PPE hazard assessment guidelines

The employer should designate a qualified person—such as a safety officer—to perform the PPE hazard assessment. This is stated in the non-mandatory guidelines which advise employers to "designate a safety officer or some other qualified person to exercise common sense and appropriate expertise to assess work activity hazards and select PPE" (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program). See also the OSHA interpretation explaining that a "competent person" must be capable of recognizing hazards and specifying necessary protection when applicable (Competent person requirements in shipyards).

• Train or pick someone with the knowledge to identify hazards and match PPE to risks.
• Document who is responsible so reassessments are assigned and consistent.

The employer must conduct a walk-through survey, organize and analyze the data, estimate injury potential, and then select PPE that matches the identified hazards. These steps come from the appendix guidance which outlines surveying sources of hazards, organizing and analyzing findings, and using that information to choose PPE (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Walk-through: identify sources such as impact, chemical, heat, dust, light radiation, falling objects, electrical hazards, etc.
• Organize data: create a hazard inventory by task and area.
• Analyze: classify hazard type, level of risk, and potential injury severity, including simultaneous exposures.
• Select PPE: choose devices that provide protection above the minimum needed and fit the user.

You should consider a set of hazard categories including impact, penetration, compression (roll-over), chemical, heat, harmful dust, light (optical) radiation, drowning, and falling. The appendix explicitly lists these categories to guide the walk-through survey (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• During the survey also look for motion sources, hot surfaces, chemical exposures, dust, welding/cutting light sources, falling or sharp objects, rolling/pinching hazards, workplace layout, and electrical hazards.

The employer must consider and provide protection for the highest level of each simultaneous hazard that is reasonably foreseeable. The appendix instructs employers to analyze combined exposures and to ensure protection adequate for the highest-level hazard present (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Provide PPE that addresses all significant hazards at once (for example, welding may require both eye radiation protection and heat/spark protection).
• Follow note (a) in the eye-and-face selection guidance which warns that multiple simultaneous exposures must be protected against.

Employers must reassess hazards whenever changing circumstances make it necessary—such as new equipment, changes in work practices, or lessons learned from accidents—and otherwise as needed to ensure PPE remains suitable. The appendix directs that a safety officer or qualified person should reassess work activities when changes occur (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Reassess after installation of new equipment, process changes, incident reviews, or when PPE does not perform as expected.
• Document reassessments and any changes to PPE selection.

Employers should select PPE that provides a level of protection greater than the minimum needed to protect employees from the identified hazards. The appendix advises comparing environmental hazard parameters (like impact velocity or radiation intensity) to PPE capabilities and choosing equipment that ensures adequate, and preferably higher-than-minimum, protection (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Know PPE performance limits and manufacturer's instructions.
• Where hazards are severe, err on the side of higher protection (e.g., use face shields over goggles for severe splash or heat exposures).

Eye or face protection must be used when employees are exposed to potentially injurious light radiation from intense sources like electric arc welding and gas torch cutting. The standard requires protection for "potentially injurious light radiation," and the appendix clarifies this means intense radiant energy such as welding or cutting (1915.153(a) and Shipyard eye and face protection interpretation).

• Ordinary sunlight is not considered "potentially injurious light radiation" for this requirement per OSHA interpretation; the term focuses on intense industrial radiation.
• Use welding helmets, goggles, or shaded lenses that meet shade requirements in 1915.153(a)(4).

Typical shade numbers for electric arc welding are 10–14, and for gas welding typical shades are 4–8 (with cutting and brazing having different recommended ranges). The appendix provides these typical shade ranges and directs compliance with the filter lens shade requirements in 1915.153(a)(4).

• Electric arc welding: typical shades 10–14.
• Gas welding: typical shades 4–8; cutting and brazing have lighter recommended shades as noted in the appendix.

No. Ordinary sunglasses are not adequate for welding or cutting because they do not provide the level of filter protection required for intense radiant energy; welders must use welding helmets, goggles, or shields meeting the shade requirements in 1915.153(a)(4). OSHA's interpretation clarifies that "potentially injurious light radiation" refers to intense sources like arc welding and gas torch cutting, and ordinary sunglasses are not designed for those hazards (Shipyard eye and face protection interpretation).

• Use the darkest shade that still allows you to perform the task safely (appendix note l).
• Always wear primary eye protection under welding helmets per appendix notes (c) and (i).

No; face shields should only be worn over primary eye protection (spectacles or goggles). The appendix explicitly states that face shields are secondary protection and must be used over primary eye protection (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• For severe splash or heat, wear goggles or spectacles with side protection as primary protection, and add a face shield over them.
• This is reiterated in the notes to the eye-and-face protection selection chart.

Employers must ensure that workers who need prescription lenses either use protective devices fitted with prescription lenses or use protective devices designed to be worn over regular prescription eyewear. The appendix explicitly requires protective devices to accommodate prescription needs (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Do not allow workers to perform tasks requiring eye protection without compatible prescription protection.
• Follow manufacturer's fitting instructions to ensure a proper seal and protection.

Contact lens wearers must still wear appropriate eye and face protection in hazardous environments, and employers should recognize that dusty or chemical conditions may pose additional risks to contact lens users. The appendix states that contact lens use does not eliminate the need for proper protective devices (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Ensure protective goggles or shields fit over contact lenses and prevent splash or dust entry.
• Consider prohibiting contact lens use in specific high-risk environments if advised by medical/professional guidance.

