Does OSHA require an annual PPE hazard assessment?

Federal OSHA doesn't require an annual PPE hazard assessment. 29 CFR 1910.132(d) requires the employer to assess the workplace for hazards that call for PPE and to certify that assessment in writing, and it sets no interval for doing either again. Nonmandatory Appendix B says to reassess "as necessary." Annual deadlines do exist elsewhere in federal PPE rules, such as the respirator fit test and retraining under 1910.134.

A coating contractor’s PPE assessment lists an October 27 review date. A week later, the form is still waiting for review. That date came from the company’s own annual schedule. The federal PPE assessment rule does not give the certification an annual expiration date.

Under federal OSHA, no rule makes that assessment expire. The year was the company's choice. 29 CFR 1910.132(d) asks for an assessment and a written certification, and it doesn't say when to redo them. Check whether the job has changed since the assessment. A different solvent in the drums, a pump sprayer where there used to be rags, a burn on someone's forearm. If something like that happened, the assessment may no longer describe the work, and that's the reason to open it again. The date isn't.

What does 1910.132(d) require?

The paragraph has two parts. The first is the assessment and what follows from it:

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall: (i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment; (ii) Communicate selection decisions to each affected employee; and, (iii) Select PPE that properly fits each affected employee. (29 CFR 1910.132(d)(1))

The duty runs from the hazard to the PPE to the worker wearing it. "Likely to be present" reaches the hazard you expect on Thursday's task, not only what's on the rack this morning. A note under the paragraph sends you to Appendix B for "an example of procedures that would comply with the requirement for a hazard assessment." That appendix is nonmandatory, and its title says so.

The second part is the written certification of paragraph (d)(2), covered below. Neither part comes with a form or a calendar. When OSHA published the general industry rule on April 6, 1994, it called paragraph (d) "a performance-oriented provision" and added:

Paragraph (d) clearly indicates that the employer is accountable both for the quality of the hazard assessment and for the adequacy of the PPE selected. (59 FR 16334)

Performance-oriented means the rule names the result and leaves the method to the employer. The quality of the assessment is on you, and so is the choice of how often to look at it again.

Is there a yearly deadline for the PPE hazard assessment?

29 CFR 1910.132 requires the workplace hazard assessment and its written certification, without prescribing an annual or other fixed interval for repeating them. A date printed on a company form needs to be identified as the company’s review date.

A yearly date on the form is a company review date. Such a review can catch changes in products, work methods or PPE selection since the assessment. If the date has passed, check the assessment against the current job and follow the company’s review policy. The anniversary itself is not a federal reassessment deadline.

Two older OSHA texts contain wording that could be taken for an interval. Neither sets one. The first is in the cost analysis of the 1994 preamble:

The cost to conduct hazard assessments was estimated to be $15.9 million per year, assuming a reassessment is conducted once every five years. (59 FR 16334)

That's a pricing assumption under the heading Costs of Compliance. The preamble doesn't bring it back anywhere as a requirement or a recommendation.

The second is OSHA Instruction STD 1-6.6, the 1995 inspection guidelines for the revised PPE standards. It let employers rely on hazard assessments done before July 5, 1994, and let an employer rely on one a previous employer had done for the worksite before that date, "provided that the job conditions have not substantially changed." That's a transition clause for assessments older than the rule, not a reassessment rule. The directive is archived, and osha.gov marks it as a document that "may no longer represent OSHA Policy."

OSHA’s interpretation letter of March 28, 2024 restates the duty to assess and certify and points to Appendix B: "An initial survey should be conducted followed by further analysis of hazards." It gives no frequency. It also reminds the reader that interpretation letters "cannot create additional employer obligations."

When should you re-assess?

Within 1910.132 and its appendix, the only text on reassessing is in Appendix B to Subpart I of Part 1910, titled "Nonmandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection." Its paragraph 7:

7. Reassessment of hazards. It is the responsibility of the safety officer to reassess the workplace hazard situation as necessary, by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE. (Appendix B to Subpart I of Part 1910)

"As necessary" is the whole schedule. What the paragraph does give is a list of things to watch: new equipment, new processes, the accident records, and whether the PPE picked last time still suits the job. Paragraph 3.b adds that "injury/accident data should be reviewed to help identify problem areas." The phrase "regular intervals" shows up in paragraph 12, on cleaning and maintenance: "PPE should be inspected, cleaned, and maintained at regular intervals so that the PPE provides the requisite protection." That sentence is about the gear.

