What Are OSHA’s Requirements for PPE Safety Training Under 1910 and 1926?

personal protective equipment

Key Takeaways

  • OSHA mandates five specific training elements for PPE under 29 CFR 1910.132(f): when PPE is necessary, what PPE is necessary, how to don and doff it, its limitations, and proper care and disposal.
  • Employees must demonstrate understanding before performing hazardous work; a signature on a roster is not enough.
  • PPE certification under OSHA refers to documented hazard assessment verification, not a card or course completion certificate.
  • PPE training is a continuous process triggered by workplace changes, new equipment, observed deficiencies, incidents, and near-misses, with retraining required whenever understanding or performance breaks down.

 

Why Do Injuries Still Happen When PPE Is “Available”?

Workers either aren't wearing it or are wearing the wrong kind for the job.

Nearly three out of five workers who suffered eye injuries were not wearing eye protection at the time of the accident, according to the Bureau of Labor Statistics. These workers most often reported that they believed protection was not required for the situation. Meanwhile, safety experts and eye doctors believe the right eye protection could lessen the severity or even prevent 90% of workplace eye injuries.

I find that most safety managers focus heavily on procurement. They obsess over ANSI ratings, supplier contracts, and inventory levels. Of course, all of that matters. But the moment PPE enters the building, the harder problem begins: making sure every worker knows when, how, and why to use it.

PPE safety training fixes the gap between “we have it” and “we use it correctly.” It addresses:

  • Hazard recognition (Can the worker identify situations that require protection?)
  • Selection (Does the worker choose the right type for the exposure?)
  • Fit and use (Can the worker wear it in a way that actually protects?)
  • Limitations (Does the worker understand what the equipment will not do?)

None of that just happens automatically. PPE sitting in a closet is just a waste of space and that's why OSHA's enforcement patterns show training as a major weak spot. In fact, fall protection training alone racked up 2,050 violations in fiscal year 2024, making it the number 7 most cited standard on OSHA's list.

 

What Is PPE Safety Training?

PPE safety training is the process of teaching workers how to select, use, and maintain PPE matched to their specific job hazards. I want to emphasize “specific” here because generic awareness videos or toolbox talks often fail the OSHA test. The training has to address the actual hazards in that worker’s environment, not a hypothetical factory somewhere else.

Before we get into the regulatory part, consider a real case. In December 2011, OSHA cited an industrial minerals company with 28 health and safety violations totaling $396,000 in proposed penalties at its Coffeen, Illinois facility. Among the charges: failure to assess the need for adequate personal protective equipment, inadequate eye protection, and inadequate information and training on PPE for dust containing silica.

Take note that this was not a one-off mistake, either. OSHA found similar violations at four of its other facilities within three months. Dr. David Michaels, then OSHA Administrator, called the problems “widespread and systemic.” Equipment failures intertwined with training failures intertwined with assessment failures.

Now contrast that with an employer who handles PPE training well. Hazards are identified task by task. PPE is chosen for those hazards. Workers are trained on what they will actually use, in the conditions they will actually face. Then the employer checks that people can use it correctly.

This is also where PPE training gets misunderstood. People talk about it like it’s one subject you can “cover” in a single session. It isn’t. PPE training breaks into categories, and the training gaps usually show up in the handoffs between them. I have laid out the main PPE categories most workplaces deal with below, so you can see what PPE training really includes.

types of ppe

 

What Are the OSHA PPE Training Requirements?

1910.132 (General Industry)

This is the primary general industry standard for PPE. 1910.132 covers the full lifecycle: hazard assessment, equipment selection, employee training, and ongoing maintenance. Paragraph (d) requires employers to assess the workplace for hazards that necessitate PPE and to certify in writing that the assessment was performed. Paragraph (f) contains the explicit training requirements that most employers reference when building their programs.

