How to Run a Workplace Hazard Assessment Under Cal/OSHA §3380
Cal/OSHA’s PPE general requirement, Title 8 §3380, puts a written hazard assessment on every California employer who issues protective equipment. That includes most manufacturers, food processors, warehouses, chemical distributors, and labs.
Cal/OSHA’s PPE general requirement, Title 8 §3380, puts a written hazard assessment on every California employer who issues protective equipment. That includes most manufacturers, food processors, warehouses, chemical distributors, and labs. The rule is direct: assess the workplace for hazards, select the right PPE, certify the selection in writing, and train each employee on what they’re wearing and why.
The standard names the requirement. It doesn’t hand you a method. This guide walks through how a §3380 assessment actually gets done at a California facility, what to look for, and what the written record needs to contain when it’s finished. For the broader program this assessment supports, see our Injury & Illness Prevention Program guide for California employers. For the service side of how CDMS delivers this work, see our PPE and hazard assessment services page.
What §3380 Actually Requires
The §3380 obligation has four working parts. Most facilities can quote the first one and forget the rest.
Assess the workplace for hazards that require personal protective equipment.
Select PPE that protects the affected employees from the identified hazards.
Certify in writing that the workplace was assessed, identifying the workplace evaluated, the person doing the assessment, the date, and that the document is the written certification of selection.
Communicate the selection to each affected employee and train them on when PPE is needed, what PPE is required, how to put it on and take it off, the limits of the PPE, and how to maintain and dispose of it.
Without the written certification page, the assessment is not §3380-compliant. That’s the document an inspector wants to see, and it’s the piece most often missing when we walk a facility for the first time.
Before You Walk the Floor
A hazard assessment that produces a defensible certification starts with preparation. Pulling these documents and items together first makes the walk-through faster and the resulting report more accurate.
- A current facility map with work areas, equipment locations, and PPE zones marked
- The list of job classifications and a brief description of what each one does
- Safety data sheets for chemicals in use
- The existing PPE program, if any, and any prior hazard assessment
- Incident and near-miss logs from the last three years
- The IIPP, training records, and any task-specific written programs (LOTO, hot work, confined space, hearing conservation)
- A camera or phone for documentation. Every finding gets a photo.
If a prior §3380 certification exists, read it before the walkthrough. The fastest way to identify gaps is to see what was assessed last time and check whether the operation has changed since.
The Walk-Through, Step by Step
This is how the assessment runs on site. Two people is better than one. One asks the questions and takes notes, the other photographs and observes the work in real time.
Start at the receiving dock and work the process flow. Don’t walk by department label. Walk the path materials take through the facility, from delivery to finished product to waste-out. Hazards cluster around transitions: loading, transfer, mixing, packaging, storage.
For each work area, identify the tasks performed there. A single area can contain multiple tasks with different PPE needs. The mixer operator, the cleaner who sanitizes the mixer between batches, and the maintenance tech who services it are three different exposures.
For each task, evaluate exposure by body part. Eyes, face, head, hearing, hands, arms, feet, body, respiratory. For each one, ask what could strike, penetrate, crush, burn, splash, or be inhaled.
Watch the work, not the procedure. What employees actually do is often different from the written SOP. Note where signage says “safety glasses required” but employees aren’t wearing them, and ask why. The answer reveals whether the gap is training, fit, comfort, or enforcement.
Interview the people doing the work. Floor employees know which PPE pinches, which gloves don’t hold up against the chemical they use, and which areas are skipped when nobody’s watching. Supervisors know what they enforce. Managers know what the program says. All three answers matter.
For each finding, rate it. Mark it as meeting requirements, not applicable to this area, or rate it on a likelihood and severity scale. That risk rating sets the priority order in the final report and drives which PPE recommendations are urgent.
Photograph everything. The photo is what makes the finding defensible six months later when the supervisor has rotated out and nobody remembers the conversation.
Assessment turned up program gaps? Your gap assessment found IIPP issues: now what? →
Hazard Assessment Checklist
These are the hazard categories to evaluate at every California facility under §3380. Not all of them apply to every site. The checklist forces a deliberate yes or no on each category instead of leaving any out by accident.
