Why This Requirement Gets Missed
Every employer knows workers need PPE. Most provide it. Most enforce use. But under OSHA 1910.132(d), you must also have a WRITTEN hazard assessment showing you thought through what PPE is needed and why.
Providing safety glasses isn't enough. You need documentation showing: "In work area X, task Y creates hazard Z, which requires PPE type A."
This is one of the easiest OSHA requirements to complete — and one of the most commonly missed.
What Every PPE Hazard Assessment Includes
1. Workplace/Task Identification
- Company name
- Facility/site name
- Work areas covered
- Tasks covered (specific enough to be useful)
2. Hazard Categories Assessed
Under 1910.132 and 1910.133-138, the categories are:
- Impact — Falling objects, flying debris, projectiles
- Penetration — Sharp objects, pointed tools
- Compression — Rollover, crushing
- Chemical — Splash, spray, contact, inhalation
- Heat/Cold — Temperature extremes, hot surfaces
- Dust — Silica, wood, drywall
- Light/Radiation — Welding arc, UV, laser
- Noise — Continuous or impact >85 dB
- Biological — Bloodborne pathogens, waste
- Electrical — Arc flash, shock, static discharge
3. Body Parts Exposed To Each Hazard
- Head
- Eyes/Face
- Ears/Hearing
- Hands
- Feet
- Respiratory
- Body/Torso
4. PPE Selected For Each Hazard
Not just "wear PPE" — specific PPE meeting specific ANSI/ASTM standards:
- Head — ANSI Z89.1 hard hats (Type I or II, Class C/G/E)
- Eye/Face — ANSI Z87.1 safety glasses/goggles
- Hearing — NRR-rated plugs or muffs
- Hands — task-specific (cut-resistant, chemical-resistant, insulated)
- Feet — ANSI Z41 / ASTM F2413 safety-toe boots
- Respiratory — NIOSH-approved (N95, half-face, full-face, PAPR, SAR)
- Fall protection — ANSI Z359 full body harness
5. Certification Block
Required by 1910.132(d)(2):
- Workplace name and address
- Date of assessment
- Name and signature of person conducting the assessment
- Identification of the document as a certification of hazard assessment
PPE Hazard Assessment Template
Complete 1910.132 assessment template with all hazard categories, body parts, and PPE selection matrix. Editable Word + PDF. Written by a 20-year field pro.
Sample Assessment Entry
Task: Concrete Cutting (Wet or Dry Saw)
Hazards Identified:
- Impact/flying particles (silica dust, concrete chips)
- Dust (respirable crystalline silica per 1926.1153)
- Noise (85-105 dB depending on saw)
- Vibration (hand-arm)
- Chemical (concrete alkalinity on skin)
Body Parts Exposed: Eyes, respiratory, hands, hearing
PPE Required:
- Safety glasses ANSI Z87.1 minimum, face shield preferred
- N95 or half-face respirator (based on 1926.1153 assessment)
- Cut-resistant gloves
- Hearing protection (foam plugs NRR 29+ or muffs)
- Long sleeves and long pants
- Steel-toe boots ASTM F2413
Engineering/Administrative Controls Also In Place:
- Wet cutting when possible (water suppression)
- Ventilation for enclosed cutting
- Job rotation to limit exposure duration
Common PPE Assessment Mistakes
- Not written — "We provide PPE" isn't enough. Must be documented.
- Not certified — Missing the signature/date/workplace block.
- Too generic — "Construction has hazards, wear PPE" isn't an assessment.
- Missing task-specific hazards — Assessment done for the site but not for specific hazardous tasks (silica cutting, welding, chemical handling).
- Not updated — Assessment done in 2015, still on file, current work is completely different.
- No worker training on it — Assessment exists but workers never trained on why they're wearing what they're wearing.
Training Documentation Required Too
Under 1910.132(f), workers must be trained on:
- When PPE is necessary
- What PPE is necessary
- How to properly put on, take off, adjust, and wear PPE
- The limitations of the PPE
- Proper care, maintenance, useful life, and disposal
Each worker signs off that they received training. Signed rosters kept 3+ years.
Frequently Asked Questions
Is a written PPE hazard assessment legally required?
What must be included in a PPE hazard assessment?
Who conducts the PPE hazard assessment?
How often must the PPE assessment be updated?
What are the fines for missing PPE assessments?
PPE Compliance Bundle
Written hazard assessment + PPE training records + toolbox talk + inspection checklist. Full PPE program in one download. From $19.99.
Article by Anthony Forbes. 20 years field experience. All templates written by Anthony directly.