Most employers can produce a glove policy. Far fewer can produce the document 8 CCR section 3380 actually asks for, which is a written certification that somebody walked the workplace, looked for hazards, and decided what protection those hazards require.
The duty to assess
Section 3380(f)(1) states that 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. Where hazards are found, the employer selects the PPE that will protect the affected employee from the hazards identified in the assessment, and has each affected employee use it.
Note the order. The hazard is identified first and the equipment is selected from it. Buying safety glasses for everyone and calling it a program inverts the standard, and it produces the predictable result: eye protection everywhere and the wrong gloves at the one station where the solvent is.
The certification
Section 3380(f)(2) 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, and the date or dates of the hazard assessment.
Three items. A workplace, a name, a date. It can be one page. The reason it is so often absent is that nobody was ever assigned to sign it, and a certification with no signature is not a certification.
What a usable assessment looks like
Walk it by area or by task, not by category of equipment. For each one, write down what could reach the body and how: impact, penetration, compression, chemical contact, heat, harmful dust, light radiation, noise, falling objects. Then record the selection that follows and why.
The chemical column is where generic assessments fail. Glove material is chemical-specific; nitrile is not a universal answer, and a breakthrough time is a property of a pairing, not of a glove. If the assessment does not name the chemical and the material chosen for it, it has not done the work.
Training, and proof of it
Under section 3380(f)(4), training covers when PPE is necessary, what PPE is necessary, how to properly don, doff, adjust and wear it, the limitations of the PPE, and its proper care, maintenance, useful life and disposal.
Then the requirement that separates this standard from most others: each affected employee shall demonstrate an understanding of the training and the ability to use the PPE properly before being allowed to perform work requiring it. A signature on a roster is attendance. The standard asks for a demonstration. Watch the person put the respirator on, or fit the face shield, and record that you watched.
The limitations clause
“The limitations of the PPE” is a required training topic and it is almost never taught. A dust mask is not protection against solvent vapor. Safety glasses are not a splash barrier. A cut-resistant glove has a rating and the rating has an end. An employee who believes their equipment protects them against something it does not is in more danger than an employee wearing nothing, because they will put their hands somewhere they otherwise would not.
The reassessment nobody schedules
Hazard assessments go stale when processes change, when a new chemical comes in, when a line is moved, when a task is added. Nothing in the standard sets a calendar interval, which is exactly why a certification dated four years ago and a product line that turned over twice since is a problem. Tie the reassessment to change, put the trigger in the injury and illness prevention program, and date every revision.
Michael Karl McNeil — environmental health and safety, industrial hygiene, Cal/OSHA citation defense.
Michael Karl McNeil 