parts 1910, 1915, 1917, 1918, and 1926 (https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

  • Employers may retain ownership and require return of PPE on termination; they may recover the cost of lost PPE in some situations so long as arrangements do not force employees to bear the cost of required PPE.
  • Deposit systems or payroll deductions must not effectively make the employee pay for required PPE.

Can an employer require a deposit for PPE issued to a shipyard employee, as discussed in the OSHA PPE payment guidance?

Yes, an employer may require a deposit for employer-owned PPE provided the system does not result in the employee bearing the cost of PPE required by OSHA and it complies with federal, state, and local laws; OSHA's interpretation permits deposits as an incentive to ensure return but cautions against practices that circumvent the employer‑payment rule (https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

  • The deposit system should not result in the employee actually paying for wear-and-tear caused by workplace conditions.
  • A clear written agreement is a recommended way to set expectations for return and reimbursement.

Under 1915.157, can employees work in garments that provide some UV protection (like welding shields) while doing non-welding tasks outdoors?

Garments and eye protection designed for welding protect against intense radiant energy from welding and cutting, but they are intended for those hot work operations and are not required to be worn solely for ordinary sunlight exposure under shipyard PPE rules. The scope of PPE for hot work and protection against injurious radiant energy is discussed for eye/face protection in an OSHA letter explaining that “potentially injurious light radiation” refers to intense sources like arc welding (see eye/face LoI at https://www.osha.gov/laws-regs/standardinterpretations/2019-12-30) and the clothing prohibition for hot work is specified in 1915.157(b).

  • If the work task creates the same intense radiation hazard as welding, use appropriate welding-rated PPE.
  • For ordinary outdoor UV exposure, employers may still consider sunglasses or sun-protective clothing, but the shipyard hot work rules do not treat sunlight as the kind of “injurious radiant energy” meant for welding PPE.

If a worker's gloves become contaminated with flammable materials (like grease or oil) during a shift, what must the employer require before the worker performs hot work?

The employer must ensure the worker does not wear clothing or gloves impregnated or covered with flammable or combustible materials while engaged in hot work or working near an ignition source, so contaminated gloves must be cleaned or replaced before performing hot work as required by 1915.157(b).

  • Remove or replace contaminated gloves and clothing before entering areas where hot work or ignition sources are present.
  • Provide suitable clean or flame-resistant PPE when work conditions make contamination likely.

If a job exposes workers to both chemical skin hazards and electrical shock hazards, what does 1915.157 require for PPE?

Both hazards must be addressed: provide protective clothing and gloves appropriate for chemical exposure under 1915.157(a) and electrical insulating gloves/sleeves or other electrical protective equipment for electrical shock hazards under 1915.157(c).

  • If hazards overlap (e.g., chemical-resistant gloves that are not electrically insulating), use layered or alternate PPE that protects against both hazards or separate tasks so PPE is appropriate for each.
  • A competent person should determine compatible PPE for combined hazards (see competent person LoI at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

Does 1915.157 specifically require training in the use of hand and body protection?

Section 1915.157 itself does not include an explicit training requirement; it requires employers to ensure affected employees use appropriate hand protection and protective clothing for listed hazards. However, OSHA guidance on the role of a competent person emphasizes that a competent person must be capable of specifying necessary protection (https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18), and employers have a general duty to ensure PPE is used properly.

  • Practical compliance means employers should train workers on when to use PPE, how to don/doff and inspect it, and how to maintain or report damaged PPE even though 1915.157 does not lay out training steps.
  • Employers should document that employees understand PPE use and that a competent person selected the PPE appropriate to the hazard.

If a glove or protective sleeve is intended to protect against electrical shock, must it be rated or tested?

Yes — while 1915.157(c) requires providing insulating gloves and sleeves or other electrical protective equipment when employees are exposed to electrical shock hazards, the selection should include equipment rated for the voltages and conditions encountered and maintained per the manufacturer and accepted practice; a competent person should specify the proper ratings (see 1915.157(c) and the OSHA letter on competent persons at https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

  • Follow manufacturer instructions and recognized industry practices for testing and inspection frequency.
  • If unsure of rating or test requirements, have a qualified electrical safety person or competent person determine the necessary rating and maintenance regimen.

Does the beryllium enforcement guidance affect hand and body protection decisions in shipyards?

Yes — the 2020 beryllium standards for shipyards require employers to address occupational exposures to beryllium, and that may include providing appropriate hand and body protection to prevent dermal contact or skin absorption where exposures or contamination occur; see OSHA's interim enforcement guidance for the 2020 beryllium standards which applies to shipyards (https://www.osha.gov/laws-regs/standardinterpretations/2021-04-21).

  • Where beryllium exposure is present, employers must follow the shipyard beryllium standard (29 CFR 1915.1024) and include PPE in their controls when required.
  • A competent person should determine what glove materials and protective clothing are necessary to prevent contamination or skin contact with beryllium.

Can an employer force an employee to pay for required shipyard PPE by having them buy it or by reimbursement systems?

No — under OSHA's employer payment policy, employers must provide required PPE at no cost to employees; reimbursement or purchase-by-employee systems that result in the employee bearing the cost of required PPE are not allowed. OSHA's interpretation on employee PPE payment methods explains this policy and covers shipyard provisions among the affected Parts (https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

  • Employers may implement reasonable policies for return of employer-owned PPE or require a deposit that is refunded, so long as the arrangement does not make the employee pay for required PPE.
  • Exceptions in the payment rule are narrow and specified in the final rule; consult the employer-payment rule and OSHA guidance when designing a payment or reimbursement practice.

Under 1915.157, are non-glove types of hand protection (like arm guards or aprons) acceptable against puncture or chemical hazards?

Yes — 1915.157 requires that each affected employee uses appropriate hand protection and other protective clothing where exposures exist; that can include arm guards, aprons, or other body coverings as appropriate to the hazard. See 1915.157(a).

  • Select the specific form of protection (glove, sleeve, apron) based on the hazard (cuts, chemicals, heat, etc.) and task.
  • A competent person should specify and document the protective ensemble needed for the work (see competent person LoI: https://www.osha.gov/laws-regs/standardinterpretations/2016-04-18).

If a shipyard worker uses PPE issued by the employer and then is terminated, can the employer require the employee to return that PPE?

Yes — if the employer retains ownership of the PPE, the employer may require the employee to return it upon termination; if the employee does not return employer-owned PPE, the employer may take reasonable steps to retrieve it or require repayment consistent with federal, state, and local law, as discussed in OSHA's PPE payment interpretation (https://www.osha.gov/laws-regs/standardinterpretations/2014-11-13).

  • The employer may not charge the employee for wear-and-tear or normal usage related to the work performed.
  • Having a written agreement about PPE return and deposit/refund terms is a good practice to avoid disputes.