OSHA Instruction STD 1-6.6 June 16, 1995 Directorate of Compliance Programs
Subject: Inspection Guidelines for 29 CFR 1910. Subpart I, the revised
Personal Protective Equipment Standards for General Industry
A. Purpose. This directive provides inspection assistance related
to Personal Protective Equipment (29 CFR 1910. Subpart I) to assist CSHOs
performing inspections in General Industry. The revised (PPE) standards
provide guidance for the selection and use of PPE as well as clearer
requirements that are performance-orientated, where appropriate.
B. Scope. This guide applies OSHA-wide.
C. Action. Regional Administrators and Area Directors shall ensure
that CSHO's performing inspections in General Industry are aware of this
D. Application. OSHA has revised portions of the general industry
safety standards addressing personal protective equipment (PPE). The revised
standards include those containing general requirements for all PPE
(1910.132) and standards that set design, selection, and use requirements for
specific types of PPE (eye, face, head, foot and hand).
New paragraphs (d),(e),and (f) (containing requirements covering
equipment selection, defective and damaged equipment, and training,
respectively) have been added to 1910.132. Also, a new section (1910.138)
has been added to this Subpart to address hazards to the hands.
Non-mandatory Appendix A, References, and Appendix B, addressing
Hazard Assessment and PPE Selection, have been added to this Subpart to
provide additional guidance to employees and employers with regard to PPE for
eye, face, head, foot, and hand hazards.
E. Effective date of Requirements. The effective date for the
revised personal protective equipment standard was July 5, 1994, except for
paragraphs 1910.132(d), Hazard Assessment and Equipment Selection and
1910.132(f), Training, which were stayed until October 5, 1994.
F. Background. The OSHA standards for personal protective equipment
(PPE) are contained in Subpart I of OSHA's general industry standards. The
original standards were adopted in 1971 from established Federal standards
and national consensus standards.
In developing a proposed revision of Subpart I, the Agency performed
a comprehensive review of the PPE standards. This review revealed several
limitations and concerns with respect to these standards. First, OSHA
determined that many of the existing PPE standards were outdated since they
reflected knowledge and practices regarding PPE as they existed in the late
1960's and early 1970's.
Also, OSHA had obtained injury data and technical reports which
showed that injuries were occurring to employees who were wearing PPE as well
as to those employees who were not wearing PPE. This indicated that, in some
cases, significant improvements in PPE design, acceptance, and use were
Based on these concerns, OSHA developed a revision to the PPE
standards. OSHA revised the safety standards for eye and face protection
(1910.133); head protection (1910.135); and foot protection (1910.136) by
referencing the latest editions of the corresponding standards published by
the American National Standards Institute (ANSI). The revised safety
standard for eye and face protection (1910.133) also changed provisions for
eye and face protection. For example, it now addresses filter lenses for
protection against radiant energy.
The provisions of existing 1910.134 (which cover respiratory
protection) are the subject of separate rulemaking actions and are not
addressed in the revised standard.
The general requirements of existing 29 CFR 1910.132 were revised by
adding provisions that: (1) require employers to select appropriate PPE
based on the hazards present or likely to be present in the workplace; (2)
prohibit the use of defective or damaged PPE; and (3) require that employees
be trained so that each affected employee can properly use the assigned
G. Inspection Guidelines. The compliance safety and health officer
(CSHO) shall determine whether the employer is in compliance with the revised
The CSHO shall specifically determine whether employers have assessed the
workplace to determine if hazards are present, or likely to be present, which
necessitate the use of personal protective equipment.
1. Inspections of workplaces subject to the revised personal
protective equipment standard shall be conducted by CSHO's in accordance with
the Field Inspection Reference Manual (FIRM).
2. The CSHO shall evaluate employer's compliance with the specific
requirements of the personal protective equipment standards. The following
guidance provides a general framework to assist the CSHO during inspections
of workplaces involving personal protective equipment.