What makes 1910.132 useful is its specificity. Unlike broader “general duty” language found elsewhere, this standard tells you exactly what training must cover: five defined elements ranging from when PPE is necessary to how to dispose of it properly. It also requires employees to demonstrate understanding before performing hazardous work, and it mandates written verification that training occurred.

1926.21, 1926.95, 1926.28 (Construction)

Construction PPE requirements are distributed across three standards that work together. This fragmented structure confuses some employers, but understanding how the pieces fit helps with compliance.

1926.21(b)(2) establishes the general duty to instruct employees in recognizing and avoiding unsafe conditions. It does not itemize specific training topics the way 1910.132(f) does, but it creates an enforceable obligation: if a worker did not know they needed eye protection for a task, that is a potential violation regardless of whether the employer purchased safety glasses.

1926.95 addresses PPE selection and use in construction, covering equipment design, employer payment obligations, and proper fit. Unlike 1910.132 in general industry, this does not contain its own training provisions as those requirements come from 1926.21. However, 1926.95 does establish that PPE must be of safe design and construction for the work performed, and the 2025 revision added explicit language requiring employers to select PPE that properly fits each affected employee.

1926.28 is the enforcement hook. It requires employers to ensure employees wear appropriate PPE in all operations with hazardous exposures. In practice, OSHA cites 1926.28 when a worker is observed without required protection, and cites 1926.21 when the underlying instruction was deficient. The standards reinforce each other.

1910.134 / 1926.103 (Respiratory)

Respiratory protection operates under its own detailed standard because the stakes are higher. A poorly fitted respirator in an oxygen-deficient or toxic atmosphere can mean immediate death. General PPE training requirements do not cover this adequately.

1910.134 requires a written respiratory protection program that includes medical evaluations, fit testing, and training specific to respiratory hazards. The training requirements under paragraph (k) address why the respirator is necessary, its limitations and capabilities, proper donning and seal checking, emergency procedures, and how to recognize medical symptoms that may affect use. Annual retraining is mandatory.

1926.103 incorporates 1910.134 by reference for construction, so the same program requirements apply. If your hazard assessment identifies respiratory hazards, you cannot address them with general PPE training alone. Respiratory protection requires its own dedicated program.

What’s the Difference Between 1910 and 1926 for OSHA PPE Training?

29 CFR 1910.132(f) provides an explicit training checklist and tells you exactly what employees must be trained to know while

29 CFR 1926.21(b)(2) is broader as it states that employers must instruct employees in the recognition and avoidance of unsafe conditions and the regulations applicable to the work environment.

Does this mean construction employers can do less? No. OSHA compliance officers will still cite construction employers for inadequate training. The enforcement just follows a slightly different path: showing that the employer failed to instruct workers on hazards and applicable regulations, including PPE use.

Standard

Training specificity

Documentation / certification

1910.132(d)

Sets what PPE is needed (before training)

Written hazard assessment certification (workplace, certifier, date)

1910.132(f)

Checklist style: 5 required elements + employee must show understanding

Written certification of training (who, date, subject)

1926.21(b)(2)

Broad: instruct workers to recognize and avoid hazards (PPE is part of that)

Not spelled out as “certification,” but training records help in audits

1926.95

Covers PPE selection, fit, and payment (training handled by 1926.21)

Not framed as “certification,” but written training records are smart

1926.28

Requires employers to make employees use PPE when hazards exist

Often cited when PPE isn’t worn; documentation supports your defense

1910.134(k)

Detailed: why needed, limits, donning, seal checks, emergencies, medical signs

Part of a written respiratory program; fit test + training records required

1926.103

Incorporates 1910.134 requirements

Same program and record expectations as 1910.134

 

What Does OSHA Require Employers to Teach?

Under 1910.132(f)(1), OSHA is fairly consistent about what it expects employers to teach. The agency is not asking for perfect recall of regulations, but whether workers know when protection is required, what to use, and how to use it without creating new risks. What follows are the core elements OSHA expects PPE training for employees to cover, regardless of industry.

