Lion News August 2016

News / August 2016 / Is PPE Your Last Resort for Workplace Safety?
Find a Course

Is PPE Your Last Resort for Workplace Safety?

Posted on August 02, 2016 by Lee Ann Coniglione

Today, American workplaces are safer than ever, but US employers still face challenges when it comes to controlling workplace hazards.

All kinds of everyday materials, processes, and operations can pose a workplace hazard to your employees—chemicals, machinery, trip-and-fall hazards, and more found in indoor and outdoor work environments. Because these hazards are so varied in nature and can pose serious risk to workers, OSHA has established several Personal Protective Equipment (PPE)–related standards to cover hazards of different types and severity. OSHA's General Requirements Standard addresses the overall elements of an employer-sponsored PPE program. In addition, the Agency enacted similar standards having to do with protecting specific body parts from occupational hazards.

The majority of the PPE standards are found in 29 CFR 1910, Subpart I. We'll start by taking a look at how OSHA organizes this collective grouping of standards:
  • 1910.132 - General Requirements
  • 1910.133 - Eye and Face Protection
  • 1910.134 - Respiratory Protection
  • 1910.135 - Head Protection
  • 1910.136 - Foot Protection
  • 1910.137 - Electrical Protective Devices
  • 1910.138 - Hand Protection
Although not found in Subpart I, another standard that fits into this grouping is the Occupational Noise Exposure Standard, found in 29 CFR 1910.95, Subpart G. It sets the requirements for managing noise hazards in the workplace, including several PPE program elements related to hearing protection.

Many other OSHA standards include provisions for PPE as well. For example, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard has a relatively large PPE component to it. For now, though, we will focus on the general requirements for implementing a PPE program.

OSHA's Hierarchy of Controls

We know that PPE is used to protect employees from hazards that can cause injury or illness through any one of several routes of exposure (e.g., contact, absorption, inhalation, injection). Before we move on with our discussion, let's look at where PPE ranks in terms of hierarchy of controls. Although certainly widespread throughout many workplaces, PPE is actually the least preferred method for controlling hazards. In fact, it occupies the last spot on the list of controls:
  1. Substitution/elimination
  2. Engineering controls
  3. Administrative and work practice controls
  4. Personal Protective Equipment
This means OSHA considers PPE to be the last resort for workplace safety. If the hazard cannot be removed from the workplace or engineered out through mechanisms, and employee exposure to the hazard cannot be mitigated by work practices, then, and only then, should the employer consider PPE for employees.

Elements Related to PPE Program Administration

Hazard Assessments

If in fact PPE has been determined to be the most feasible course of action to protect employees from job hazards, then a comprehensive hazard assessment must be performed by the employer. The hazard assessment should be focused on identifying hazards that are present or likely to be present in the workplace.

Going through the hazard assessment process is crucial. The information gathered during this phase will enable employers to make informed decisions about when there is a legitimate need for PPE.

Selecting PPE for (and With!) Employees

Two of the most basic goals of any PPE program likely have to do with providing employees with an adequate level of protection as well as supplying them with equipment they will actually wear. While the latter may sound a bit like a no brainer, it can be a challenge to achieve full PPE compliance, particularly when employees are not involved in the selection process. Employees may decide not to wear their PPE for many reasons—maybe it doesn't fit properly; it's too hot or otherwise uncomfortable; it interferes with items already worn on the face, such as eyeglasses or safety glasses; or it slows them down. Again, all of these reasons (and more) reinforce why employees should be included and have a voice in the selection process.

The Written PPE Certification

As stated in OSHA's PPE Standard, part of the hazard assessment and equipment selection process requires that employers provide written certification that the required workplace hazard assessment has been performed. In terms of guidance, OSHA provides a template document in the form of Appendix B to Subpart I. In it, employers will find the steps of the hazard assessment process outlined, in addition to some PPE recommendations when considering protection for various parts of the body.

Training Employees on PPE Selection, Fit, Wear, and Care

Aside from the hazard assessment and equipment selection processes, another significant component of the general requirements is training. Employers are expected to train their employees to an adequate level at which they are able to recognize when PPE is necessary, what PPE is necessary, how to properly put on and remove their PPE, and how to wear and make adjustments to it. Employees must also be trained to know about the limitations of PPE, as well as how to properly care for and dispose of it.

While a few specific standards do mandate annual training on PPE use (e.g., Respiratory Protection at 29 CFR 1910.134 and Hearing Conservation at 29 CFR 1910.95), general use PPE does not require repeat training on a regular basis. However, following initial training, employees may need retraining in the event that there are changes in the workplace, such as the introduction of new hazards or new types of PPE.

Follow-up PPE training would also be necessary in the event employees were to behave in a manner indicating they do not know how to properly wear the assigned PPE or otherwise failing to comply with the employer's PPE policy.

Who Pays for PPE?

Once an employer determines that PPE is necessary to protect employees from hazards in the workplace, the next question is: Who pays for it?