Hard hats are selected by the type of protection needed: Class A provides impact and low-voltage electrical protection (proof tested to 2,200 volts), Class B provides impact and high-voltage protection (proof tested to 20,000 volts), and Class C provides impact and penetration protection but conducts electricity and should not be used near electrical hazards. The appendix explains these classes and recommends considering electrical hazards when selecting head protection (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Use Class B when high-voltage exposure is possible; avoid metal (Class C) helmets near live electrical conductors.
• Where falling object hazards exist, head protection must be worn.

A chin strap may be necessary when a hard hat might fall off during work operations, but the strap should break at a reasonably low force to prevent a strangulation hazard. The appendix advises careful fitting and notes that chin straps should break away at a low force for safety (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Follow the manufacturer's fitting instructions when available.
• Balance the need to keep the hat on with preventing entanglement or strangulation risks.

Safety shoes and boots should meet ANSI Z41-1991, provide impact and compression protection, and include additional features like puncture or metatarsal protection when the hazard assessment shows those are necessary. The appendix sets out these selection guidelines for foot protection (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Use puncture-resistant soles where sharp objects may be stepped on.
• Provide metatarsal protection for tasks with roll-over or top-of-foot hazards.

Employers must identify the toxic properties of chemicals, select gloves based on the chemical with the shortest breakthrough time in mixtures, and obtain manufacturer documentation that the gloves meet appropriate test standards. The appendix emphasizes that glove materials vary and that selection must be hazard-specific (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• For mixtures, choose gloves based on the component with the shortest breakthrough time.
• Ensure employees can remove gloves without contaminating skin and consider dexterity and duration of use.

Yes; before purchasing gloves employers should request documentation from the manufacturer showing the gloves meet appropriate test standards for the anticipated hazards. The appendix explicitly recommends obtaining manufacturer test data to verify glove performance (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Keep the documentation with PPE procurement records to support selection decisions.
• If no specific test data exist for a mixture, use the worst-case chemical component to guide selection.

PPE must be inspected, cleaned, and maintained at regular intervals so it continues to provide expected protection, and contaminated PPE that cannot be decontaminated must be disposed of safely. The appendix provides these cleaning and maintenance guidelines (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Schedule regular inspections and cleaning, especially for eye protection where fogging or dirt can impair vision.
• Establish procedures for safe disposal or replacement of PPE contaminated with hazardous substances.

When maintenance workers are exposed to asbestos, employers must provide appropriate supplemental PPE for asbestos hazards in addition to basic PPE, and follow asbestos-specific PPE requirements in 1915.1001. The appendix provides the example that maintenance workers exposed to asbestos must receive supplemental PPE and references the asbestos standard (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Asbestos PPE may include respirators, disposable clothing, and decontamination procedures as required by 1915.1001.
• Ensure removal and disposal procedures prevent secondary exposure.

The appendix lists basic PPE for a welder as: hard hat, welding shield (face), welding gloves, safety glasses, safety shoes, and welding sleeves when welding overhead. This example reflects a hazard assessment of typical welding exposures (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Additional PPE may be required depending on work location (e.g., fall protection when working at height).
• The list is illustrative; employers must perform their own assessments for specific jobs.

For painters, the appendix recommends basic PPE including hard hats, safety glasses, disposable clothing, gloves, and respiratory protection (including airline respirators when working in confined spaces). The appendix highlights that additional PPE may be required depending on hazards like falls or hazardous atmospheres (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Respiratory protection must meet applicable respiratory standards and be chosen based on exposure assessment.
• Confined-space respirator types (e.g., airline respirators) are specified when exposures could exceed limits or in IDLH situations.

Employers are generally required to pay for PPE they must provide to employees under OSHA standards; the OSHA interpretation on PPE payment explains the employer-payment rule and acceptable administrative approaches like deposit systems that do not result in employees bearing the cost. See the OSHA interpretive letter on employer payment for PPE for more detail (Employee PPE payment methods) and the shipyard PPE guidance (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Employers may retain ownership and require return of PPE; if not returned, employers may take reasonable steps to retrieve it or require payment consistent with law.
• Employers cannot shift the cost to employees for PPE that OSHA requires them to provide at no cost.

Yes; a competent person may evaluate exposures using other occupational exposure limits like ACGIH TLVs and specify necessary protections when OSHA has no PEL, provided they are capable of recognizing and evaluating the hazard and specifying protection measures. OSHA's interpretation on competent person responsibilities affirms that competent persons can use recommended OELs where there is no OSHA PEL (Competent person requirements in shipyards) and the appendix recommends designating a qualified person to assess hazards (Non-mandatory Guidelines...).

• Document the basis for protective measures and the OELs relied upon.
• If exposures are serious, implement controls and PPE appropriate to the assessed risk.

Employers should select eye and face protection that provides adequate ventilation without allowing splash entry, and recognize that restricted ventilation inside protectors can cause lenses to fog—requiring frequent cleaning. The appendix notes that protectors should balance ventilation and splash protection (Non-mandatory Guidelines for Hazard Assessment, Personal Protective Equipment (PPE) Selection, and PPE Training Program).

• Consider anti-fog coatings, indirect ventilation, or powered respirators with face shields where fogging is a problem.
• Ensure cleaning procedures are in place to maintain visibility and protection.