When PPE Is Necessary

This part of the training is all about getting your employees to understand that there is a situation and a task that makes PPE a must. You may think it's pretty simple but actually, a lot of people still mess this up. Remember that eye injury report from the BLS? Workers most often said they believed protection was not required for the situation. That belief was wrong, and it stemmed from inadequate training on when PPE becomes necessary.

Effective training on this element covers:

  • Specific hazards present in the employee’s work area (chemical splash zones, impact hazards, noise levels, fall exposures)
  • Tasks that require protection even when hazards are not immediately visible (entering a permit-required confined space, working near energized equipment)
  • How to recognize changing conditions that may require additional PPE (a normally quiet area becomes noisy during maintenance, a clean area becomes contaminated during a spill response)

I find it helps to walk through actual work scenarios during training. “You are grinding a weld bead. What PPE do you need? Now the grinder kicks back and throws sparks toward your coworker. What PPE should they have been wearing?” Scenario-based training builds hazard recognition skills better than reading a list of requirements.

What PPE Is Necessary

Once employees understand when protection is required, they need to know what type of protection to use. This is not as obvious as it sounds. Safety glasses come in different impact ratings. Gloves come in materials suited for different chemical exposures. Hard hats have classes for electrical protection. Selecting the wrong type provides a false sense of security.

Training on this element should address:

  • The specific PPE types approved for each hazard in your workplace
  • How to read markings and ratings (ANSI Z87.1 for eye protection, ASTM ratings for cut resistance)
  • The difference between similar-looking equipment with different protection levels (safety glasses vs. chemical splash goggles, leather gloves vs. chemical-resistant gloves)
  • Where to find PPE and how to request replacements

Employers who maintain PPE selection charts or job hazard analysis forms linked to specific equipment make this training more concrete. A worker should be able to look at their task and identify exactly what PPE is required.

How to Properly Don, Doff, Adjust, and Wear PPE

This is the hands-on core of PPE donning and doffing training. Knowing that you need a harness does not help if you cannot put it on correctly. OSHA explicitly requires training on donning (putting on), doffing (removing), adjusting (achieving proper fit), and wearing (maintaining protection throughout use), which I will discuss in detail later on.

Each PPE type has specific techniques:

  • Eye protection: Ensure side shields are in place, check that prescription inserts are properly seated, verify anti-fog treatment if applicable
  • Hearing protection: Proper insertion technique for earplugs (roll, pull, hold), proper seal for earmuffs (hair and glasses can break the seal)
  • Gloves: Check for proper sizing, inspect for holes or degradation before donning, understand when to change gloves during extended use
  • Hard hats: Adjust suspension for secure fit, position correctly on head (brim forward unless rated for reverse wear), understand when accessories are required (chin strap at heights, face shield for specific tasks)
  • Fall protection harnesses: Proper leg strap routing, dorsal D-ring position, chest strap adjustment, inspection of webbing and hardware before each use

The doffing sequence is important too, especially for PPE that may have gotten contaminated. Workers need to learn to take off gloves without touching the outside, and handle used respirators without getting contaminated. I have had employees ace the written test and then really struggle with the hands on part. That is the gap that this training is meant to close.

Limitations of the PPE

Every piece of protective equipment has boundaries. Training on limitations prevents the dangerous assumption that PPE makes a worker invincible. I’ve gathered examples of limitations that training on PPE must address:

  • Safety glasses rated for impact do not protect against chemical splash; goggles or a face shield may be required for liquid hazards
  • Cut-resistant gloves resist cuts but may not resist punctures; needle stick hazards require different protection
  • Hard hats protect against falling objects but do not protect against side impacts unless specifically rated
  • Hearing protection has a noise reduction rating (NRR), but real-world protection is typically less than the labeled value due to fit issues
  • Respirator cartridges have service life limits based on contaminant concentration and humidity; breakthrough can occur without warning
  • Fall arrest systems have maximum arrest forces and fall distances; exceeding the rated capacity or fall clearance can result in injury even when the system activates

This element also covers what PPE cannot do at all. No PPE eliminates a hazard; it only reduces exposure or mitigates consequences. Engineering controls and administrative controls should be primary defenses where feasible.