The appendix is nonmandatory, so paragraph 7 is guidance, and paragraph (d)(1) says nothing about when to look again. What 1910.132 does tie to events is training. Under paragraph (f)(3), the employer retrains a trained employee it has reason to believe lacks the understanding and skill the rule requires, and the circumstances where retraining is required "include, but are not limited to, situations where:"

(i) Changes in the workplace render previous training obsolete; or (ii) Changes in the types of PPE to be used render previous training obsolete; or (iii) Inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill. (29 CFR 1910.132(f)(3))

The 1994 preamble says the paragraph "indicates clearly that employers have an ongoing responsibility to maintain employee proficiency in the use and care of their PPE." Ongoing, tied to events, no date.

On a real job the two lists overlap. If the crew has to learn a new glove, someone chose that glove against a hazard, and the assessment either names that hazard or it doesn't. A short list of events worth a second look at the assessment: a product with a new SDS shows up on site, a new tool or process starts, someone gets hurt or nearly does, a worker joins who has never done the task, the job moves into a new phase. 1910.132 names none of them as a trigger for the assessment. Any one of them can make it wrong.

Passing the company’s review date is not, by itself, a missed federal assessment deadline. The question is whether the assessment still describes the wipe-down, and that's about the solvent and the rags, not the calendar.

What goes on the written certification?

Paragraph (d)(2) names four things:

The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment. (29 CFR 1910.132(d)(2))

The workplace, the person certifying, the date or dates, and a title that says what the document is. If the assessment took two days on site, both dates belong on it. A review date isn't on the list, and neither is an expiration date or a signature.

The 1994 preamble explains why the requirement is this short:

OSHA believes that some form of record is needed to provide OSHA compliance officers and affected employees with appropriate assurance that the required hazard assessment has been performed. The Agency agrees with the commenter that it is not "necessary for employers to prepare and retain a formal written hazard assessment." (59 FR 16334)

It goes on to say that "the generation and review of extensive documentation would be unnecessarily burdensome," and its recordkeeping section says: "This final rule does not contain recordkeeping requirements." The rule doesn't say how long a certification stays good or how long to keep it.

The 1995 inspection guidelines, archived since, had the compliance officer verify two things: that the employer "has conducted a workplace hazard assessment," and that it has the certification. A certification with four items fits on one page. The assessment behind it is what answers questions. On the day someone asks why the wipe-down crew wears nitrile and not latex, the answer is the list of hazards and the PPE picked against each one. Federal OSHA doesn't require that list in writing. Writing it down anyway, on the certification form or in the JHA for the task, means the answer doesn't depend on who's still on the payroll.

Does the certification cover respirators?

No. Paragraph (g) draws the line:

(g) Paragraphs (d) and (f) of this section apply only to §§ 1910.133, 1910.135, 1910.136, 1910.138, and 1910.140. Paragraphs (d) and (f) of this section do not apply to §§ 1910.134 and 1910.137. (29 CFR 1910.132(g))

Section 1910.134 is titled "Respiratory protection." The hazard assessment and certification in paragraph (d), and the training in paragraph (f), stop where the respirator starts. If your assessment form has a respirator line, keep it: the assessment is a reasonable place to note an airborne exposure. But listing a half-mask on a certified PPE assessment doesn't take care of 1910.134, which has its own written program and its own dates. Its paragraph (l)(1) uses the same open wording as Appendix B:

The employer shall conduct evaluations of the workplace as necessary to ensure that the provisions of the current written program are being effectively implemented and that it continues to be effective. (29 CFR 1910.134(l)(1))

"As necessary" again, this time for the program. In 1910.134, the yearly dates are the fit test and the training.

Which PPE rules do run on a yearly clock?

The respirator rules do, and so does testing for some electrical gear. Under 1910.134, a tight-fitting facepiece gets fit tested before first use, again with a different facepiece, and every year after that:

The employer shall ensure that an employee using a tight-fitting facepiece respirator is fit tested prior to initial use of the respirator, whenever a different respirator facepiece (size, style, model or make) is used, and at least annually thereafter. (29 CFR 1910.134(f)(2))

Retraining follows the same calendar. Paragraph (k)(5) begins "Retraining shall be administered annually, and when the following situations occur:" and goes on to list them. On a construction site, 1926.103 brings all of it along: "The requirements applicable to construction work under this section are identical to those set forth at 29 CFR 1910.134 of this chapter." The test methods are covered in respirator fit testing in construction.

