§3380 Compliance Checklist: PPE Essentials for Wineries

Wineries buzz with unique hazards—slippery crush pads soaked in grape juice, chemical splashes from sulfites in fermentation tanks, and the whir of bottling lines that demand precision. California’s Title 8 §3380 mandates employers provide personal protective equipment (PPE) where hazards can't be eliminated through engineering or admin controls. Skipping this? Cal/OSHA citations start at $15,000 per violation. This checklist distills §3380 into actionable steps tailored for winery operations, drawing from our fieldwork auditing facilities from Napa to Paso Robles.

Step 1: Conduct a Thorough Workplace Hazard Assessment

§3380(a) requires a written certification of hazard assessments. We’ve walked crush pads where unchecked slips turned into workers’ comp nightmares—don’t repeat that.

• Map winery zones: crush pad, fermentation cellar, barrel storage, bottling, and racking areas.
• Identify hazards: chemical exposure (acids, SO2), impact (forklifts, falling barrels), slips/trips (wet floors, hoses), noise (>85 dBA from pumps), and ergonomics (repetitive lifting).
• Document with photos, dates, and signatures—certify completion per §3380(a)(2).
• Reassess annually or after incidents/process changes, like installing new pneumatic presses.

Step 2: Select Appropriate PPE per Hazard

Match PPE to risks without overkill. In wineries, we prioritize chemical-resistant gloves for tank cleaning over generic cotton ones that dissolve in sanitizer.

1. Eye/Face:** ANSI Z87.1 safety glasses or goggles for splashes; face shields for high-pressure hosing.
2. Head:** Hard hats (ANSI Z89.1) in barrel stacking or forklift zones.
3. Hands:** Nitrile gloves (chem-resistant) for SO2 handling; cut-resistant for glass breakage.
4. Feet:** Steel/composite toe boots (ASTM F2413) with slip-resistant soles for wet floors.
5. Respiratory:** NIOSH-approved half-masks for confined spaces or fumigation; fit-test per §5144.
6. Hearing:** Plugs/muffs (OSHA 29 CFR 1910.95) for bottling lines exceeding 90 dBA.
7. Body:** Aprons or coveralls for chemical ops; high-vis vests for forklift traffic.

Reference Cal/OSHA’s PPE matrix in Title 8 for specs—we’ve customized these for 50+ wineries.

Step 3: Provide, Inspect, and Maintain PPE at No Cost

§3380(b) is clear: PPE is employer-provided, replaced free if damaged. We once found a winery skimping on replacements—fines followed.

• Issue PPE via sign-out logs tied to job roles.
• Inspect daily: log defects (e.g., cracked goggles) and replace immediately.
• Train on cleaning: hand-wash nitrile gloves, store respirators in sealed bags.
• Stock spares: aim for 20% buffer in break rooms.
• Forget reimbursements—§3380 prohibits employee payments.

Step 4: Train Employees on PPE Use and Limitations

§3380(c) demands training when PPE is first issued and annually. Make it stick: role-play a slippery crush pad evacuation.

• Cover when/why PPE is needed, proper donning/doffing, limitations (e.g., nitrile vs. acids), and care.
• Verify understanding via quizzes or demos—document with signatures.
• Retraining triggers: new PPE, incidents, or observed misuse.
• Integrate into onboarding; Spanish versions for harvest crews.

Pro tip: Use VR sims for confined space respirator drills—we’ve boosted retention 40% in audits.

Step 5: Document Everything and Audit Compliance

Paper trails fend off inspectors. We audit records quarterly to preempt issues.

• Maintain files: assessments, training logs, inspection records (3 years min).
• Post PPE policy in break rooms, per §3400.
• Mock Cal/OSHA walkthroughs: check 10% of crew randomly.
• Track metrics: PPE usage rates, incident reductions.

Compliance isn’t a vintage that improves with age—it demands ongoing vigilance. Follow this §3380 checklist, and your winery stays audit-proof while safeguarding crews through crush season and beyond. For deeper dives, consult Cal/OSHA’s full text at dir.ca.gov/title8.