When I give talks on this stuff I like to tell real-life stories about workers who got hurt because they didn’t understand the limitations of their PPE. A worker who’s aware that their cut-resistant gloves will only protect them against an ANSI A4 glass cut but the glass they’re handling could easily cut them with forces up to ANSI A6 has the chance to change their actions accordingly.

Proper Care, Maintenance, Useful Life, and Disposal

The sad truth is that PPE degrades over time. UV light can weaken harness webbing, chemicals can harm glove materials, and impacts can compromise hard hat shells even if there’s no obvious damage. Training needs to cover how to keep your PPE in good nick and how to know when it needs to be retired.

Care and maintenance training includes:

  • Cleaning procedures appropriate to the PPE type (some respirator components cannot be submerged; some gloves cannot be washed)
  • Storage requirements (UV protection for synthetic materials, temperature limits, separation from chemicals)
  • Inspection criteria before each use (what defects to look for, what is repairable vs. requires replacement)

Useful life training addresses:

  • Manufacturer guidance on replacement intervals (hard hats typically have a 2-5 year service life from first use depending on conditions)
  • Condition-based replacement triggers (visible cracking, fading, stiffness, chemical exposure history)
  • Documentation requirements for inspected equipment (some employers maintain harness inspection logs; some respiratory programs require cartridge change schedules)

Disposal training ensures that old PPE doesn’t somehow end up back in service. Employees should know to chop the straps off a used harness, puncture those chemical gloves, and mark the gear as “DO NOT USE” before tossing it in the bin.

But even with clear rules, guess what? PPE still somehow gets put back in rotation when people get in a hurry or aren’t sure what to do, or when a “looks fine to me” judgment slips through. That’s why OSHA PPE training rule is written to prevent that. According to 29 CFR 1910.132(f)(2), employees have to show they understand the training and can use the PPE properly before they get to do a job that requires it.

core elements of ppe training

 

How Do You Prove Employees Understand PPE Training?

According to OSHA’s enforcement directive CPL 02-01-050, compliance officers will determine whether employees who perform work requiring PPE can demonstrate understanding and proper use. OSHA states:

“The CSHO shall determine whether each employee performs work requiring the use of PPE can demonstrate an understanding of the required training, and the ability to use PPE properly. Lack of an employee’s knowledge in or use of, assigned PPE would be indicative that the employee has not retained the requisite understanding or skill.”

Translation: if an inspector watches your worker put on a harness incorrectly, that is evidence of a training failure. The worker’s signature on a training log does not immunize you.

Acceptable methods for demonstrating competency include:

  • Written assessment: Quiz or test covering the five training elements
  • Hands-on demonstration: Worker shows correct donning, adjustment, doffing, and inspection
  • Observed task performance: Supervisor watches the worker use PPE correctly during actual work

For fall protection specifically, the ANSI/ASSP Z359.2 standard emphasizes hands-on practice as well. Kevin Denis, chair of the ANSI/ASSP Z359.2 subcommittee, says this directly in an ASSP interview:

“The standard requires that training include experiential exercises, which means that it must include physical hands-on activities where the authorized person has the opportunity to touch, wear and carry the equipment and feel how it's used. They should connect every piece together and understand fall distances and clearance estimates.”

Slides and videos alone do not meet this bar. As for documentation, it must include:

  • Name of the employee trained
  • Date(s) of training
  • Identification that training was provided under 1910.132(f)
  • Method of competency verification (how you confirmed understanding)

Some employers maintain skill matrices showing which employees have demonstrated competency on which PPE types. That level of documentation pays off during audits.

