Who Is Responsible for Training Workers on the Use of PPE? (Most Small Companies Get This Wrong)

The Box Arrived. That Was It.

In early 2023, our company hit 45 employees. We'd grown past the point where "just grab something from the supply closet" worked for safety gear. We had people operating forklifts, handling chemicals, working at heights. I figured it was time to get serious about PPE.

I did what any office admin does—I started comparing suppliers. Portwest caught my eye because they had everything in one place: coveralls, boots, gloves, hard hats, safety glasses. I ordered 30 pairs of their Euro Work Coveralls in polycotton. Added a few Kask hard hats, too. The price was reasonable. The catalog was impressive.

Two weeks later, a box showed up. Inside: 30 coveralls, each with a care label. No training packet. No video link. No "here's how to use this properly" guide.

I called the supplier. "Do you guys offer any training resources?"

"There are care instructions on the website."

I remember thinking that was... fine. Not great, but fine. The gear was certified. What else did we need?

Turns out, a lot.

The Real Answer Nobody Told Me

Six months later, our insurance broker asked a simple question during a routine audit:

"Where's your PPE training documentation?"

I blinked at her. "The manufacturer sells the equipment. Isn't that their job?"

She pulled up the regulation on her laptop and turned the screen toward me. OSHA 29 CFR 1910.132(f). The wording is dry, but the message is clear: The employer shall provide training to each employee who is required to use PPE.

Not the manufacturer. Not the distributor. Not Portwest, not Kask, not any brand whose logo is printed on the box. The employer.

Here's what most people don't realize: suppliers are responsible for selling you compliant products. That means products that meet ANSI/ISEA standards, products that have proper certification marks, products that won't fall apart under the conditions they're rated for. But the moment that product crosses into your facility, the responsibility for how it's used transfers to you.

Kask manufacturers some of the best hard hats on the market. Their products meet ANSI Z89.1. But if an employee wears that hard hat backwards because nobody showed them the correct orientation, that's on the employer.

Portwest makes coveralls that are certified for specific hazards. But if a worker doesn't know how to don and doff them properly in a chemical environment, the certification becomes meaningless.

The gear is necessary. But the gear alone is not sufficient.

Why Small Companies Get Hit Hardest

Large manufacturers have safety managers. They have dedicated EHS personnel. They have entire departments that live and breathe compliance.

At a 45-person company, I'm the safety manager. I'm also the office manager, the purchasing coordinator, and the person who orders birthday cakes.

I went back and forth for weeks between two approaches: build a proper training program myself, or hire a consultant. The consultant quoted $3,200 for a half-day session. My DIY approach meant reading the regulations, creating materials, and somehow getting buy-in from employees who'd been "doing this for twenty years."

I chose DIY. Not because I was confident, but because $3,200 wasn't in my budget.

Looking back, I should have pushed harder for the consultant. At the time, though, I didn't understand what was actually at stake.

Here's the hidden cost of being small: nobody educates you on the regulations. Large companies have outside consultants sending quarterly reminders. We just have shipping boxes with care labels and hope.

And here's something vendors won't tell you: most suppliers won't offer training support unless you ask. They assume you know the rules. If you're new to PPE procurement, that assumption is dangerous.

What It Actually Costs When You Skip Training

Our insurance broker ran the numbers for me.

If a workers' comp claim involves an injury that proper PPE could have prevented, and you don't have documented training, the insurance company can deny coverage for employer negligence. Average claims start around $40,000. Serious injuries easily reach six figures.

But the financial cost is only part of the picture.

We had a warehouse worker who removed the inner lining from his Portwest coverall during a July heatwave. He thought he was being smart—staying cool. What he didn't know was that the lining provided part of the thermal protection rating. It wasn't a "comfort layer." It was a functional component.

No injury that time. But we got lucky.

Another incident: a new hire adjusted his Kask hard hat so loose that it fell off when he bent over. He'd worn hard hats before—at a previous job where nobody trained him either. He assumed it was "just about having something on your head."

The product was fine. Our training was the problem.

The Simple Fix (That I Wish I'd Known Earlier)

Here's what I do now. It's not fancy, but it works:

1. Map PPE requirements to job roles. Not every employee needs every item. Check OSHA 1910.132 (general requirements) plus any industry-specific standards. Document which roles need what.
2. Request training materials from suppliers. Portwest has care guides and usage documentation on their website—just not front and center. Kask has fitting instructions for their hard hats. Say the words: "Do you have training resources I can share with my team?" Good suppliers will point you in the right direction.
3. Document everything. Who was trained. When. On what equipment. A signed sheet is enough. Fancy LMS platforms are nice but not required.
4. Repeat annually. OSHA doesn't require yearly retraining for all PPE, but it's good practice. New hires, new equipment, new hazards—all trigger the need.
5. Think about PPE from the start. When you order disposable coveralls or FR garments, ask for the usage documentation. When you buy safety boots, find out if there are specific fitting guidelines. Treat training materials as part of the product.

Small doesn't mean unimportant. It means potential. The vendors who treated my small orders seriously—who answered questions without making me feel stupid—those are the ones I still call. The ones who threw a catalog at me and disappeared? I found alternatives.

Bottom Line

OSHA is clear: training is the employer's responsibility. Suppliers sell compliant products. They don't train your workers.

If you're running a small operation and nobody told you this, you're not alone. But now you know. And the fix is simpler than you'd think—ask questions, request materials, and document what you do.

The alternative is paying for it later. Not just in fines, but in the kind of injury that makes you question every shortcut you ever took.

"According to OSHA 29 CFR 1910.132(f)(1): 'The employer shall provide training to each employee who is required by this section to use PPE.'"