OSHA does allow employees to provide and use their own protective equipment, though this is more likely to be the exception than the rule. In general, employers are responsible for purchasing, providing, and maintaining PPE, as well as any associated costs that are incurred as part of a medical surveillance program.

As mentioned earlier, payment for protective equipment is also addressed in the General Requirements Standard, and with limited exception, PPE "shall be provided by the employer at no cost to employees." [29 CFR 1910.132(h)(1)]

When Is the Employer NOT Required to Pay for PPE?

The following list addresses those limited exception scenarios in which the employer is NOT required to pay the cost of PPE:
  • Non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job site
  • When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots
  • Logging boots required by 29 CFR 1910.266(d)(1)(v)
  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots
  • Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen
  • Replacement PPE when the employee has lost or intentionally damaged the PPE
  • Where an employee provides adequate protective equipment he or she owns, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment
So, in summary, the employer cannot require an employee to provide or pay for his or her own PPE, unless the PPE falls into one of the aforementioned bulleted scenarios. To learn more about OSHA's General Requirements Standard for PPE, and other related standards, click here.

OSHA 10-hour Training for General Industry Employees

US businesses lose up to $1,000,000,000 per week due to workplace injury and illness. Do your employees know how to protect themselves from the hazards in your workplace? OSHA 10-hour Training at helps employees identify hazards, take steps to mitigate their exposure, spot safety red flags, and keep themselves and their co-workers safe. From GHS HazCom to elevated work surfaces, electrical safety to machine guarding, and more, the OSHA 10-hour General Industry Online Course helps your employees work safely and efficiently.

Looking for HAZWOPER Training?

If you and your team perform cleanup work at an "uncontrolled hazardous waste site," the new 8-hour OSHA HAZWOPER Refresher online course will help you meet your annual HAZWOPER training requirement. Learn more at

Lion - Quotes

"The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!"

Curtis Ahonen

EHS&S Manager

"These are the best classes I attend each year. I always take something away and implement improvements at my sites."

Kim Racine

EH&S Manager

"Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had."

Rachel Mathis

EHS Specialist

"Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat. "

Genell Drake

Outbound Lead

"I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!"

Sara Sills

Environmental Specialist

"The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing."

Linda Arlen

Safety & Environmental Compliance Officer

"As always, Lion never disappoints"

Paul Resley

Environmental Coordinator

"I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for."

Frank Sizemore

Director of Regulatory Affairs

"I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops."

Stephanie Gilliam

Material Production/Logistics Manager

"Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider."

Francisco Gallardo

HES Technician

"The instructor was excellent. They knew all of the material without having to read from a notepad or computer. "

Gary Hartzell

Warehouse Supervisor

"I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down."

Nicole Eby

Environmental Specialist

"This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions."

Amanda Oswald

Shipping Professional

"This is the best RCRA training I've experienced! I will be visiting Lion training again."

Cynthia L. Logsdon

Principal Environmental Engineer

"I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!"

Henry Watkins

Hazardous Waste Technician

"I can't say enough how pleased I was with this course! Everything finally makes sense."

Kim Graham

Lab Manager

"The instructor was energetic and made learning fun compared to dry instructors from other training providers."

Andy D’Amato

International Trade Compliance Manager

"This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information."

Rachel Stewart

Environmental Manager

"I have been to other training companies, but Lion’s material is much better and easier to understand."

Mark Abell

Regional Manager

"I love that the instructor emphasized the thought process behind the regs."

Rebecca Saxena

Corporate Product Stewardship Specialist

"More thorough than a class I attended last year through another company."

Troy Yonkers

HSES Representative

"Amazing instructor; real-life examples. Lion training gets better every year!"

Frank Papandrea

Environmental Manager

"The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun."

Teresa Arellanes

EHS Manager

"I can take what I learned in this workshop and apply it to everyday work and relate it to my activities."

Shane Hersh

Materials Handler

"The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable."

Mary Sue Michon

Environmental Administrator

"The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly."

Brittany Holm

Lab Supervisor

"These are the best commercial course references I have seen (10+ years). Great job!"

Ed Grzybowski

EHS & Facility Engineer

"Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms."

David Hertvik

Vice President

"You blew the doors off the competition!"

Stephen Bieschke

Facilities Manager

"I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop."

Tom Bush, Jr.

EHS Manager

"Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are."

Amanda Schwartz

Environmental Coordinator

"The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information."

Stephanie Venn

Inventory Control Specialist

"Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic."

Dorothy Rurak

Environmental Specialist

"If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials."

Bryce Parker

EHS Manager

"I appreciate the focus on what the regulations tell us to do, as well as what is subject to interpretation."

Nicole Eby

Environmental Specialist

"The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information."

Morgan Bliss

Principal Industrial Hygienist

"Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right."

Gregory Thompson

Environmental, Health & Safety Regional Manager

"I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better."

Danny Province

EHS Professional

"Content was comprehensive and seemed to really “dig in” to the material. I liked the option to review FAQs and re-review the quiz questions."

Morgan Bliss

Principal Industrial Hygienist

"The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete."

Felicia Rutledge

Hazmat Shipping Professional

"The course is well thought out and organized in a way that leads to a clearer understanding of the total training."