 

When Does OSHA Require Retraining?

OSHA specifies three triggers for retraining under 1910.132(f)(3):

  1. Workplace changes that render previous training obsolete (new equipment, new hazards, modified processes)
  2. Changes in PPE types to be used (switching from one glove material to another, introducing new respiratory protection)
  3. Observed deficiencies in an employee’s knowledge or use of assigned PPE

That third trigger is the one I watch most closely. If a supervisor sees a worker wearing a face shield without safety glasses underneath, that is an observed deficiency. If a worker stores a harness in direct sunlight, that is an observed deficiency. Each of these triggers a retraining obligation rather than just a verbal reminder.

I also recommend that we take the initiative to offer periodic refresher training on PPE, even when none of the three triggers come into play. Workers can get rusty, habits can slip, and annual refresher training will keep knowledge up to date and also demonstrate your ongoing commitment to keeping your workplace safe.

 

What Does OSHA Mean by “PPE Certification”?

This is a point of confusion I encounter quite often. When OSHA uses the word “certification” in the context of general PPE, it refers to documented verification of the hazard assessment; it’s not training completion certificates or professional licensing.

PPE certification requirements under 1910.132(d)(2) state that the employer shall verify the required workplace hazard assessment has been performed through a written certification that includes:

  • Identification of the workplace evaluated
  • Name of the person certifying the evaluation was performed
  • Date(s) of the hazard assessment

This certification must exist before training can be meaningful. You cannot train workers on what PPE to use if you have not first identified what hazards they face. Understanding these PPE certification requirements is the first step; the certification connects assessment findings to training content.

Here is the linkage:

hazard to ppe to training workflow

For example, a hazard assessment identifies airborne silica exposure during concrete cutting. You select a half-face respirator with P100 filters. Training addresses that specific respirator, for that specific task, including fit check procedures and filter change intervals. The written certification anchors the entire chain. Separate training documentation then verifies that each employee received and understood the training. Both pieces of paper matter.

📄Certification vs. Certificate: OSHA’s PPE certification is an employer’s written verification that a hazard assessment was performed. It is not a wallet card, vendor certificate, or professional credential. We need to make sure we get this right or we risk compliance issues.

 

Who Is Responsible for Training Workers on the Use of PPE?

OSHA places the duty for PPE safety training on the employer, but execution involves multiple roles.

An April 2024 OSHA memorandum clarified that training duties impose a “separate compliance duty with respect to each employee,” meaning “each failure to train an employee may be considered a separate violation.”

Let that sink in. If you have 20 workers who needed harness training and you failed to train all of them, that could theoretically become 20 separate violations. At $16,550 per serious violation as of January 2025 (per OSHA penalty schedules), you are looking at potential exposure exceeding $330,000 for a single training gap.

Responsibility typically distributes as follows:

ppe training roles and responsibilities

There’s also a simple RACI-style way (Responsible, Accountable, Consulted, Informed) to assign duties. I like using this because it prevents the most common failure: everybody assumes somebody else handled it.

Example scenarios:

Task

Responsible

Accountable

Consulted

Informed

Update hazard assessment for the new task

Safety manager or EHS coordinator (does the assessment)

Operations manager or site manager (signs off)

Supervisor/foreman, maintenance, affected workers

HR/training admin, department leads

Select PPE for the task

Safety manager or EHS coordinator

Operations manager or site manager

Supervisor/foreman, vendor/manufacturer rep (as needed), industrial hygienist (if applicable)

Purchasing, department leads

Deliver PPE training for the task

Supervisor/foreman (task-level training) or designated trainer

Safety manager or training manager

Safety/EHS (content), experienced operators

Operations leadership, HR/training admin

Run hands-on PPE donning and doffing training

Supervisor/foreman or designated trainer

Safety manager or training manager

Safety/EHS, PPE vendor rep (as needed)

Department leads, HR/training admin

Verify competency and document

Supervisor/foreman (observes) + training admin (records)

Safety manager (owns verification method)

Safety/EHS, QA (if they audit records)

Operations leadership, HR

Monitor use and trigger retraining

Supervisor/foreman (daily observation)

Operations manager (enforces)

Safety/EHS (retraining criteria), HR/training admin

Safety committee, department leads

 

How to Run PPE Donning and Doffing Training Correctly

PPE donning and doffing training deserves its own separate discussion because this is where theory meets practice. A worker can pass a written quiz on harness components but still connect the dorsal D-ring incorrectly.

