Key areas covered
- Hazard Assessment and the PPE Selection Hierarchy
- PPE Training, Inspection, and Maintenance
- Supervisor Enforcement and Accountability
As a foreman or crew lead, you are responsible for ensuring every worker wears the right PPE for the task. This topic covers the hazard assessment process, the hierarchy of PPE selection, training requirements under 29 CFR 1926.95, and your supervisory duty to inspect, enforce, and document PPE use on the job site.
Hazard Assessment and the PPE Selection Hierarchy
Before selecting PPE, a competent person must conduct a written hazard assessment of the work area (29 CFR 1926.95(b)). This assessment identifies sources of head, eye, face, hand, foot, and body hazards. PPE is always the last resort in the hierarchy of controls — after elimination, substitution, engineering controls, and administrative controls have been evaluated. Once hazards are identified, select PPE certified to the applicable ANSI or ASTM standard. Hard hats must meet ANSI Z89.1 and be rated for the task (Class E for electrical work). Safety glasses and face shields must meet ANSI Z87.1. Gloves, foot protection, and hearing protection all have specific standards. Document the assessment, identify the PPE required for each task, and keep the written certification on file.
Why it matters
A crew lead who skips the written hazard assessment exposes the company to citations under 1926.95(b) and — more importantly — puts workers at risk from hazards that a systematic review would have caught. The assessment is not a formality; it is the foundation for every PPE decision you make on that site.
Field note
At the pre-task meeting, review the written hazard assessment with the crew. Point to the specific PPE required for each phase of work. If conditions change mid-task (e.g., overhead work begins), stop and re-assess before continuing.
PPE Training, Inspection, and Maintenance
OSHA requires that each employee who uses PPE be trained to know: when PPE is necessary, what PPE is necessary, how to properly put on, take off, adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life, and disposal of PPE (29 CFR 1926.95(d) via 1910.132(f)). Training must be documented. Retraining is required when a worker does not demonstrate understanding or when new hazards require different PPE. Before each use, workers must inspect PPE for defects. Hard hats should be checked for cracks, dents, and degraded suspension systems. Harnesses must be free of cuts, burns, and chemical damage. Respirators require a user seal check every time they are donned. Defective PPE must be immediately removed from service and replaced — never repaired with tape or makeshift fixes.
Why it matters
Issued PPE that is damaged or worn incorrectly provides little or no protection. As the supervisor, you own the inspection culture — if you walk past a worker wearing a cracked hard hat or an unclipped harness, that is a leadership failure with potentially fatal consequences.
Field note
Build a 60-second PPE inspection into every pre-task toolbox talk. Have workers hold up their hard hat, gloves, and glasses for a visual check while you are talking. Remove and replace anything defective before work begins — never after the first near-miss.
Supervisor Enforcement and Accountability
OSHA holds employers — and by extension, supervisors — responsible for PPE enforcement. Under the multi-employer worksite doctrine, a controlling employer can be cited for failing to correct hazardous conditions created by a subcontractor if they had the authority to do so. Your enforcement responsibilities include: ensuring PPE is available and in good condition before work begins, observing and correcting PPE non-compliance in real time, documenting PPE training and fit-testing, escalating repeat non-compliance through progressive discipline, and coordinating with other trades to align PPE requirements when scopes overlap. For respiratory protection, a written program is mandatory under 29 CFR 1926.103 / 1910.134, including medical evaluation, fit-testing, and training before any respirator is worn. Supervisors must never allow workers to begin respiratory-hazard tasks without a completed fit-test record on file.
Why it matters
A single OSHA Willful citation for PPE non-compliance can exceed $16,000. More critically, courts and juries hold supervisors personally accountable when a worker is injured after documented non-compliance was ignored. Enforcement is not optional — it is your legal obligation.
Field note
Keep a PPE sign-off sheet for each task phase. When you update the hazard assessment or change task conditions, get a fresh signature from each worker acknowledging the new PPE requirement. That paper trail protects you and your company.