What a §3380 Hazard Assessment Actually Requires

Cal/OSHA’s PPE rule under Title 8 §3380 puts the obligation on the employer to determine whether hazards are present that require PPE, select the right protection for those hazards, communicate the selection decision in writing, train each employee on what they’re required to wear, and verify the assessment was performed.

A few notes on how this lands in practice:

• “We already know our hazards” is not the same as a documented assessment. Cal/OSHA wants the certification on paper, signed and dated, mapping job categories to specific protective equipment.
• The assessment is not a one-time deliverable. When you add a process, change a chemical, or move a line, the assessment has to be revisited.
• PPE selection has to match recognized consensus standards. The common ones in our reports: ANSI Z87.1 for eye and face protection, ANSI Z89.1 for head protection, ASTM F2413 for protective footwear, ANSI Z49.1 for welding, ANSI/ISEA 105 for hand protection, and ANSI/ISEA Z358.1 for emergency eyewash and shower equipment.

For a complete overview of how this fits into your facility’s broader safety program, see our California Injury & Illness Prevention Program (IIPP) guide. The §3380 hazard assessment is the input that drives the PPE section of the IIPP.

When Facilities Call Us About PPE & Hazard Assessment

The trigger is rarely “we’d like to schedule a hazard assessment.” It usually shows up like this:

• A general contractor audited the subcontractor’s safety program and flagged a missing or outdated PPE certification.
• An inspector cited the facility for employees not wearing eye protection in a posted PPE area, and the corrective action requires a documented assessment.
• The facility is building its IIPP from scratch (new lease, new ownership, new entity) and needs the hazard assessment that feeds it.
• An incident or near-miss exposed a gap between what the PPE program says on paper and what employees are actually doing.
• Operations changed: a new process, a new chemical, new equipment, a new shift, a paint booth, a welding station.

When we walk a metalworking or food-processing facility, the most common deficiency we find is not a missing PPE program. It’s a PPE program that exists but doesn’t match the work. Safety glasses are required in signage, but employees aren’t wearing them, and nobody can produce a training record for the people who skipped it. That gap, between the written program and what’s happening on the floor, is exactly what an inspector finds.

Two Levels of Hazard Assessment

Not every facility needs the same depth. Most engagements fall into one of two scopes:

The high-level version is what most facilities need when the primary goal is the IIPP. The detailed version is what you need when PPE is the focus, when a job hazard analysis (JHA) is on the table, or when you’ve been told to produce a written PPE certification. We help clients sort out the JHA vs PPE assessment question during scoping.

Came here from a gap assessment? Your gap assessment found IIPP issues: now what? →

How We Run the Assessment On Site

Two CDMS consultants walk your facility together. Before we arrive, we review your existing IIPP, any prior PPE certification, and your site layout, so the walkthrough is focused on what’s actually running, not on getting oriented.

The walkthrough is structured. We examine work operations and interview employees at all levels (floor, supervisor, manager) because what’s written and what’s happening are not always the same. For each work area and job classification, we evaluate the hazard categories that apply: impact, penetration, compression, chemicals, heat, harmful dust, light radiation (welding, lasers), noise, and respiratory hazards. We look at the sources of those hazards too: moving parts, hot work, spills and leaks, stacking, electrical, heights, sharp objects, compressed gas, and pinch points.

Every item gets photographed. Photos go into the final report so your team can see exactly what we observed, not just read about it. For each finding we either mark it as meeting requirements, not applicable, or rate it on a five-point likelihood and a five-point severity scale. That risk rating is what drives the PPE recommendation and the priority order of the findings.

What’s in the Final Report

The deliverable is a written report organized by job classification and work area. Each section covers:

• The hazard observed and where, with photographs
• The risk rating (likelihood and severity)
• The PPE selection, or other engineering or administrative control, we recommend
• The consensus standard the recommended PPE meets (ANSI Z87.1 for eye protection, ASTM F2413 for footwear, ANSI Z49.1 for welding, and so on)
• The §3380 certification language, signed and dated

You can use the report two ways: as the standalone hazard assessment and PPE certification your facility is required to keep on site, and as the input that feeds the PPE section of your facility’s IIPP. For a deeper look at the regulatory mechanics behind the assessment itself, see how to run a workplace hazard assessment under Cal/OSHA §3380.

What Hiring CDMS Looks Like

We provide a fixed-price quote based on the number of processes, job classifications, and operational areas at your facility. During scoping, we’ll ask about the trigger (audit finding, IIPP build, new operation, inspector contact), what the deliverable needs to satisfy, and whether you want the assessment as a standalone report or bundled with PPE program development, IIPP work, training, or ongoing compliance support.

If you only need the assessment and report, that’s the scope. We don’t require an ongoing engagement to produce a standalone deliverable. We’ve talked to plenty of facilities that ran into the opposite with other providers and came to us specifically because they wanted the report and a clear stopping point.