David Baily

Hazmat Shipping Professional

"This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things. "

Quatama Jackson

Waste Management Professional

"The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others."

Donnie James

Quality Manager

"My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material."

Robert Roose

Manager, Dangerous Goods Transportation

"Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs."

Neil Luciano

EHS Manager

"The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course."

Jeffrey Tierno

Hazmat Shipping Professional

"Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training."

Caroline Froning

Plant Chemist

"The course was very well structured and covered the material in a clear, concise manner."

Ian Martinez

Hazmat Shipping Professional

"The online course was well thought out and organized, with good interaction between the student and the course."

Larry Ybarra

Material Release Agent

"My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow."

Steven Erlandson

Environmental Coordinator

"I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective."

John Gratacos

Logistics Manager

"Lion does a great job summarizing and communicating complicated EH&S-related regulations."

Michele Irmen

Sr. Environmental Engineer

"Far superior in terms of detail and instructional/support materials. The depth of instructor knowledge is always beyond any other training I have participated in."

Linda Arlen

Safety & Environmental Compliance Officer

"The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked. "

Johnny Barton

Logistics Coordinator

"I have returned to Lion's compliance training for several years and prefer to stay with a trusted source. The material and presentation are far superior than others I have taken."

Robert Roose

Manager, Dangerous Goods Transportation

"I chose Lion's online webinar because it is simple, effective, and easily accessible. "

Jeremy Bost

Environmental Health & Safety Technician

"Lion's information is very thorough and accurate. Presenter was very good."

Melissa Little

Regulatory Manager

"Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus."

John Brown, CSP

Director of Safety & Env Affairs

"The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!"

Brian Martinez

Warehouse Operator

"Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again."

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

"I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities."

Pamela Embody

EHS Specialist

"Energetic/enthusiastic! Made training enjoyable, understandable and fun!"

Amanda Walsh

Hazardous Waste Professional

"Lion was very responsive to my initial questions and the website was user friendly."

Michael Britt

Supply Chain Director

"Convenient; I can train when I want, where I want."

Barry Cook

Hazmat Shipping Professional

"Having the tutorial buttons for additional information was extremely beneficial."

Sharon Ziemek

EHS Manager

"We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training."

Timothy Mertes

Hazmat Shipping Professional

"Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented."

George Bersik

Hazardous Waste Professional

"Lion courses are the standard to which all other workshops should strive for!"

Brody Saleen

Registered Environmental Health Specialist

"Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well."

Marty Brownfield

Hazardous Waste Professional

"The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!"

Chelsea Minguela

Hazmat Shipping Professional

"Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time."

Kimberly Arnao

Senior Director of EH&S

"Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers."

Robert Brenner

District Environmental Manager

"I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!"

Diana Joyner

Senior Environmental Engineer

"The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers."

George Alva

Manufacturing Manager

"The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable."

Marc Bugg

Hazardous Waste Professional

"Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!"

Oscar Fisher

EHS Manager

"Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed."

John Hutchinson

Senior EHS Engineer

"The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again."

John Nekoloff

Environmental Compliance Manager

"The instructor was very engaging and helped less experienced people understand the concepts."

Steve Gall

Safety Leader

"This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!"

Lori Hardy

Process & Resource Administrator

"I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past."

Neil Ozonur

Safety Officer

"The instructor created a great learning environment."

Avinash Thummadi

CAD & Environmental Manager

"Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!"

Paul Harbison

Hazardous Waste Professional

"The instructor took a rather drab set of topics and brought them to life with realistic real-life examples."

Tom Berndt

HSE Coordinator

"Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything."

Ellen Pelton

Chemical Laboratory Manager

"I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!"

George Chatman

Hazardous Material Pharmacy Technician

"I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!"

Kevin Pylka

Permitting, Compliance & Environmental Manager

"No comparison. Lion has the best RCRA training ever!!"

Matt Sabine

Environmental Specialist

"Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials."

John Troy

Environmental Specialist

"The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry."

Frances Mona

Shipping Manager

"I will never go anywhere, but to Lion Technology."

Dawn Swofford

EHS Technician

"Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!"

Stephanie Weathers

SHE Specialist

"One of the best trainings I have ever received!"

Brandon Morfin

EH&S Manager

"Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!"

Donna Moot

Hazardous Waste Professional

"Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years! "

Tony Petrik

Hazmat Shipping Professional

"The instructor made the class very enjoyable and catered to the needs of our group."

Sarah Baker


"The instructor was very patient and engaging - willing to answer and help explain subject matter."

Misty Filipp

Material Control Superintendent

"Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!"

Marti Severs

Enterprise Safety Manager

"Lion is my preferred trainer for hazmat and DOT."

Jim Jani

Environmental Coordinator

download our latest whitepaper

Get to know the top 5 changes to OSHA’s revised GHS Hazard Communication Standard at 29 CFR 1910.1200 and how the updates impacts employee safety at your facility.

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Current and Privacy Policy.

The GHS HazCom Transition Five “Must-Know” Changes