OSHA Scan

PPE gaps: the last line of defense, and the one most often missing

Head, eye, hearing, respiratory, hand, and foot protection done right

Personal protective equipment is the final barrier between a worker and an injury, yet missing, wrong, or ill-fitting PPE remains one of the most common findings on any job site. PPE sits at the bottom of the hierarchy of controls for a reason — it does nothing to remove the hazard, it only reduces the harm if everything else fails. OSHA Scan reads a single photo and flags the workers who are unprotected before the moment they need protection arrives.

Where does PPE fall in the hierarchy of controls?

PPE is the last line of defense, sitting below elimination, substitution, engineering controls, and administrative controls. It does not remove the hazard — it only reduces the severity of an injury if the other controls fail. That is why OSHA expects employers to control hazards at the source first and treat PPE as a supplement, not a substitute.

Does the employer have to pay for PPE?

In most cases, yes. OSHA requires employers to provide required PPE at no cost to the worker, including hard hats, safety glasses, hearing protection, respirators, and most gloves and footwear. Narrow exceptions exist — such as ordinary non-specialty prescription safety eyewear allowed off-site and certain everyday footwear — but the general rule is employer-paid.

What is a written hazard assessment?

It is the employer's documented evaluation of each work area and task to identify hazards that require PPE. Under 29 CFR 1910.132 the assessment must be certified in writing, identifying the workplace evaluated, the person certifying it, and the date. Skipping the written certification is itself a citable violation even when the correct PPE is present.

When are hard hats required?

Hard hats are required wherever there is a danger of head injury from impact, falling or flying objects, or electrical shock and burns. They must meet the applicable ANSI/ISEA Z89.1 standard. On active construction sites with overhead work or struck-by hazards, that generally means hard hats are worn at all times in the work area.