OSHA provides eTool guidance on donning and doffing procedures for electrical PPE, and the principles apply across categories.

For each PPE type, training should include:

  1. Inspection before donning: What to check, what defects disqualify the equipment
  2. Correct donning sequence: Order matters, especially when multiple PPE items are used together
  3. Adjustment for fit: How to achieve proper seal, tension, or coverage
  4. Fit verification: Positive/negative pressure checks for respirators, tug tests for harnesses
  5. Correct doffing sequence: Order also matters here, especially for contaminated PPE
  6. Post-use inspection and storage: What to check after removal, how to store

Sequence When Multiple PPE Items Are Used

When a task requires multiple PPE items, the donning and doffing order affects protection. There is no single universal sequence, and the correct order depends on the hazards present and the specific PPE being used. That being said, some general principles also apply:

Donning order: A common approach is to work from the core outward and from the bottom up. Foot protection first, then body coverage, then hand protection, then eye/face, then respiratory, then head (if applicable). However, manufacturer instructions and site-specific protocols may specify different sequences based on the hazards involved.

Doffing order: The guiding principle is to remove the most contaminated items first while avoiding contact between contaminated surfaces and skin or cleaner PPE. In healthcare and chemical settings, this typically means removing gloves first, since hands have the greatest contamination potential. The exact sequence should follow facility protocols and CDC or OSHA guidance for the specific hazard.

I used to see training programs that only covered one PPE type at a time, and never touched on how they all work together. That's a gap. Workers doing jobs like grinding might need to wear safety glasses, a face shield, ear protection, gloves, and an apron all at once. They need to know the right order.

Fit Checks and Adjustment Techniques

Fit is not optional, and effective PPE donning and doffing training must address this directly. An improperly fitted respirator provides zero protection. A harness worn too loose shifts during a fall, potentially causing suspension trauma or slipping off entirely.

Training should include:

  • How to verify correct fit (visual inspection, user seal checks, fit test procedures where applicable)
  • Adjustment points and acceptable ranges
  • What to do if fit cannot be achieved (report to supervisor, request a different size/model)

Removal Without Self-Contamination

This applies most strongly to PPE used in chemical, biological, or radiological settings, but the principle matters anywhere PPE may carry residue. Workers should learn to remove gloves without touching the exterior surface, doff contaminated coveralls without contacting the outer layer, and handle eye protection without transferring substances to their face.

Research on healthcare workers found that contamination during doffing is common. One study observed incorrect doffing in 90% of cases. The most frequent errors included removing gowns from the front rather than pulling away from the shoulders, touching the front of masks during removal, and contacting contaminated surfaces with bare hands mid-sequence. A separate study found that workers who made multiple doffing errors were significantly more likely to be contaminated afterward. These mistakes translate across industries.

Training should address:

  • Hand hygiene timing: Workers often assume hand hygiene happens only at the end. In contaminated environments, it may be required between doffing steps, such as after removing gloves and before touching the face to remove a respirator.
  • Deliberate pacing: Doffing errors increase when workers are fatigued, rushed, or distracted. Training should emphasize slow, methodical removal rather than speed.
  • Visual aids at doffing stations: Posted step-by-step sequences reduce reliance on memory. For high-hazard work, a trained observer or buddy system adds a second layer of verification.
  • Practice with detection tools: Using fluorescent lotions or UV powder during training reveals contamination transfer that workers would otherwise miss. Research has shown that after seeing visual evidence of their contamination, workers significantly reduced skin and clothing contamination from 30% to 3%. Seeing the evidence changes behavior more effectively than verbal instruction alone.