Physical hazards
- Impact (falling or flying objects, struck-by, struck-against)
- Penetration (sharp objects, nails, needles, broken glass)
- Compression (rollover, pinch points, equipment crush)
- Cuts and lacerations (blades, sheet metal, glass)
- Slips, trips, falls (wet floors, cords, elevation changes)
- Falls from height (mezzanines, ladders, platforms, rooftops)
Chemical hazards
- Toxic exposure (inhalation, skin absorption, ingestion)
- Corrosive exposure (acids, bases, splash hazards)
- Flammable and combustible materials
- Compressed gases
- Hazardous dusts
Thermal and energy hazards
- Heat (hot surfaces, molten materials, steam, hot work)
- Cold (refrigerated storage, cryogenics)
- Electrical (shock, arc flash, static, lockout/tagout scope)
- Radiation (ionizing for x-ray or gauging equipment; non-ionizing for welding arc, lasers, UV)
Biological and environmental hazards
- Biological (bloodborne pathogens, mold, bacteria, animal handling)
- Noise (any operation above 85 dBA)
- Ergonomic (lifting, repetition, awkward posture, vibration)
- Temperature extremes (indoor heat under §3396, outdoor heat under §3395)
- Visibility (low light, fog, traffic areas)
For each box checked, the assessment must document where the hazard occurs, which job classifications are exposed, what PPE is selected, and what consensus standard the PPE must meet (ANSI Z87.1 for eye protection, ANSI Z89.1 for head protection, ASTM F2413 for footwear, ANSI Z49.1 for welding, ANSI/ISEA 105 for hand protection, ANSI/ISEA Z358.1 for emergency eyewash and shower stations).
For a comparison of how this maps to job-by-job hazard analysis, see JHA vs. PPE assessment: what’s the difference.
The Written Certification
The certification page is the §3380 deliverable. It’s short and it has to contain specific elements. At minimum:
- The workplace evaluated, by name and address
- The name of the person certifying the assessment
- The date the assessment was performed
- A statement that the document is the written certification of hazard assessment and PPE selection
This page sits at the front of the assessment report. Behind it: the body-part-by-body-part findings, the PPE selected for each exposure, the consensus standard each item meets, the work-area photographs, and the training and re-issue procedure. The full package lives in your IIPP appendix and at the PPE issue point.
Where Most Facilities Fall Short
When we walk a California facility for the first time, the most common §3380 deficiency isn’t a missing PPE program. It’s a program that exists but doesn’t match the work. Three patterns show up over and over:
- Generic template, no facility specifics. A downloaded PPE policy that lists hazards the facility doesn’t have and misses hazards the facility does have. An inspector reading it sees a document built for a different operation.
- No certification page. Findings, photos, and recommendations all in place, but no signed and dated certification at the front. Under §3380, that omission means the assessment was never formally completed.
- Stale assessment, current operations. The assessment is two years old. Since then, a new chemical was introduced, a paint booth was added, or a shift was extended. The §3380 obligation requires the assessment to be revisited when operations change.
The fix in each case is the same: walk the facility against the actual operation, document each hazard category against each job classification, photograph the work, and certify the document with a signature and date.
Next Steps
If you’re being asked to produce a §3380 certification you don’t have, or if your existing PPE program hasn’t been updated since the floor changed, the most efficient path is one walk-through that produces the full deliverable. We come to your facility, evaluate each work area and job classification, rate the findings, and hand back a written hazard assessment with the §3380 certification, photographs, and PPE selections you can put in front of a Cal/OSHA inspector.
Trusted throughout California
BSY started working with CDMS last year after our in-house EHS person departed the company. CDMS reviewed our existing operational permits as well as any additional Federal, State and Local regulations that could apply and helped us to create a comprehensive compliance calendar to track regulatory deadlines and submittal due dates. The CDMS team does an excellent job of tracking everything and can be relied upon to complete the forms accurately and assist with submittals, allowing me to focus on our business.
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