OSHA Hand Protection Requirements: What 1910.138 Actually Requires From Employers
Posted by G & F Products R&D Team on Aug 27th 2026
Every few weeks someone calls us and asks for "OSHA-approved work gloves." We've been making hand protection at G & F Products since the 1980s, and we have to give the same answer every time: there is no such thing. OSHA does not approve, certify, or list gloves. What OSHA does is put obligations on you, the employer — assess the hazard, pick a glove that matches it, make it fit, pay for it, and train people to use it.
That distinction matters, because most citations we hear about aren't "you bought the wrong glove." They're "you never documented why you bought that glove." Here's what the OSHA hand protection requirements actually say, and what a compliant glove program looks like in practice.
What OSHA 1910.138 actually requires
The hand protection standard is remarkably short — two paragraphs. Under 29 CFR 1910.138(a), employers must select and require employees to use appropriate hand protection when hands are exposed to hazards including skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, and harmful temperature extremes.
Paragraph (b) covers selection: the choice must be based on an evaluation of the glove's performance characteristics relative to the tasks performed, the conditions present, the duration of use, and the hazards identified.
Read that again — "duration of use" is written into the rule. A glove that protects perfectly for ten minutes and gets pulled off at minute eleven is not an appropriate selection under 1910.138(b). We say this constantly and it is genuinely the regulation, not sales talk.
The hazard assessment is the requirement people miss
1910.138 is short because the heavy lifting sits in the general PPE standard, 1910.132. Paragraph (d)(1) requires you to assess the workplace to determine whether hazards are present or likely to be present. If they are, you must:
- Select and have each affected employee use PPE that protects against the identified hazards
- Communicate those selection decisions to each affected employee
- Select PPE that properly fits each affected employee
The written certification
1910.132(d)(2) is the one that catches small shops. You must verify the hazard assessment through a written certification that identifies four things: the workplace evaluated, the person certifying that the evaluation was performed, the date or dates of the assessment, and language identifying the document as a certification of hazard assessment.
That's it. It's a one-page document. It does not need to be elaborate — it needs to exist. If a compliance officer asks how you decided your line crew needed A4 gloves instead of cotton jersey, this page is the answer.
Fit is a legal requirement, not a comfort preference
"Properly fits each affected employee" in (d)(1)(iii) is enforceable text. In the field, this usually means women and workers with smaller hands are handed men's large gloves, roll the cuffs, lose dexterity, and take them off. That is a compliance gap and an injury risk in the same moment. If you carry one size, you are almost certainly not meeting (d)(1)(iii). Our glove sizing guide covers how to measure a crew properly, including why "large" is not a standard measurement across brands.
Who pays for work gloves?
This is the single most common question we get from small employers, and the answer is in 1910.132(h)(1): protective equipment used to comply with the standard shall be provided by the employer at no cost to employees. Under (h)(5), the employer also pays for replacement PPE — except where the employee lost or intentionally damaged it.
The weather-gear exception that confuses everyone
Paragraph (h)(4)(iii) excepts ordinary clothing and other items "used solely for protection from weather," and it names gloves in that list alongside winter coats, parkas, and rubber boots.
People read that and conclude gloves are exempt. They aren't. The operative word is solely. If gloves are issued only so an outdoor crew's hands are warm, that's weather gear. The moment those same hands are exposed to a cut, abrasion, puncture, chemical, or thermal hazard under 1910.138(a), the gloves are PPE and the employer pays. A crew handling sheet metal in February needs cut protection and insulation, and that glove is not weather gear.
One more clause worth knowing: under (h)(6) you may not require employees to provide or pay for their own PPE — and under 1910.132(b), if they do use their own gloves, the adequacy, maintenance, and sanitation of that equipment become your responsibility anyway. It is cheaper and cleaner to just buy the gloves.
Training, and when you have to do it again
1910.132(f)(1) requires training for every employee required to use PPE, covering when PPE is necessary, what PPE is necessary, how to properly don, doff, adjust and wear it, the limitations of the equipment, and its proper care, maintenance, useful life, and disposal.
"Limitations" is the part that gets skipped. A worker in A4 gloves who believes they're wearing something cut-proof will handle a blade differently than one who knows the rating covers slicing force, not punctures. Under (f)(2), employees must demonstrate understanding before performing the work — and (f)(3) requires retraining when the workplace changes, when the PPE type changes, or when someone's actual glove use shows the training didn't stick.
Damaged gloves
1910.132(e) is one line: defective or damaged PPE shall not be used. A snagged cut-resistant knit no longer performs at its marked rating, and a pinhole in a chemical glove is a direct skin-absorption exposure under 1910.138(a). Build inspection into the shift start and keep replacement stock on the shelf — a crew that has to request a new pair through a purchase order will keep wearing the torn one.
Matching the hazard to the glove
Once the assessment names the hazard, selection gets straightforward. Broadly, how we map it:
- Severe cuts and lacerations — cut-resistant gloves rated on the ANSI/ISEA 105 scale, with cut-resistant sleeves where forearms are exposed. Our guide to ANSI A1–A9 explains how to pick a level without over-speccing.
- Severe abrasion and general material handling — nitrile-coated knit gloves or leather work gloves where the wear is heavy and sustained.
- Punctures — a coated or leather palm; note that ANSI cut level does not predict puncture performance.
- Harmful temperature extremes — insulated cold weather gloves for cold stress, heat-resistant construction for hot surfaces.
- Mixed jobsite hazards — most construction and general industry work is cut plus abrasion plus grip, which is why coated knits dominate the category.
A compliance file that holds up
If you want a hand protection program that survives an inspection, keep five things together in one folder: the signed written hazard assessment certification, the glove specification you selected for each task with the reason, your training records, your PPE payment policy, and the issue-and-replacement log. Everything else is detail.
None of that requires a consultant. It requires a decision, written down, that connects a real hazard to a real glove.
Need help specifying gloves for a hazard?
We manufacture the gloves, so we can tell you what a rating does and doesn't cover before you commit to a pallet. Browse our full range of protective work gloves, or send us the hazard and the task and our team will spec against it. We would rather help you get one glove right than sell you ten of the wrong thing.
This article is general information about federal OSHA requirements and is not legal advice. State plan states may impose additional requirements, and other OSHA standards — including substance-specific and construction standards — may apply to your operation. Consult the current regulation text or a qualified safety professional for your specific workplace.