OSHA 29 CFR 1910.138 - Hand Protection: A Comprehensive Guide for WHS, OHS, and Compliance Managers

Hand and finger injuries remain among the most frequent, costly, and preventable categories of workplace injury in the United States. For Workplace Health and Safety (WHS), Occupational Health and Safety (OHS), and Compliance Managers operating under federal OSHA jurisdiction (or State Plans that are at least as effective), 29 CFR 1910.138 is the specific regulatory foundation that governs when and how hand protection must be provided and used in general industry.

This standard is deliberately concise, performance-based, and tightly integrated with the broader Personal Protective Equipment (PPE) framework in Subpart I. Understanding its exact requirements, historical context, practical application, and relationship to consensus standards such as ANSI/ISEA 105 is essential for defensible compliance programs, effective injury reduction, and audit readiness.

The Exact Text of 29 CFR 1910.138

The standard contains only two paragraphs:

(a) General requirements. Employers shall select and require employees to use appropriate hand protection when employees’ hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.

(b) Selection. Employers shall base the selection of the appropriate hand protection on an evaluation of the performance characteristics of the hand protection relative to the task(s) to be performed, conditions present, duration of use, and the hazards and potential hazards identified.

Published at 59 FR 16362 (April 6, 1994) and corrected at 59 FR 33911 (July 1, 1994), this language has remained substantively unchanged.

Scope and Application

1910.138 applies to general industry workplaces covered by Part 1910. It covers gloves, mittens, and other forms of hand protection intended to protect against the listed hazards. It does not set design or testing specifications itself; instead, it requires employers to select protection whose performance characteristics match the identified hazards and work conditions.

Key points of coverage include:

• Mechanical hazards (severe cuts, lacerations, abrasions, punctures)
• Chemical hazards (skin absorption of harmful substances, chemical burns)
• Thermal hazards (thermal burns and harmful temperature extremes — both hot and cold)
• The list of hazards is illustrative, not exhaustive. Employers must address any recognized hand hazard that can cause injury or impairment.

Relationship to 29 CFR 1910.132 — The Overarching PPE Framework

1910.138 does not stand alone. Paragraphs (d) (hazard assessment and equipment selection) and (f) (training) of 1910.132 explicitly apply to hand protection under 1910.138.

This means employers must:

• Conduct a workplace hazard assessment to determine if hand hazards are present or likely to be present.
• Select PPE that will protect affected employees from those hazards.
• Ensure the selected PPE properly fits each employee.
• Provide training covering when PPE is necessary, what PPE is required, how to don/doff/adjust/wear it, its limitations, and proper care, maintenance, useful life, and disposal.
• Verify that employees understand the training and can use the PPE correctly before allowing them to perform work requiring it.
• Provide the PPE at no cost to employees (with limited exceptions under 1910.132(h)).

The written certification of the hazard assessment required by 1910.132(d)(2) is a frequent inspection focus. Failure to document the assessment that justifies glove selection is a common citation pathway even when gloves are provided.

Historical Context: Why 1910.138 Was Introduced

The Occupational Safety and Health Act of 1970 established OSHA and created a broad general duty on employers to furnish a workplace free from recognized hazards. Early PPE standards existed, but Subpart I was significantly revised in the early 1990s to strengthen requirements for hazard assessment, selection based on performance, training, and employer payment.

The April 6, 1994 final rule on Personal Protective Equipment for General Industry added the dedicated hand-protection section (1910.138) as part of that modernization. Prior language was less specific about performance-based selection for hands. The 1994 rule clarified that employers could no longer simply issue generic gloves; selection had to be driven by an evaluation of the protection’s actual performance relative to the specific tasks, conditions, duration, and hazards present.

This shift reflected growing recognition that hand injuries were both highly prevalent and highly preventable through proper matching of glove performance to hazard. It also aligned federal requirements more closely with the evolving body of voluntary consensus standards that quantify glove performance (cut resistance, chemical permeation, thermal protection, etc.).

Why 1910.138 Matters: Injury Data, Costs, and Legal Exposure

Hand and finger injuries consistently rank among the leading causes of nonfatal workplace injuries involving days away from work or restricted duty. Bureau of Labor Statistics data and emergency-department studies show hundreds of thousands of such cases annually, with fingers accounting for a large share. Construction, manufacturing, healthcare, food service, and agriculture frequently appear among higher-rate sectors. Severe outcomes include lacerations, punctures, chemical burns, thermal injuries, and amputations.