 

How to Build a PPE Training Program That Holds up in an Audit

Now we get practical. If you want OSHA PPE training that survives scrutiny, follow this five-step structure.

Step 1: Turn Hazards Into Training Requirements

Start with your hazard assessment findings. For each identified hazard, map it to the required PPE, then to specific training content. You can also use a matrix, which can become your training curriculum, and each hazard-PPE combination gets its own module.

Example matrix:

Hazard

Location/Task

Required PPE

Training Topics

Flying metal particles

Grinding station

Safety glasses with side shields, face shield

Impact ratings, when to use face shield vs. glasses alone, inspection for scratches

Noise above 85 dBA

Press area

Earplugs

Insertion technique, NRR derating, signs of hearing damage

Fall exposure >6 ft

Roof access

Full body harness, lanyard, anchor

Harness inspection, dorsal D-ring connection, fall clearance calculation, anchor selection

Step 2: Deliver Training by Task

Organize PPE training for employees by job task rather than PPE type. Workers learn what they need for their actual work, not an abstract catalog of all PPE that exists.

A press operator does not need detailed training on chemical suits if they never handle chemicals. A painter does not need detailed training on cut-resistant gloves if they never handle sharp materials. Match training content to exposure.

This also means including hands-on demonstrations. There is evidence that supports this approach: a meta-analysis examining 95 studies found that as training becomes more engaging through hands-on methods, reductions were seen in accidents, illnesses, and injuries, and training improves behavioral performance.

Lectures and videos rate as “least engaging” in that research. Hands-on training with behavioral modeling rates as “most engaging.” The difference in outcomes is measurable.

Step 3: Test Competency and Close Gaps

To make sure your PPE training is up to snuff, you need to put people to the test. This means both written and practical tests to make sure they can actually use the gear. Keep track of who passed and who didn't, and retrain anyone who is struggling.

I know its tempting to just pass everyone and be done with it, but that just sets people up for trouble down the road. You need to make sure people are really getting it, not just going through the motions. And if someone can't do a simple user seal check on their respirator, well, they are not trained.

Lindsay Bell, CSP, IG Americas SHEQ human performance manager, in an ASSP interview on workforce communication, recommends practical approaches:

“One thing I like to do with larger groups — because a lot of times you're walking into a room and don't know the people — is to always have support materials. This could be a participant guide that has activities and supplemental information. It’s important to write down any key points or takeaways so employees can digest them at their own pace and refer to them later. If you have key points you want them to know, you can put that in a wallet card or make a one-pager that summarizes what you're talking about. If you’re doing a virtual training, you can use breakout groups for small group discussions and use polls and other tools within the virtual platform. One of the most important things in virtual training is keeping people within the platform that you’re using. Once you start sending them links, you’re sending them to the rest of the internet where they can get distracted.”

Wallet cards or one-pagers summarizing key points help workers retain information after the training session ends. I have found these particularly useful for PPE that is used infrequently. A worker may remember the session well the following week but forget details six months later when they finally need that equipment.

Step 4: Manage Refreshers and Retraining Triggers

Even if OSHA doesn't require it, you should still have a system in place for regular refreshers on PPE training. Annual refreshers are the norm, by the way. But you also need a way to flag when people need retraining and that includes:

  • Incident occurred involving PPE → review training for all affected workers
  • Near-miss reported → evaluate whether training gap contributed
  • Supervisor observes deficiency → retrain that worker
  • PPE type changes → retrain all users
  • Workplace condition changes → update training content and retrain

I track these triggers in a simple spreadsheet with dates and actions. When an inspector asks “how do you handle retraining?” you can show them the system and the records.