Equipment testing and inspection have separate schedules. In construction, 1926.97(c)(2)(viii) subjects electrical protective equipment to "periodic electrical tests," with maximum intervals in Table E-5, titled "Rubber Insulating Equipment, Test Intervals": "Before first issue and every 12 months thereafter" for blankets and sleeves, every 6 months for gloves. The same section has insulating equipment "inspected for damage before each day's use," and 1926.106(b) has buoyant work vests inspected "Prior to and after each use." 1926.97 even has a certification of its own, for the tests. It identifies "the equipment that passed the test and the date it was tested." That's a test record, not a hazard assessment.

The split was already visible in 1994. The preamble quotes a comment from Union Electric, which objected that the proposed training language "could imply that employees must be periodically retrained in the proper use of their equipment" and called that "unnecessary for such items as safety glasses, footwear and headgear." The next sentence: "Respirators already have a periodic training requirement." The final rule's retraining paragraph, (f)(3), runs on events.

What changes on a construction site?

Part 1926 has no general counterpart to 1910.132(d). Section 1926.28(b) sends the rules on "the use, selection, and maintenance of personal protective and lifesaving equipment" to Subpart E, and Subpart E has no hazard assessment in it and no certification of one. The duty to require PPE sits in 1926.28(a):

The employer is responsible for requiring the wearing of appropriate personal protective equipment in all operations where there is an exposure to hazardous conditions or where this part indicates the need for using such equipment to reduce the hazards to the employees. (29 CFR 1926.28(a))

Section 1926.95(a) has protective equipment "provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment," and 1926.95(c), as amended at 89 FR 100346 (December 12, 2024), covers design and fit:

Employers must ensure that all personal protective equipment: (1) Is of safe design and construction for the work to be performed; and (2) Is selected to ensure that it properly fits each affected employee. (29 CFR 1926.95(c))

The fit amendment has its own write-up in OSHA's PPE fit rule for construction.

The closest thing to a schedule sits in the general provisions. 1926.20(b)(2) calls for "frequent and regular inspections of the job sites, materials, and equipment to be made by competent persons designated by the employers," and 1926.21(b)(2) has the employer "instruct each employee in the recognition and avoidance of unsafe conditions." Neither mentions PPE or a hazard assessment, and "frequent and regular" isn't a number.

Part 1926 also has assessments for particular hazards. Section 1926.960(g)(1) addresses exposure to flames or electric arcs, and 1926.1408(a) addresses crane work near power lines. These task-specific provisions should be checked separately from the general industry PPE assessment and certification in 1910.132(d).

So for construction work, Part 1926 asks for no PPE hazard assessment certification and puts no date on one. The duties to require the right PPE and to make it fit are still there. If you want them on paper, the JHA for each task is a natural home: the step, the hazard, the PPE picked against it. The JHA guide has a template. Respirators keep their clock on site too, through 1926.103.

How do you track review dates without inventing a deadline?

A yearly review is a fine company policy. Write it down as yours. The certification under 1910.132(d)(2) already names the workplace, the person certifying and the date of the assessment. Put a next review date beside it with no label, and the next safety manager will read it as a federal deadline. Call it company policy on the form and in the binder.

Then watch for what changes the hazards. Appendix B, which is nonmandatory, points to new equipment and processes, accident records, and whether the PPE you picked still suits the work. None of those waits for the anniversary. When you redo an assessment, keep the old certification next to the new one. The 1994 rule has no recordkeeping requirement, but the two side by side show what changed.

HazComFast keeps that distinction on every record. The next review date of an assessment comes from an interval your company sets in Account Settings, 12 months unless you choose another, and once that date passes the assessment turns amber with "Review due (company policy)." The tip on the status says it in so many words: "Review due: the review date your company set has passed." Set the interval to 0 and periodic reviews stop altogether. A card at the top of the PPE Hazard Assessment page counts the reviews due across the whole account, and search finds any assessment by workplace, area or certifier.

The change that matters gets flagged on its own. Assign a chemical to a jobsite that a certified assessment covers, and a "Conditions changed" alert names the product and recommends a re-assessment. Re-assess, and the new version links to the old one, which stays readable under Versions, marked Superseded. A signed assessment is never rewritten: an edit is saved as a corrected version beside it. And an assessment can't be certified until its walk-through is recorded.

The PPE list starts from the SDS. When a product's SDS is read, the protective equipment its section 8 calls for is checked off in the manufacturer's own words, in English and Spanish, so forty products don't mean forty rounds of copying section 8 by hand.

Related reading: PPE for construction · OSHA's PPE fit rule for construction · Respirator fit testing in construction · The JHA template and guide