Safety

PPE requirements for construction

Safety
Stencil print of a full PPE set laid out in a grid
The kit is the visible half; the written assessment is the half that gets cited.

Published 2026-09-04 · 10 min read · sources checked 2026-09-04

Everybody knows the gear. Fewer contractors have the document that is supposed to precede it — and eye and face protection in construction was still the ninth most frequently cited federal standard in fiscal year 2024.

PPE is the last control, not the first

The hierarchy is eliminate, substitute, engineer, administer, then protect the person. PPE sits at the bottom because it fails in the worst way: it depends on a human wearing it correctly, every time, and it does nothing about the hazard itself.

That is not an argument against PPE — it is an argument for finishing the job hazard analysis before you order it. A JHA whose every row says “wear PPE” is a shopping list, not an analysis.

The assessment comes before the equipment

1910.132(d)(1) requires the employer to assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of PPE. 1910.132(d)(2) then requires the employer to verify that the assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying that the evaluation has been performed, the date or dates of the hazard assessment, and that identifies the document as a certification of hazard assessment.

Four elements, all four required. Non-mandatory Appendix B to the subpart contains an example of procedures that would comply. The form is on the PPE hazard assessment form.

Notice

Handing out hard hats is not compliance with the PPE standard. It is compliance with half of it. The other half is a piece of paper that says who looked, at what, on which date — and says it is a certification.

By body part, with the section

ProtectionConstruction sectionNote
Head1926.100ANSI Z89.1-2009, -2003 or -1997; Section 9.7 for high-voltage exposure
Eye and face1926.1029th most cited federal standard, FY2024
Hearing1926.101Protectors where engineering and administrative controls do not reduce the level
Respiratory1926.103Adopts the general-industry programme at 1910.134 — fit testing, medical evaluation, a written programme
Foot1926.96Safety-toe footwear meeting the referenced standard
Hand and body1926.95General criteria for PPE selection, maintenance and sanitary condition
Fall protection1926.502(d)Its own subpart, its own criteria; not a general PPE item

Sections read from 29 CFR 1926 Subpart E on 2026-09-04; citation ranking from osha.gov/data/commonstats.

Respiratory protection is the one that turns into a programme rather than a purchase. Fit testing, medical evaluation and a written programme all come with it, and respiratory protection was the fifth most cited federal standard in fiscal year 2024 — mostly for having the respirators without the programme.

Who pays

1910.132(h) is the rule: except as provided in paragraphs (h)(2) through (h)(6), the protective equipment used to comply with the part shall be provided by the employer at no cost to employees.

The exception people quote is narrower than they think. The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes or boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the jobsite. Take the boots off the exception and the exception disappears with them.

Everything else — hard hats, goggles, gloves, hearing protection, respirators, harnesses, high-visibility clothing — is on the employer. Head protection specifics, including the truth about expiry dates, are in hard hat requirements.

Provide
Stencil print of a half-mask respirator with cartridges
At no cost to employees — with one narrow, conditional exception.

Sources, with the date each was read

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