The $60 Boot Allowance and the Bulk-Purchased N95s

Start with the duty: §1910.132(a) requires the employer to provide PPE wherever hazards require it, and §1910.132(h) requires the employer to pay for it. The exceptions are narrow:

• Non-specialty safety-toe footwear may be left to the employee to purchase only if the employer permits it to be worn off-site. A $60 allowance toward such boots is defensible - but if the boots are specialty footwear (metatarsal guards, electrical-hazard, puncture-resistant), the employer must pay in full.
• Non-specialty prescription safety eyewear may also be employee-purchased where it may be worn off-site.
• Ordinary clothing and items the employee chooses to wear voluntarily are not covered.

Everything else here is the employer's cost: hard hats, safety glasses, high-visibility vests, gloves, and the respirators. The employer also must pay for replacement PPE unless the employee lost or intentionally damaged it.

The 'bring your own' posting is not a lawful transfer of the obligation. Employee-owned PPE may be permitted, but only if the employer verifies it is at least as effective as required PPE, keeps it in serviceable condition, and trains on it. A cracked, pencil-punctured hard hat fails that test and must be replaced at the employer's expense - destroyed before the next shift.

Also missing: the written hazard assessment certification required by §1910.132(d).

Eyewear. §1910.133(a)(3) requires employees whose vision requires corrective lenses to wear eye protection that incorporates the prescription or that is designed to fit over the glasses. Ordinary prescription lenses - even polycarbonate - are not safety eyewear unless they meet the ANSI Z87 impact standard. A saw operator with a high-velocity chipping/cutting exposure needs Z87-rated prescription safety glasses or goggles designed to be worn over them, employer-paid (non-specialty version may be employee-purchased only if it can be worn off-site).

Respirators. Required use triggers the full §1910.134 program:

1. Written program with a designated administrator (c).
2. Medical evaluation before fit testing or use (e) - questionnaire reviewed by a PLHCP.
3. Annual fit test, by an OSHA-accepted protocol, for each make/model/size (f).
4. No facial hair that interferes with the sealing surface of the facepiece (g)(1)(i). Both bearded workers cannot be fit tested or wear a tight-fitting facepiece until they are clean-shaven - or they must be moved to a loose-fitting PAPR.
5. Training (k), cleaning/storage/inspection (h), and selection based on hazard (d).

N95s bought in bulk with no medical evaluation, no fit test, and no program is a violation on its face. If the only use were voluntary filtering-facepiece use, a full program would not be required - but Appendix D information would be. Here the dust control depends on the respirators, so the use is not voluntary.

The signed sheet accomplishes nothing except evidence that the employer knew training was required. §1910.132(f) sets the content; a signature line is not instruction.

The training must cover, at minimum:

1. When PPE is necessary (and the hazard assessment is what tells you).
2. What PPE is necessary.
3. How to don, doff, adjust, and wear it - demonstrated.
4. The limitations of the PPE (an N95 with a beard does not seal; a cracked shell is not a hard hat).
5. Care, maintenance, useful life, and disposal.

Each employee must demonstrate understanding and the ability to use the PPE properly before performing work requiring it. Retraining is required when the workplace changes, when new PPE is introduced, or when an employee shows by behavior that they don't understand - and the cracked hat and the 'polycarbonate glasses' comment are exactly that evidence.

The employer must also prepare a written certification of training with the employee's name, date, and the subject of the training. The fix here is a short, documented toolbox session per hazard, not a longer sign-in sheet.