3. The CSHO shall verify that the employer has conducted a
workplace hazard assessment, and has a written certification that identifies
the workplace evaluated, the person certifying that the evaluation has been
performed, and the dates of the hazard assessment. The document must be
identified as a certification of hazard assessment.
a. Employers who have performed appropriate hazard assessments
of their worksites prior to July 5, 1994, conforming to the requirements of
the standard 29 CFR 1910.132(d), may rely upon such hazard assessments as
compliance with the standard. (Grandfathering of hazard
b. An employer may also rely upon a hazard assessment
conforming to 29 CFR 1910.132(d) that a previous employer had conducted for
the worksite prior to July 5, 1994, provided that the job conditions have not
substantially changed. (Grandfathering of hazard assessments)
c. If an employer relies upon a hazard assessment that it or
another employer conducted prior to the standard's effective date, the
certification (1910.132(d)(2)) may contain the date the employer determined
that the prior hazard assessment was adequate rather than the date(s) of the
4. The CSHO shall determine if the employer has selected and is
having each affected employee use the types of PPE that will protect the
affected employee from identified hazards, has communicated selection
decisions to each affected employee, and has selected PPE that properly fits
each affected employee.
5. The CSHO shall determine if the employer is using defective or
damaged personal protective equipment. Defective or damaged personal
protective equipment shall not be used.
6. The CSHO shall evaluate the employer's training programs to
determine whether the programs meets the revised personal protective
equipment standards requirements. The CSHO shall determine if employees are
trained to know at least the following:
a. When PPE is necessary;
b. What PPE is necessary;
c. How to properly don, doff, adjust, and wear
d. The limitations of the PPE;
e. The proper care, maintenance, useful life and disposal of
a. An employer may rely upon training conforming to 29 C.F.R.
1910.132(f) that a previous employer had provided an employee, or the
knowledge and ability to use PPE properly that an employee has gained through
his or her prior experience, in determining if an employee has the requisite
knowledge and skill.
7. The employer shall verify that each affected employee has
received and understands the required training through a written
certification that contains the name of each employee trained, the dates of
training, and that identifies the subject of the certification.
a. If the employer relies upon training provided by another
employer to an employee prior to the standard's effective date, or relies
upon the knowledge and ability gained by an employee through his or her
experience, the certification may contain the date that the employer
determined that the prior training, or the employee's knowledge and ability,
was adequate rather than the date of the actual training.
b. The employer may use any convenient format that contains the
required information. It may be a single certification for all of its
employees, for an identified group of its employees (based on a common task,
type of exposure, or other appropriate characteristic), or for one or more
named employees, provided the document contains the required
c. The certification document need only to indicate that it is
a certification of training for the PPE being used by the employee. It need
not identify the specific category (e.g., eye and face protection), type
(e.g., goggles), or model of PPE covered by the certification.
H. General Inspection Procedures. The CSHO shall determine whether
the following items are in compliance with the revised standard:
1. Eye and face protection 1910.133. Each affected employee
shall use appropriate eye or face protection when exposed to eye or face
hazards from flying particles, molten metal, liquid chemicals, acids or
caustics liquids, chemical gases or vapors, or potentially injurious light
a. Detachable side protectors (e.g. clip-on or slide-on side
shields) meeting the pertinent requirements of this section are
b. The CSHO shall assure that each employee who wears
prescription lenses while engaged in operations that involve eye hazards is
wearing eye protection that incorporates the prescription in its design, or
protection that can be worn over the prescription lenses without disturbing
the proper position of the prescriptive lenses.
c. The CSHO shall assure that each affected employee using
protective eyewear with filter lenses has eyewear with a shade number
appropriate for the work being performed for protection from injurious light
d. Protective eye and face devices purchased after July 5, 1994
shall comply with ANSI Z87.1-1989, "American National Standard Practice for
Occupational and Educational Eye and Face Protection", or shall be
demonstrated by the employer to be equally effective.
Eye and face protective devices purchased before July 5, 1994
shall comply with the ANSI "USA Standard for Occupational and Educational Eye
add Face Protection, Z87.1-1968, or shall be demonstrated by the employer to
be equally effective.
2. Head Protection 1910.135. Each affected employee shall
wear protective helmets when working in areas where there is potential for
injury to the head from falling objects. Also, protective helmets shall be
designed to reduce electrical shock hazards when employees are working near
exposed electrical conductors.
