Employer’s Guide to OSHA PPE Standards

By Rehan Iqbal

Personal protective equipment (PPE) is vital to workplace safety when hazardous conditions are present. In most cases, employers are obligated to provide workers with PPE when necessary. As these regulations can be confusing and complex, this guide summarizes your key obligations as an employer in plain English.

What is PPE and Why is it Necessary?

Controlling hazards at their source is by far the most effective way to reduce the risk of injury, loss, and legal liability. When controlling hazards is not enough to reduce risk, personal protective equipment is required.

Providing your workers with PPE drastically reduces their exposure to injury, illness, or death due to workplace hazards.

PPE may refer to:

Eyewear: Special safety glasses needed when working with chemicals or other similar hazards.
Footwear: Special footwear is required to protect employees from heavy machinery, falling objects, puncture hazards, etc.
Hardhats: Hardhats are almost universally required on all construction sites.
Gloves: Hazardous chemicals or extreme temperatures may require protective gloves.
Hearing protection: In especially loud working conditions, earplugs will prevent severe hearing damage or loss of hearing.

This is not an exhaustive list by any means.

How Employers Benefit from PPE

Safety comes first on every job site. Personal protective equipment saves employees in dangerous conditions from agony, injury, loss of working ability, and even death.

However, employers also benefit from PPE. By providing your employees with PPE, you:

Reduce lost work hours: Countless man-hours are lost to injury every year, costing companies thousands in damages. PPE will keep your employees healthy and productive.
Improve productivity: Extreme or hazardous conditions drastically reduce productivity (imagine trying to work in extreme cold). PPE increases productivity by eliminating barriers to working in extreme conditions.
Eliminate legal liability: Nothing is more damaging than injury lawsuits or government fines (the maximum fine has been raised to over $129,000!). Follow regulations and you will be fine.
Improve morale: Nothing is worse for productivity than a toxic workplace. Providing safety equipment shows you put employee safety first and increases morale in the workplace.

Your Obligations as an Employer

Employer responsibilities range from assessment and training to maintenance and review. Basically, you are responsible for ensuring every facet of the safety of your workplace.

Your obligations include:

Conducting a “hazard assessment.” This will identify threats in your workplace.
Providing PPE to employees based on those hazards.
Training your employees to use their PPE correctly.
Maintaining PPE as well as the safety of your workplace.
Periodically reviewing your PPE and safety conditions, updating where necessary.

Don’t worry, you aren’t alone in this. Your employees must help too. They are obligated by OSHA to attend training, properly wear their PPE, and to care for it as best they can according to instructions.

Employers Must Pay for PPE

According to new the most recent OSHA standards (2008), employers must pay for any personal protective equipment used to comply with OSHA safety standards.

That means ANY PPE for OSHA standards must be provided by you completely.

Employers are no longer allowed to make employees purchase their own PPE (with limited exceptions. We cover those further below). However, an employee may VOLUNTARILY request to wear their own PPE (perhaps a pair of boots they love from a previous job). In this case, you are responsible for assessing whether or not the equipment is up to standard and will keep them safe from hazards on your job site.

Common examples of PPE you must pay for include:

Non-prescription protective eyewear
Rubber boots with steel toes
Hardhats
Goggles or face shields
Welding PPE
Full firefighting gear
Earmuffs

Employers ARE NOT OBLIGATED to Pay for:

Exemptions to OSHA’s standards are rare but usually apply to items that are considered “everyday” items or items worn by employees in non-work situations. For example:

Non-specialty footwear: Regular steel-toed boots ARE EXEMPT from OSHA standards because these are typically worn by employees outside of the workplace or taken from job to job.
Everyday clothing: Long sleeve shirts, shorts, street shoes, or regular work boots.
Items used as protection from regular weather: Regular winter jackets, skin creams, raincoats, ordinary sunglasses, or sunscreen are not solely for the workplace or necessary in most cases. They are therefore exempt.

Other exempt items include miscellaneous or unproven items such as lifting belts. Also, if the employee intentionally damages their PPE or does not follow regulations, they are obligated to replace it.

What is ASTM? And What Should Employers Know About ASTM Footwear?

The American Society for Testing and Materials publishes safety standards for work wear, including work boots (the most common and important form of PPE). When purchasing work boots for employees, it’s helpful to understand what their markings mean. They will serve as guidelines and help you narrow your search down to only OSHA-compliant materials.

Know these signs and you’ll be able to quickly tell how safe a boot is (and whether or not its suitable for your work environment):

Green Triangle: Puncture resistant (grade 1) boots suitable for construction and heavy industries (impact to 125 joules).

Yellow Triangle: Puncture resistant (grade 2) boots suitable for light industries (90 joules).

Red Square (and black C): This means the boots are electrically conductive and suitable for low voltage hazards.

Green Fir Tree and Light Background: Protects against chainsaws.

White Square and Omega Symbol: Suitable for live electrical hazards.

As an employer, your first duty is to protect the health and safety of your workforce. OSHA standards clearly dictate what is and is not your responsibility on the job site. Fines and penalties are steep, so be sure to follow the regulations closely. PPE is not an expense, it is an investment in your workforce. Use this guide to understanding PPE, your responsibilities, and which footwear to provide employees according to your workplace dangers.