Step 5: Improve Training Using Incidents and Near-Misses

Every incident involving PPE, whether it results in injury or not, contains information your training program needs. The question is whether you capture it.

When a near-miss occurs, the instinct is often to remind workers to “be more careful” and move on. That is a missed opportunity. A near-miss where a worker’s safety glasses fogged and they removed them to see better tells you something about your equipment selection, your training on anti-fog options, or both. A near-miss where a harness was donned incorrectly tells you the hands-on portion of your training did not stick.

Feed incident investigations back into your training on PPE content. If a near-miss reveals a knowledge gap, update the training and retrain affected workers. If an injury investigation shows that the worker knew the requirement but chose not to comply, that points to a different problem: enforcement, equipment comfort, or work pressure that discourages proper PPE use.

I recommend a simple after-action process:

  1. Document what happened and what PPE was involved
  2. Interview the worker and witnesses about what they understood their obligations to be
  3. Compare their understanding to what your training actually covered
  4. Identify the gap (knowledge, skill, equipment, or behavioral)
  5. Update training content or delivery method accordingly
  6. Retrain affected workers and document the change

This creates a feedback loop. Your PPE safety training program becomes a living system that learns from experience rather than a static compliance exercise that repeats the same content year after year while the same problems keep occurring.

how to build a ppe training program

 

The Cost of Getting This Wrong

The gap between compliance and protection is not about budget or intent. Most employers want their workers safe. The gap is about follow-through. Did you verify the worker can actually don that respirator correctly, or did you just show a video and collect a signature? Did you explain why the harness inspection matters, or did you hand them a checklist and assume they would figure it out?

Workers notice when training is real versus when it is theater. They know the difference between a supervisor who watches them demonstrate a skill and one who just needs them to initial a form. That difference shows up in how they treat PPE when no one is watching.

PPE training for employees is not administrative overhead. It is the bridge between equipment that exists and equipment that protects. Build that bridge with the same rigor you apply to the hazards it addresses, and your workers go home the same way they arrived.

 

FAQs

Does OSHA certify PPE?

No. OSHA sets standards for PPE selection and use but does not certify or approve specific products. Equipment certification comes from organizations like ANSI (American National Standards Institute), NIOSH (for respirators), and third-party testing labs. OSHA requires employers to select equipment that meets applicable standards.

Who is required to provide PPE?

Under 1910.132(h) and 1926.95(d), employers must provide required PPE at no cost to employees, with limited exceptions for items like non-specialty safety-toe footwear and prescription safety eyewear that workers may use off the job.

What training is needed for PPE use?

Training on PPE must cover the five elements specified in 1910.132(f)(1): when PPE is necessary, what PPE is necessary, how to don/doff/adjust/wear it, its limitations, and proper care, maintenance, useful life, and disposal. Employees must demonstrate understanding before performing hazardous work.

How often does OSHA require PPE training sessions to be conducted?

OSHA does not mandate a specific interval for PPE safety training sessions. Retraining is required when workplace changes occur, PPE types change, or an employee shows deficiency in knowledge or use. Many employers conduct annual refreshers as best practice, and some industry standards (such as ANSI Z359.2 for fall protection programs) recommend periodic retraining.

What are the potential penalties for failing to address non-compliance in PPE training under OSHA regulations?

As of January 2025, serious violations carry a maximum penalty of $16,550 per violation. Willful or repeated violations can reach $165,514 per violation. Under OSHA’s instance-by-instance citation policy, PPE training failures can be cited separately for each untrained employee, meaning a training gap affecting 10 workers could result in 10 separate citations.

 

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The material provided in this article is for general information purposes only. It is not intended to replace professional/legal advice or substitute government regulations, industry standards, or other requirements specific to any business/activity. While we made sure to provide accurate and reliable information, we make no representation that the details or sources are up-to-date, complete or remain available. Readers should consult with an industrial safety expert, qualified professional, or attorney for any specific concerns and questions.

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