Personal protective equipment is often the most visible part of a safety program — hard hats, safety glasses, gloves, high-visibility vests. But OSHA doesn’t just require that PPE be worn; it requires that employers first prove they’ve thought about why. That proof takes the form of a written hazard assessment, and it’s one of the most commonly overlooked steps in an otherwise reasonable PPE program.

The Legal Requirement

Under 29 CFR 1910.132(d), employers 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 hazards exist, the employer must select PPE that properly fits each affected employee and communicate selection decisions, and must verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying it was performed, and the date of the assessment.

That certification requirement means a hazard assessment that exists only in someone’s memory doesn’t satisfy the standard, even if the PPE selections themselves are correct.

Step 1: Walk the Workplace Systematically

A defensible hazard assessment starts with a structured walkthrough of each work area, evaluating exposure to:

• Impact and penetration hazards — falling or flying objects, sharp edges
• Compression hazards — rolling or pinching objects
• Chemical hazards — splashes, fumes, dusts, mists
• Heat and cold hazards — molten materials, cryogenic exposure
• Harmful dust — respirable particulates
• Light (optical) radiation — welding arcs, lasers, UV sources
• Electrical hazards — arc flash, shock

OSHA’s non-mandatory appendix, 1910 Subpart I Appendix B, provides a useful checklist format many safety professionals use as the backbone of their walkthrough documentation.

Step 2: Follow the Hierarchy of Controls Before Reaching for PPE

A frequent compliance and credibility gap: treating PPE as the first line of defense instead of the last. NIOSH’s hierarchy of controls places elimination, substitution, engineering controls, and administrative controls above PPE for good reason — PPE depends on correct fit, consistent use, and maintenance to work at all, while engineering controls protect workers passively. A hazard assessment that jumps straight to “employees will wear X” without documenting why elimination or engineering controls weren’t feasible is both a weaker safety program and a more exposed one in an inspection.

Step 3: Select PPE to the Hazard, Not the Catalog

Once hazards are identified, PPE selection should map to the specific exposure, not a generic default. Eye and face protection selection, for example, has its own detailed standard at 1910.133, and eye/face protection citations were among OSHA’s top 10 most-cited standards in FY2025, underscoring how often this specific selection step gets missed even when general PPE policies exist on paper.

Step 4: Fit, Train, and Document

A hazard assessment isn’t complete once equipment is chosen. Employers must also:

1. Ensure PPE fits each individual employee properly — a poorly fitted respirator or glove can be functionally equivalent to no PPE at all.
2. Train employees on 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, per 1910.132(f).
3. Document that training with employee certification.
4. Reassess whenever a new process, material, or piece of equipment is introduced.

Reassessment Triggers

A hazard assessment isn’t a one-time document. Common reassessment triggers include new machinery or processes, incident or near-miss investigations that reveal an unaddressed exposure, changes in raw materials or chemicals, and OSHA standard updates. Employers who treat their hazard assessment as a living document — reviewed on a set schedule and after any relevant change — build a program that holds up under both real-world conditions and regulatory scrutiny.

The Bottom Line

The written hazard assessment is the foundation that everything else about a PPE program rests on. Skipping it, or treating it as a formality, leaves both workers and employers exposed — workers to hazards that were never properly evaluated, and employers to citations for a paperwork gap that’s straightforward to close.

Sources & Further Reading

• OSHA, 1910.132 — Personal Protective Equipment, General Requirements
• OSHA, Personal Protective Equipment (PPE) Assessment
• OSHA, 1910 Subpart I Appendix B — Nonmandatory Compliance Guidelines for Hazard Assessment
• NIOSH, Hierarchy of Controls