3. Foot Protection 1910.136. Each affected employee shall
wear protective footwear when working in areas where there is a danger of
foot injuries due to falling and rolling objects, objects piercing the sole,
and where such employee's feet are exposed to electrical hazards.
4. Electrical Protective Equipment 1910.137. Each affected
employee shall use electrical protective equipment such as insulating
blankets, matting, covers, line hose, gloves, and sleeves made of rubber when
exposed to electrical hazards.
5. Hand Protection 1910.138. Employers shall select and
require employees to use appropriate hand protection when employee's hands
are exposed to hazards such as those from skin absorption of harmful
substances; severe cuts or lacerations; severe abrasions; punctures; chemical
burns; thermal burns; and harmful temperature extremes.
I. Employer Obligation to Pay for Personal Protective Equipment.
The personal protective standards 29 CFR 1910.132 through 1910.138 establish
the employer's obligation to provide personal protective equipment to
employees. In particular, 29 CFR 1910.132(a) states as follows:
"Protective equipment, including personal
protective equipment for eyes, face, head and extremities,
protective clothing, respiratory devices and protective shields and barriers,
shall be provided, used and maintained in a sanitary and reliable condition
wherever it is necessary by reasons of hazards of process or environment,
chemical hazards, radiological hazards or mechanical irritants encountered in
a manner capable of causing injury or impairment in the function of any part
of the body through absorption, inhalation or physical
The "worker-provided" clause in the general industry PPE
standard, (1910.132(b), and also in the construction industry standard,
1926.95(b), has raised questions as to when employers are required to pay for
PPE, as well as "provide" it.
1. In order to accommodate those work situations where it is
customary for workers to provide their own PPE without compromising employee
protection, 29 CFR 1910.132(b) provides that the employer must assure the
adequacy of such equipment.
2. The PPE standard requires employers to provide and to pay for
personal protective equipment required by the company for the worker to do
his or her job safely and in compliance with OSHA standards. Where equipment
is personal in nature and may be used by workers off the job, the matter of
who pays for the PPE may be left to labor-management negotiations.
Examples of PPE that would not normally be used away from the
worksite include, but are not limited to: welding gloves, wire mesh gloves,
respirators, hard hats, specialty glasses and gloves (e.g., designated for
laser or ultraviolet radiation protection), specialty foot protection (such
as metatarsal shoes and linemen's shoes with built in gaffs), face shields
and rubber gloves, blankets, cover-ups, hot sticks and other live-line tools
used by power generation workers.
Examples of PPE that is personal in nature and often used away
from the worksite include non-specialty safety glasses, safety shoes, and
cold-weather outer wear of the type worn by construction workers. However,
shoes or outwear subject to contamination by carcinogens or other toxic or
hazardous substances which cannot be safely worn off-site must be paid for by
the employer. Failure of the employer to pay for PPE that is not personal
and not used away from the job is a violation of 29 CFR 1910.132(a) and shall
J. Federal Program Change. This is a Federal Program change which
impacts State programs.
1. The Regional Administrator (RA) shall ensure that this change is
promptly forwarded to each State designee using a format consistent with the
Plan Change Two-way Memorandum in Appendix P, State Plan Policies and
Procedures Manual (SPM).
2. The RA shall explain the content of this change to the State
designee as required.
3. The State shall respond to this change within 70 days in
accordance with paragraph I.1.a. (2)(a) and (b), Chapter III of the
4. The State's acknowledgment shall include (a) the State's plan to
adopt and implement an identical change (b) the State's plan to develop an
alternative, which is as effective, or (c) the reasons why no change is
necessary to maintain a program which is as effective. The State shall submit
a plan supplement within six months in accordance with I.1.a.(3)(c), Chapter
III of the SPM.
5. The RA shall advise the State designees that they consult with
the OSHA regional Office for technical assistance and questions relating to
6. The RA shall review policies, instructions and guidelines issued
by the State to determine that this change has been communicated to State
Joseph A Dear Assistant Secretary
Distribution: National, Regional, and Area Offices All Compliance Officers
State Designees NIOSH Regional Program Directors 7(c)(1) Consultation Project
Managers OSHA Training Institute