OSHA hand protection requirements: what 1910.138 says

What does the employer have to do, step by step?

1. Assess the workplace for hand hazards. The employer must assess the workplace to determine whether hazards are present, or likely to be present, that require PPE. For hands that means walking the tasks and naming the sharp, hot, cold, rough and chemical contacts.
2. Select the glove from its performance characteristics. The selection has to be based on an evaluation of the glove’s performance against the task, the conditions, the duration of use and the hazards identified. Appendix B says to ask the manufacturer for documentation that the glove meets the test standard for the hazard before buying it.
3. Have each employee use it, and make sure it fits. The employer selects the PPE, has each affected employee use it, tells each employee what was selected, and selects PPE that properly fits each employee.
4. Certify the assessment in writing. A written certification that names the workplace evaluated, the person certifying, the dates, and identifies itself as a certification of hazard assessment.
5. Train each employee. When the gloves are necessary, what gloves, how to put them on, take them off, adjust and wear them, their limitations, and their care, maintenance, useful life and disposal. The employee has to demonstrate understanding, and retraining is required when the workplace or the gloves change.
6. Pay for them. PPE required by the standard is provided at no cost to the employee, with the exceptions in 1910.132(h)(2) through (h)(6), which cover items such as non-specialty safety-toe footwear, everyday clothing and weather gear, not gloves selected for a hazard.
7. Keep it in usable condition. PPE is provided, used and maintained in a sanitary and reliable condition. Defective or damaged PPE may not be used.

Does OSHA require cut-resistant gloves?

Not by name. No OSHA standard says “cut-resistant gloves” or names an ANSI level. What 1910.138 says is that hand protection is required when hands are exposed to severe cuts or lacerations, and that it must be selected from its performance characteristics for that hazard. Once the hazard assessment identifies a cut hazard, a glove with no cut rating, or with a rating below the hazard, does not meet the selection requirement. In practice that is a requirement for cut-resistant gloves at a level the assessment names, and the ANSI/ISEA 105 level on the glove is how compliance is shown.

OSHA citations for hand injuries are written under 1910.138(a) (no hand protection, or the wrong kind, for a named hazard) and 1910.132(d)(1) (no hazard assessment, or one that missed the hazard). The defense is the paper: an assessment that names the cut hazard and the level, gloves marked at that level, and training records. The level itself is a judgment call the standard leaves to the employer, which is what the ANSI scale is for.

Construction has its own PPE section, which says the same things with less detail: PPE is provided and used wherever hazards require it, and it must be of safe design and construction for the work. Construction employers generally apply the 1910.132 and 1910.138 method as the recognized practice.

What does Appendix B add?

• OSHA is unaware of any glove that protects against all hand hazards, and common glove materials give only limited protection against many chemicals. Select the glove for the application, and decide how long it can be worn and whether it can be reused.
• Know the glove’s performance characteristics for the specific hazard (chemical, cut, flame), assessed by standard test procedures, and ask the manufacturer for documentation that the glove meets the test standard before buying.
• Study the work for dexterity needed, duration, frequency and degree of exposure, and the physical stresses on the glove.
• Where performance is acceptable, regularly changing a cheaper glove can be more cost-effective than reusing an expensive one.
• For chemicals: determine the toxic properties, including skin absorption; any chemical-resistant glove is generally acceptable for dry powders; select for a mixture by the component with the shortest breakthrough time; and make sure employees can remove gloves without contaminating their skin.

What is not in 1910.138?

Electrical shock. Rubber insulating gloves are covered by 1910.137 and the electrical work rules in 1910.335, with their own class marks and 6-month test cycle. Bloodborne pathogens. Gloves for blood and other potentially infectious material are in 1910.1030(d)(3)(ix). Hazardous waste and emergency response. HAZWOPER has its own PPE program requirement. Welding. 1910.252 requires employees exposed to welding, cutting and brazing hazards to be protected by PPE under 1910.132, with the clothing depending on the size, nature and location of the work. Each of those standards applies in addition to the general rule, not instead of it.