CSAC Excess Insurance Authority
LOSS PREVENTION BEST PRACTICES
PERSONAL PROTECTIVE EQUIPMENT
CAL/OSHA WRITTEN CERTIFICATION ASSESSMENT REQUIREMENTS
Introduction
Cal/OSHA personal protective equipment (PPE) requirements have been in force since the early 1970s. But, as of April,
13, 2011, Cal/OSHA amended CCR 3380, Personal Protective Devices, which now requires California employers to
conduct a PPE assessment of their workplace and verify the assessment was conducted through a written certification
process.
This assessment is vital in determining if PPE can be
eliminated.
PPE is the least effective method for protecting your
employees because PPE does not eliminate or reduce
the hazard. One of the basic principles of safety
management is called the Hierarchy of Controls. It
prioritizes control methods that remove or reduce a
hazard in the workplace, rather than rely on human
behavior. Types of Controls from most to least effective
include:




Elimination of the Hazard/Substitution – Substitute
with safer alternatives
Engineering Controls – Implement physical change
to the workplace, which eliminates/reduce the
hazard
Administrative and Work Practice Controls –
Establish efficient processes or procedures to avoid
over exposure
PPE – Use of protection to reduce exposure to
hazard
The scope of the regulation
covers PPE requirements
for the head, eyes/face,
hands, feet, and body;
however, as a best practice,
you are encouraged to
include all applicable PPE in
your assessment, such as respiratory protection,
hearing protection, and fall protection.
Conducting the PPE Assessment
In order to assess the need for PPE, the entity should
conduct a walk-through survey of the work areas where
the entity believes PPE may be necessary. The purpose
of the survey is to identify sources of hazards to
www.csac-eia.org
workers using basic hazard categories, such as impact,
penetration, compression (roll-over), chemical, heat,
harmful dust, and light/radiation. Sources of hazards
may include:

Motion, such as machinery or processes where
any movement of tools, machine elements or
particles could exist, or movement of personnel
that could result in collision with stationary
objects

High temperatures that could result in burns,
eye injury or ignition of protective equipment,
etc.

Chemical/harmful dust exposures includes gas,
liquids, and solids

Light radiation, such as welding, brazing,
cutting, furnaces, heat treating, high intensity
lights, etc.

Falling objects or potential for dropping objects

Sharp objects which might pierce the feet or
cut the hands

Rolling or pinching objects which could crush
the feet

Layout of workplace and location of workers

Electrical hazards
Potential sources may also be identified by analyzing
accident/injury data.
Analyzing the Assessment
Once the information is gathered, each of the basic
hazard categories should be reviewed and a
determination made as to the source of the hazards and
potential injury from the hazards. In many cases, there
may be several hazards identified.
916.850.7300
Loss Prevention Best Practices
PPE – Cal/OSHA Written Assessment Requirements
Certifying the Assessment
The entity must verify that the required workplace
hazard assessment has been performed through a
written certification that identifies the workplace
evaluated, the person certifying that the evaluation has
been performed, and the date(s) of the hazard
assessment. The evaluator should have knowledge of
the tasks and operations performed within the
assessment. Sample PPE Assessment Form
PPE Selection Guidelines
After completing the analysis, Cal/OSHA recommends
the following procedure for selecting PPE:




Become familiar with the potential hazards and
the type of protective equipment that is
available, and what it can do; i.e., splash
protection, impact protection, etc.;
Compare the hazards associated with the
environment; i.e., impact velocities, masses,
projectile shape, radiation intensities, with the
capabilities of the available protective
equipment;
Select the protective equipment which ensures
a level of protection greater than the minimum
required to protect employees from the
hazards; and
Fit the user with the protective device and give
instructions on care and use of the PPE. It is
very important that end users be made aware
of all warning labels for and limitations of their
PPE.
PPE Selection Resources
Cal/OSHA has developed a PPE Guide which provides
detailed guidance on selecting PPE for the eyes, face,
head, feet, and hands.
Additional Cal/OSHA resources:
- 8 CCR 3381, Head Protection
- 8 CCR 3382, Eye and Face Protection
- 8 CCR 3383, Body Protection
- 8 CCR 3384, Hand Protection
- 8 CCR 3385, Foot Protection
2
Training Requirements
The entity must provide training to each employee who
is required to use PPE. Training must include, at least,
the following:

When PPE is necessary

What PPE is necessary

How to properly don, doff, adjust, and wear PPE

The limitations of the PPE

The proper care, maintenance, useful life and
disposal of the PPE
Employees must demonstrate an understanding of the
training and an ability to use the PPE properly before
performing work requiring the use of the PPE
The entity must re-train affected employees when:

Changes in the workplace render previous
training obsolete;

Changes in the types of PPE to be used render
previous training obsolete; and

There are inadequacies in an affected
employee's use of assigned PPE which indicates
the employee has not retained the required
understanding or skill.
A written certification is required that confirms the
employee received and understood the training.
Documentation should include employee name, training
date(s), and subject. Sample PPE Training Form
Cleaning and Maintenance
It is important that all PPE be kept clean and properly
maintained. Cleaning is particularly important for eye
and face protection where dirty or fogged lenses could
impair vision.
PPE should be inspected,
cleaned, and maintained
at regular intervals so that
the PPE provides the
requisite protection.
Contaminated PPE which
cannot be decontaminated must be disposed of in a
manner that protects employees from exposure to
hazards.