OSHA PPE Assessment Question
How often is OSHA looking for the PPE Hazard Assessment described in 1910.132 (d)(2) to be completed? I don’t see any guidance on frequency in the website’s PPE Training, in the Letters of Interpretation, or past Settlement Agreements.
Comments (4)
It's required for all tasks, so the frequency will vary. If it's a fixed task that doesn't change (e.g., operating a bench grinder, using an overhead crane, etc.), then it's a "one and done" with a periodic review to ensure nothing has changed. If your tasks change daily (e.g., field service employees), they may be doing their PPE hazard assessments each day or at each different job.
How you document it will also look differently. We have a standard PPE Hazard Assessment form that we use for "fixed" tasks that meets all of the certification requirements mentioned in 1910.132, but if it's a field task, it coud be completed via a JSA, JHA, risk assessment, or other similar form as long as it meets all of the "certification" requirements mentioned in 1910.132. For example, if you're performing any electrical work and want to comply with NFPA 70E, they have you do an electric shock and arc flash risk assessment each time you work on the equipment, and they also tell you what to look for you in your assessments.
In general, you need to have some form of periodic review schedule (which will be site-specific) so that you can ensure these assessments are being reviewed and verified for accuracy and compliance.
Basically OSHA will require an update on anything when "any changes have occurred". This puts the onus on the employer to stay current on any changes that would require a change to PPE for this instance.
I often see the PPE assessment integrated as part of the JSA in manufacturing environments, and included in the work instructions and/or written job procedures. It’s typically reviewed during any process or equipment change to ensure ongoing relevance and accuracy, and added to the annual review process to ‘double-check’ any changes, or need to revisit, before being formally filed, especially if you are ISO 45001. Some tasks do require a PPE assessment, as well as a JSA/JHA prior to individual tasks as well, which is included in some of our “permit required” tasks.
On my understanding OSHA only provides a guidance, (standard ), it's up to the companies to make changes or upgrades on their own policy .
I'm agree as a federal agency needs to be on top and updated but it is what it is.