Gloves, Gowns, and Masks: The OSHA Rules Small Practices Must Follow (29 CFR § 1910.133)

Gloves, gowns, and masks are more than basic supplies; they are essential personal protective equipment (PPE) mandated by OSHA to reduce occupational hazards in healthcare environments. Under 29 CFR §1910.132, small medical practices must ensure the correct selection, use, and availability of protective gear. Proper compliance prevents the transmission of infectious agents, reduces exposure to chemical hazards, and safeguards both staff and patients. For small practices, meeting these requirements demonstrates legal compliance, prevents penalties, and strengthens patient trust.

Every day, healthcare workers encounter risks ranging from bloodborne pathogens to airborne infections. OSHA requires small medical practices to provide and enforce the proper use of gloves, gowns, and masks as part of workplace safety. Section 1910.132 sets the general requirements for protective equipment, mandating employers to assess hazards and provide PPE that matches those risks. For respiratory protection, employers must also comply with §1910.134. Compliance with this rule ensures staff are protected from injuries and illnesses, while clinics avoid costly citations and reputational harm. For resource-limited practices, understanding and implementing this standard is crucial to maintaining safe, efficient operations.

Understanding Gloves, Gowns, and Masks Under 29 CFR § 1910.133

According to 29 CFR §1910.133, employers must provide suitable eye and face protection whenever workers are exposed to hazards such as flying particles, molten metal, liquid chemicals, or potentially infectious materials. While the section emphasizes eye and face protection, gloves, gowns, and masks are integral to the broader PPE requirements defined across OSHA standards. Clinics must:

• Evaluate the workplace to determine necessary PPE.

• Provide PPE at no cost to employees.

• Train staff in proper use and limitations of PPE.

• Replace or repair damaged or contaminated PPE immediately.

Failure to comply may result in OSHA citations, staff injuries, and liability. By aligning with this standard, small practices reduce risks while showing regulators that safety is taken seriously.

The OCR’s Authority in Gloves, Gowns, and Masks Compliance

While OSHA enforces workplace safety, the Office for Civil Rights (OCR) enforces HIPAA, which overlaps in areas where PPE documentation intersects with patient privacy. For example:

• Training records that include exposure incidents may contain PHI.

• OCR can investigate if patient complaints suggest poor infection control linked to inadequate PPE.

• Noncompliance with PPE requirements could be seen as a failure to safeguard both staff and patients, triggering HIPAA-related audits.

For small practices, this means documentation of PPE compliance must not only meet OSHA standards but also protect patient confidentiality.

1. Perform a Hazard Assessment
   Document risks that require gloves, gowns, and masks (blood, droplets, or chemicals).

2. Select Appropriate PPE
   Choose PPE that matches specific hazards. For instance, surgical masks for droplet exposure, N95 respirators for airborne risks.

3. Provide PPE at No Cost
   OSHA mandates that employers cover the cost of required PPE.

4. Train Employees
   Cover donning/doffing, disposal, limitations, and maintenance of gloves, gowns, and masks.

5. Document Training and Usage
   Maintain written certification of training sessions, including dates and staff names.

6. Inspect and Replace PPE
   Ensure worn or contaminated PPE is replaced promptly.

7. Maintain Records for OSHA
   Store hazard assessments, training records, and PPE logs for inspection readiness.

In a small urgent care clinic, staff began reporting recurring shortages of protective gowns during the height of flu season. Nurses and medical assistants often found themselves reusing gowns between patient encounters or improvising with makeshift coverings when supplies ran low. Concerned about their own safety and the risk of cross-contamination, one employee filed a confidential complaint with OSHA. During the subsequent inspection, OSHA investigators discovered that the clinic had never performed a formal hazard assessment to determine the type and amount of PPE required for seasonal surges. Inspectors also noted that training on PPE use was inconsistent and not documented. These lapses represented violations of OSHA’s PPE standards, particularly under 29 CFR 1910.133, which requires employers to assess hazards and provide appropriate protective equipment. The practice was issued citations totaling $9,000 and was ordered to correct deficiencies by implementing annual hazard assessments, maintaining documented PPE training, and ensuring adequate stock of protective gear at all times. Beyond the financial penalty, the citation caused reputational harm as staff questioned management’s ability to prioritize safety during critical periods of high patient volume.

By contrast, another small clinic in the same region demonstrated the benefits of proactive compliance. Management had developed written PPE policies that outlined responsibilities for monitoring supply levels and triggering reorders before shortages occurred. They also conducted annual hazard assessments to evaluate emerging risks, such as flu outbreaks or potential bloodborne pathogen exposures. Staff received documented PPE training sessions, complete with attendance sheets, hands-on demonstrations, and refresher courses before flu season began. The clinic stored protective gowns and other PPE in clearly labeled cabinets accessible on every shift, reducing delays in patient care. When OSHA inspectors later conducted an unannounced inspection, the clinic was able to provide hazard assessment records, training logs, and inventory checklists. No citations were issued. In fact, inspectors noted the clinic as an example of best practice in small healthcare settings. Employees reported high confidence in their safety, and patients expressed trust in the clinic’s infection control measures. This proactive approach not only avoided penalties but also reinforced the clinic’s reputation as a reliable and safe care provider.

Common Pitfalls to Avoid Under 29 CFR § 1910.133

• Failing to provide PPE at no cost: OSHA requires employers to supply PPE, not employees.

• Inadequate hazard assessments: Without documentation, clinics cannot justify PPE selection.

• Lack of staff training: PPE is ineffective if staff do not know how to use it properly.

• Improper storage or disposal: Contaminated PPE can spread infections if mishandled.

• Standardize PPE supply ordering to prevent shortages.

• Use signage reminding staff of proper PPE use.

• Store PPE in accessible, designated stations.

• Conduct quarterly refresher training sessions.

• Keep dual copies of PPE records (digital and paper).

These practices help small clinics meet compliance efficiently and with minimal cost.

A compliance culture requires ongoing leadership commitment. Clinic managers should prioritize PPE discussions in staff meetings, conduct surprise audits to reinforce good habits, and encourage staff to report PPE issues without fear of retaliation. By integrating gloves, gowns, and masks into daily routines, practices create an environment where safety is second nature.

Small healthcare practices must view compliance with 29 CFR § 1910.133 not as a burden but as a critical part of safe operations. By conducting hazard assessments, training staff, documenting compliance, and maintaining PPE supplies, practices can prevent fines and protect lives.

Advisers

Affordable compliance software solutions can help small practices track PPE training, schedule hazard assessments, and store digital documentation. Free OSHA guidance, HHS infection control resources, and OCR’s HIPAA compliance tools provide additional support. Leveraging these resources ensures that gloves, gowns, and masks are not only available but properly documented, used, and integrated into a safe workplace.

• eCFR — 29 CFR § 1910.133 Eye and Face Protection

• OSHA — Personal Protective Equipment Standards

• OSHA — Healthcare Wide Hazards

• OIG — Compliance Resources for Healthcare Providers