In general industry, 29 CFR 1910.132(d)(2) requires the employer to verify that a workplace hazard assessment was done, through a written record identifying four things: the workplace evaluated, the person attesting to the evaluation, the date or dates, and the document itself. That is the whole documentary obligation - and it is narrower, and applies to fewer types of PPE, than most safety manuals assume.
What 1910.132(d) covers - and what it does not
Start with the carve-out, because it is the single most misapplied paragraph in Subpart I. 1910.132(g) reads: "Paragraphs (d) and (f) of this section apply only to §§ 1910.133, 1910.135, 1910.136, 1910.138, and 1910.140. Paragraphs (d) and (f) of this section do not apply to §§ 1910.134 and 1910.137."
| Equipment | Standard | Covered by (d) and (f)? |
|---|---|---|
| Eye and face protection | 1910.133 | Yes |
| Head protection | 1910.135 | Yes |
| Foot protection | 1910.136 | Yes |
| Hand protection | 1910.138 | Yes |
| Personal fall protection | 1910.140 | Yes |
| Respiratory protection | 1910.134 | No - own written program, medical evaluation, fit testing |
| Electrical protective equipment | 1910.137 | No - own requirements |
| Hearing protection | 1910.95 | Not under 132(d) - governed by the noise standard |
Everything else about PPE still flows from 1910.132(a), which is broad: protective equipment "shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants."
The four items the written record must identify
Paragraph (d)(2) is one sentence. The employer shall verify that the required workplace hazard assessment has been performed through a written record that identifies:
- The workplace evaluated. Name the actual area or operation - "Bay 3, weld cells 1-4," not "Manufacturing."
- The person attesting that the evaluation has been performed. A name, not a department.
- The date or dates of the hazard assessment. Plural in the text, because a walk-through can span several visits.
- An identification of the document as a hazard assessment record. A title on the page. This is the item people leave off, and it is the easiest one to fix.
How to run the assessment: the Appendix B method
1910.132(d)(1) tells you to assess the workplace but not how. The note under it points to Appendix B to Subpart I, which is non-mandatory but is the method OSHA itself describes as complying. Its four steps are survey, sources, organize, analyze.
Appendix B opens with a warning worth keeping in front of a client who wants to solve everything with gloves: "PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound manufacturing practices."
The seven basic hazard categories
During the walk-through survey, Appendix B says consideration should be given to: impact, penetration, compression (roll-over), chemical, heat, harmful dust, and light (optical) radiation. Seven, no more - it is a short enough list to hold in your head while walking.
The ten sources to look for
| # | Source to observe |
|---|---|
| a | Sources of motion - moving tools, machine elements, particles, or people colliding with stationary objects |
| b | Sources of high temperatures - burns, eye injury, ignition of protective equipment |
| c | Types of chemical exposures |
| d | Sources of harmful dust |
| e | Sources of light radiation - welding, brazing, cutting, furnaces, heat treating, high intensity lights |
| f | Sources of falling objects, or potential for dropping objects |
| g | Sources of sharp objects that might pierce the feet or cut the hands |
| h | Sources of rolling or pinching objects that could crush the feet |
| i | Layout of the workplace and location of co-workers |
| j | Any electrical hazards |
Appendix B adds one more input that costs nothing and is usually skipped: "injury/accident data should be reviewed to help identify problem areas." Then organize the data, and analyze it - for each basic hazard, determine "the type, level of risk, and seriousness of potential injury," and consider "the possibility of exposure to several hazards simultaneously."
Selection, fit and training
Once hazards are identified, (d)(1) imposes three duties in sequence: select and have each affected employee use PPE that protects against the hazards identified, communicate the selection decisions to each affected employee, and select PPE that properly fits each affected employee.
Appendix B's selection guidance goes a step further than "greater than zero": select equipment "which ensures a level of protection greater than the minimum required to protect employees from the hazards," then fit the user and give instructions on care and use, making sure end users know all warning labels and limitations. On fit it is blunt - "PPE that fits poorly will not afford the necessary protection" - and it flags eye protection sealing to the face and helmets staying on the head, with the practical note that a chin strap "should break at a reasonably low force" to prevent a strangulation hazard.
