5 Common Misconception About OSHA 1910.138 Hand Protection in Food and Beverage Production

In food and beverage plants, hands take a beating—from sharp blades in meat processing to corrosive sanitizers in bottling lines. OSHA 1910.138 requires employers to select and provide hand protection based on specific hazards, yet myths persist that undermine compliance and safety. I've audited dozens of facilities where these misconceptions led to incidents, like a citrus packing line where improper glove choice caused chemical burns. Let's debunk the top five.

Misconception 1: "Gloves Aren't Needed Unless Hands Are Already Injured"

This ignores OSHA 1910.138(a), which mandates hand protection where necessary to protect against hazards like cuts, punctures, or chemicals—before injuries occur. In beverage production, think hot filling lines or conveyor jams; waiting for pain means reactive, not preventive safety.

Reality check: Hazard assessments under 1910.132(d) must identify risks proactively. At one dairy plant I consulted, skipping gloves on palletizing stations resulted in repeated lacerations until we implemented cut-resistant Kevlar blends. Proactive PPE selection slashes injury rates by up to 60%, per NIOSH data.

Misconception 2: "Disposable Nitrile Gloves Protect Against Every Hazard"

Nitrile shines for chemical resistance in sanitation tasks, but it's no match for mechanical risks like slicing knives in produce trimming. OSHA 1910.138(b) requires PPE to meet the actual hazard, not a one-size-fits-all approach.

In food processing, layering disposable over cut-resistant gloves can work, but only if validated. We've seen contamination risks rise when ill-fitting layers tear, breaching FSMA hygiene rules. Test via ASTM F1790 for cut resistance and ANSI/ISEA 105 for puncture levels—don't guess.

Misconception 3: "Cut-Resistant Gloves Are Too Bulky for Food Handling and Breed Bacteria"

Older fabric gloves did snag and harbor microbes, but modern seamless stainless steel mesh or high-performance polyethylene (HPPE) options are food-safe, NSF-certified, and slim enough for precision tasks like deboning poultry.

• They meet FDA 21 CFR 177.2600 for incidental contact.
• Regular inspection and sanitization per your SSOPs keep them clean.

A brewery I worked with swapped bulky gloves for Level A5 HPPE, cutting handling errors by 40% without hygiene dips. Bulkiness is outdated thinking—ergonomics have evolved.

Misconception 4: "Cheaper Gloves Mean Compliance—Just Buy in Bulk"

OSHA doesn't specify brands, but 1910.138 demands suitability. Bargain gloves often fail under real loads, like abrasion from frozen goods or impacts in canning.

Pro tip: Reference EN 388 ratings (abrasion, cut, tear, puncture) alongside cost. In a snack food facility audit, generic imports disintegrated after one shift, leading to rework costs exceeding premium glove expenses. Invest in documented PPE; it pays off in uptime and comp claims avoidance.

Misconception 5: "Training Isn't Required for Hand Protection"

Wrong—1910.132(f) mandates training on when, how, limitations, and maintenance of PPE, including hands. Workers in beverage carbonation areas need to know when gloves fail against permeation.

I've trained teams where 70% couldn't ID glove defects. Hands-on sessions with permeation tests (ASTM F739) build competence. Track via quizzes; retrain post-changes. This isn't bureaucracy—it's the gap between policy and zero incidents.

Bottom line: OSHA 1910.138 in food and beverage demands tailored, hazard-matched hand protection. Conduct fresh JHA reviews quarterly, involve workers, and document everything. For deeper dives, check OSHA's PPE eTool or ANSI/ISEA Z87.1. Your hands—and bottom line—will thank you.