Beyond human cost, these injuries drive direct medical expenses, workers’ compensation claims, lost productivity, and potential OSHA citations. Because 1910.138 is a specific standard (rather than solely the General Duty Clause), compliance officers can cite it directly when they observe unprotected hands in a documented hazard zone, mismatched gloves, or absence of a supporting hazard assessment and training records.

Common enforcement findings include:

• Employees working in hazard areas without required hand protection
• Gloves provided but not matched to the hazard (e.g., general-purpose cotton gloves for chemical or high-cut exposures)
• Lack of written hazard-assessment certification
• Inadequate or undocumented training
• Failure to enforce use or replace damaged/compromised gloves

Performance-Based Selection: The Critical Obligation Under (b)

The heart of 1910.138(b) is the requirement to evaluate performance characteristics. Employers must look beyond brand or price and consider how the glove actually performs against the identified hazards under real task conditions, duration of use, and environmental factors (wet, oily, abrasive, chemical, temperature extremes, etc.).

This is where consensus standards become indispensable practical tools. ANSI/ISEA 105 (the current 2024 edition) provides classified performance levels for cut resistance (A1–A9), abrasion, puncture, and other properties. Chemical-resistance guides, thermal performance data (including conductive heat), and manufacturer technical data sheets supply the objective information needed to demonstrate that selection was performance-based rather than arbitrary.

A robust selection process typically includes:

• Task and hazard identification (building on the 1910.132 assessment)
• Review of performance data relative to those hazards
• Consideration of dexterity, grip, comfort, and secondary risks (e.g., entanglement)
• Fit testing and user feedbac
• Documentation of the rationale
• Ongoing evaluation as tasks, materials, or processes change

Practical Compliance Framework for Managers

Effective programs treat 1910.138 as more than a glove-issuance rule. Recommended elements include:

• Documented hazard assessments that specifically address hand hazards by task or work area, with written certification.
• Glove selection matrices that map tasks/hazards to required performance levels (e.g., ANSI cut level, chemical breakthrough time, thermal rating) and list approved models.
• Written PPE policies that require use in designated areas/tasks, address inspection and replacement, and assign enforcement responsibility to supervisors.
• Training that covers the five elements in 1910.132(f), includes hands-on practice, and is documented with employee demonstration of understanding.
• Procurement controls that prevent unauthorized substitution of lower-performing gloves.
• Inspection and maintenance procedures so damaged, contaminated, or worn-out protection is removed from service.
• Periodic program review triggered by incident data, process changes, new chemicals or materials, or updated consensus standards.
• Integration with hierarchy of controls — PPE is the last line of defense. Engineering and administrative controls should be evaluated first; gloves protect residual risk.

State-Plan states may have identical or more stringent requirements; managers must verify local applicability.

Common Pitfalls and How to Avoid Them

• Issuing “one glove fits all” without performance evaluation.
• Relying solely on catalog descriptions rather than test data.
• Providing gloves but failing to enforce or monitor use.
• Neglecting documentation of the hazard assessment and selection rationale.
• Overlooking duration of use, environmental conditions, or secondary hazards (e.g., loss of tactile feedback leading to other injuries).
• Treating training as a one-time checkbox rather than competency-based.

From Regulatory Minimum to Effective Protection

29 CFR 1910.138 is brief by design. Its power lies in requiring employers to select and require appropriate hand protection based on a genuine evaluation of performance characteristics against real workplace hazards. When combined with the hazard-assessment, training, and payment requirements of 1910.132, it creates a clear, enforceable framework.

For WHS, OHS, and Compliance Managers, mastery of this standard means fewer injuries, stronger documentation, reduced citation risk, and a more credible safety culture. The most effective programs go beyond the regulatory floor: they use current consensus standards (such as ANSI/ISEA 105), maintain living selection matrices, train for competence, enforce consistently, and continuously improve based on injury data and process changes.

Hand protection is not merely a compliance item — it is one of the highest-leverage interventions available for reducing a persistent and costly category of workplace injury. Understanding and rigorously applying 1910.138 is fundamental to that outcome.