Training under 1910.132(f)(1) has five required subjects: when PPE is necessary, what PPE is necessary, how to properly don, doff, adjust and wear it, its limitations, and its proper care, maintenance, useful life and disposal. Two clauses people miss:
- (f)(2) requires a demonstration. Each employee must demonstrate understanding and the ability to use the PPE properly before being allowed to perform work requiring it. A signed roster is not a demonstration.
- (f)(3) requires retraining when workplace changes or PPE changes make previous training obsolete, or when an employee's knowledge or use of assigned PPE shows they have not retained the skill.
Construction plays by different rules
On a construction site, 1910.132 does not apply. The obligations come from 1926.28(a) - "The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions" - and from Subpart E, principally 1926.95.
| Obligation | General industry (1910) | Construction (1926) |
|---|---|---|
| Assess the workplace for PPE needs | Required, 1910.132(d)(1) | No equivalent clause; the duty is implicit in 1926.28(a) |
| Written record of the assessment | Required, 1910.132(d)(2) | Not required |
| PPE must properly fit each employee | Required, 1910.132(d)(1)(iii) | Required, 1926.95(c)(2) - added December 12, 2024, effective January 13, 2025 |
| Five-subject PPE training | Required, 1910.132(f) | No general clause; specific standards impose their own (for example 1926.503 for fall protection) |
| Employer pays, with exceptions | 1910.132(h) | 1926.95(d) - same structure and same exceptions |
The fit rule is the recent change worth flagging to any GC still working from an old manual. Until January 13, 2025, construction's PPE standard had no explicit fit requirement while general industry and shipyards did; OSHA's final rule closed that gap by adding 1926.95(c)(2), which requires PPE to be "selected to ensure that it properly fits each affected employee." The practical target of the rule is well documented in the rulemaking record: equipment sized for an average male body that leaves smaller workers - and larger ones - in ill-fitting harnesses, gloves and high-visibility clothing.
Who pays for PPE
The default is unambiguous: PPE used to comply with Part 1910 (or Part 1926) "shall be provided by the employer at no cost to employees." The exceptions are a closed list, and the same in both parts:
- Non-specialty safety-toe footwear and non-specialty prescription safety eyewear - only if the employer permits those items to be worn off the jobsite.
- Metatarsal shoes or boots - where the employer provides metatarsal guards and the employee, at their own request, chooses boots with built-in protection instead.
- Everyday clothing - long-sleeve shirts, long pants, street shoes, normal work boots.
- Ordinary weather gear - winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, sunscreen, skin creams, used solely for protection from weather.
- Replacements are on the employer - "except when the employee has lost or intentionally damaged the PPE."
Two further points. An employee may use adequate PPE they own, and the employer need not reimburse it - but the employer "shall not require an employee to provide or pay for his or her own PPE" outside the listed exceptions. And where another OSHA standard has its own payment provision, that standard's provision prevails.
Five ways the assessment goes wrong
- One document for the whole facility. (d)(2) requires the workplace evaluated to be identified. A site-wide sheet identifies nothing.
- PPE listed by job title instead of by hazard. "Welders: shade 10" is a conclusion without an assessment. The record should show the hazard that drove the choice.
- Assuming PPE is the control. Appendix B puts guards and engineering controls first. An assessment that never asks whether the hazard could be removed is skipping the cheaper answer.
- Treating respirators and hearing protectors as covered. 1910.132(g) excludes 1910.134; 1910.95 governs hearing protection. Both need their own programs.
- Ordering by the case, in one size. Fit is a requirement in both parts now. Stocking one glove size and one harness size is a citable condition, not a purchasing preference.
Bottom line
- General industry: assess the workplace, then keep a written record naming the workplace, the person, the date and the document. Four items.
- Use the Appendix B method - walk-through, seven hazard categories, ten sources, plus your injury records - and write down what you found, not just what you bought.
- 1910.132(d) and (f) do not reach respirators, electrical protective equipment or hearing protection. Those live in 1910.134, 1910.137 and 1910.95.
- Construction has no written-assessment clause, but since January 13, 2025 it does have an explicit fit requirement at 1926.95(c)(2).
- The employer pays, minus a short closed list of exceptions - and pays for replacements unless the employee lost or wrecked the item on purpose.