PPE Program: The Hazard Assessment OSHA Actually Checks
Updated July 23, 2026
OSHA’s PPE rules, 29 CFR 1910.132 through 1910.138 and 1926 Subpart E on construction sites, require you to assess the workplace for hazards, select PPE that matches them, and train employees to use it. One piece must be in writing: the hazard assessment certification under 1910.132(d), a document that identifies the workplace evaluated, the person certifying, and the date. A PPE program is that assessment plus the selection, training, and replacement rules built around it.
What 1910.132 requires, step by step
- ✓ Assess the workplace to determine if hazards are present that require PPE
- ✓ Certify the assessment in writing: the workplace evaluated, the certifier, and the date
- ✓ Select PPE that properly fits each affected employee and communicate the selections
- ✓ Train each employee: when PPE is necessary, what kind, how to put it on and adjust it, its limitations, and its care
- ✓ Retrain when the workplace changes, the PPE changes, or an employee shows they did not retain the training
- ✓ Replace damaged or defective PPE; defective equipment must not be used
- ✓ Pay for required PPE, with narrow exceptions covered below
The standards by body part
| Protection | General industry | Construction | Typical trigger |
|---|---|---|---|
| Eye and face | 1910.133 | 1926.102 | Cutting, grinding, chipping, chemical splash |
| Head | 1910.135 | 1926.100 | Overhead work, falling object exposure, low clearances |
| Foot | 1910.136 | 1926.96 | Falling or rolling materials, puncture hazards |
| Hand | 1910.138 | Selected per the hazard assessment | Cuts, abrasion, chemicals, vibration |
| Hearing | 1910.95 | 1926.101 | Saws, grinders, powder-actuated tools, equipment noise |
| Respiratory | 1910.134 (its own written program) | 1910.134 applies | Silica tasks, welding in enclosed spaces, spray finishing |
How to do the hazard assessment
Walk the work task by task and record what can strike, cut, burn, splash, or irradiate each part of the body: impact, penetration, compression, chemical, heat, harmful dust, and light radiation are the categories OSHA suggests. Match each finding to the PPE that controls it, then sign and date the certification.
You do not need software for this. The free printable PPE hazard assessment form gives you the certification format, and the PPE hazard assessment builder walks you through it hazard by hazard and outputs the finished document.
Who pays for PPE
The employer pays for required PPE. The exceptions are narrow: non-specialty safety-toe footwear and non-specialty prescription safety eyewear the employer allows workers to wear off the job, everyday clothing, and ordinary weather gear. If the boot or the glove is required for the task and stays specialized to it, the company buys it.
The program document reviewers ask for
GCs and prequal portals ask for a written PPE program: the assessment, the selections by task, the training records, and the replacement policy in one document. TailgateDocs generates a Written Safety Program built for your trade for $149, with every citation checked against a verified OSHA standards table before delivery, and free revisions within 24 hours if a reviewer asks for changes.
Common questions
▸Does OSHA require a written PPE program?
The standard requires one written document: the hazard assessment certification under 1910.132(d). In practice, GCs and prequal reviewers ask for a full written PPE program, and the assessment is the piece an OSHA inspector asks to see.
▸How often does the hazard assessment need to be updated?
No fixed interval is set. Reassess when tasks, equipment, or materials change, and after any injury that PPE should have prevented. A certification dated years before your current scope of work reads as stale to a reviewer.
▸Do respirators belong in the PPE program?
Respirators have their own written program requirement under 1910.134, with medical evaluations and fit testing. Reference it from the PPE program, but keep it as its own document so each stands on its own in review.
▸Does my employer have to pay for my safety boots?
Usually yes. The exception is non-specialty safety-toe footwear the employer lets you wear off the job. Metatarsal boots or other specialized footwear required for the task are on the company.
Official sources
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