Putting on a hard hat and safety glasses and calling it good enough is not a PPE hazard assessment. OSHA 1926.95(a) requires the employer to assess each task for its specific hazards and select PPE to address those hazards. On NYC construction sites, this means the SSM and foremen must think through the hazards of each task — not just hand out generic PPE at the gate.
What a Hazard Assessment Covers
- Head: Is there overhead work? Falling objects? Electrical exposure? → Class E hard hat required
- Eyes/Face: Grinding? Cutting? Chemical splash? Overhead concrete work? → Safety glasses with side shields? Goggles? Face shield?
- Hands: What type of hazard — cut, crush, chemical, heat, electrical? → Select glove to match
- Feet: Nail hazards? Chemical spills? Wet surfaces? Electrical exposure? → PR midsole? Chemical-resistant boot? EH-rated?
- Body: Struck-by from vehicles? Chemical splash? Arc flash? Falling debris? → Hi-vis? Coveralls? Arc flash suit?
- Respiratory: Dust? Vapors? Asbestos? Silica? → Which respirator type and filter rating?
The Assessment Must Be Written
- OSHA requires a written certification that the hazard assessment was performed — a verbal walk-around is not sufficient
- The assessment must identify the workplace assessed, the date, the name of the person certifying it, and the hazards found
- On NYC sites: the SSM typically maintains this documentation as part of the daily log or project safety plan
When the Assessment Must Be Updated- When a new task or trade begins work on the site
- When new materials or chemicals are introduced
- After an injury or near-miss that exposed a PPE gap
- Seasonally — winter work introduces cold stress and different foot/hand protection requirements
Discussion Questions- Walk through the PPE hazard assessment for your specific task today — head, eyes, hands, feet, body, respiratory. What is required for each?
- OSHA says the hazard assessment must be "written." Why does this matter compared to just doing it verbally?
- Name two situations that would require you to update the PPE hazard assessment for this site.
- Who is responsible for conducting the PPE hazard assessment on this project?
Sign-Off
Foreman / Supervisor
SSM / SSC Name & License No.
Worker Attendance
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