OSHA hazard assessment requirements for PPE and certification.

• + A hazard assessment is a prerequisite to PPE selection, because you cannot pick PPE correctly without first evaluating the hazards.
• + The assessment must be certified in writing, identifying the workplace, the certifier, and the date.
• + OSHA does not require a separate form per employee, but it does require evidence that the evaluation occurred.
• + Hazard assessments support multiple programs, and PPE, respiratory protection, and hearing conservation all depend on a defensible exposure evaluation.

Under 29 CFR 1910.132(d)(1), the employer must assess the workplace to determine whether hazards are present, or are likely to be present, that necessitate the use of personal protective equipment. If such hazards exist, the employer must select and require appropriate PPE, communicate the selection decisions to affected employees, and select PPE that properly fits each affected employee.

A defensible assessment includes a walk through the work areas, a review of each task, and an evaluation of impact, penetration, compression, chemical, heat, harmful dust, light radiation, and other hazard categories. The assessment is a documented process, and its output determines every later PPE decision.

1910.132(d)(2) requires the employer to verify that the required workplace hazard assessment has been performed through a written certification. The certification must identify the workplace evaluated, identify the person certifying that the evaluation has been performed, and give the date(s) of the hazard assessment.

OSHA does not prescribe a specific form, and a single document covering multiple areas is acceptable as long as it contains all three required elements and accurately reflects the spaces and tasks that were evaluated.

Other standards depend on the hazard assessment. Respiratory Protection (1910.134) depends on a determination of airborne hazards, and the Occupational Noise standard (1910.95) depends on exposure monitoring. Substance-specific standards such as Hazard Communication (1910.1200) require evaluation of chemical hazards, so a weak hazard assessment weakens every program that relies on it.

For industrial-hygiene exposures, a qualitative walkthrough is often only the starting point, and air sampling, noise dosimetry, or other quantitative monitoring may be needed to characterize the exposure in a defensible way and select controls.

Inspectors typically ask to see the written certification and then test whether it matches the workplace. If the certification names work areas that have changed, omits a process that obviously requires PPE, or cannot identify who performed the evaluation, the assessment is treated as not having been properly performed.

The most common finding is the absence of a documented assessment that justifies the PPE in use, or the use of PPE that the assessment never evaluated.

29 CFR 1910.132

PPE general requirements and hazard assessment

29 CFR 1910.132(d)

Hazard assessment and equipment selection

29 CFR 1910.133

Eye and Face Protection

29 CFR 1910.134

Respiratory Protection

29 CFR 1910.95

Occupational Noise Exposure

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