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Tips to Comply with OSHA’S Safety Gear Payment Rule
Worker Safety: Personal protective equipment required under OSHA standards usually must be provided free for employees; a critical first step in compliance is to conduct a hazard assessment.
By Elizabeth Grey Morrison
Date Posted: 10/1/2008
Rules concerning employer-paid personal protective equipment (PPE) are hardly new. Published in the Federal Register in November 2007, the Occupational Safety and Health Administration (OSHA) issued a final rule mandating that all PPE required under OSHA standards, with a few exceptions, must be provided at no cost to employees. The new rule which became effective in May 2008 did not add any new PPE requirement other than requiring the employer to pay for it.
Failure to comply with PPE requirements could result in major fines. OSHA recently clarified its PPE rule by stating that employers are required to provide PPE, such as respirators, or training to all employees based on the dangers in their job. Each employee not protected may be considered a separate violation for penalty purposes.
A critical first step to compliance is a process known as “hazard assessment” in which employers identify physical and health hazards in the workplace. Potential hazards can both be physical and health-related, and a thorough hazard assessment should identify hazards in both categories. `
According to OSHA documents regarding PPE, the hazard assessment should begin with a walk-through survey of the facility to develop a list of possible hazards in basic categories including impact, penetration, compression (roll-over), chemical, heat/cold, harmful dust, light radiation and biologic. OSHA recommends noting other additional items during the survey including:
• Sources of electricity.
• Sources of motion such as machines or processes where movement may exist that could result in an impact between personnel and equipment.
• Sources of high temperatures that could result in burns, eye injuries, or fire.
• Types of chemicals used in the workplace.
• Sources of harmful dusts.
• Sources of light radiation, such as welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.
• The potential for falling or dropping objects.
• Sharp objects that could poke, cut, stab, or puncture.
• Biologic hazards such as blood or other potentially infected material.
When the survey is complete, the employer should organize and analyze the data so that findings may be efficiently used to determine the proper types of PPE required at the worksite. Written documentation of the hazard assessment is required, and must include the following information:
• Identification of the workplace evaluated;
• Name of the person conducting the assessment;
• Date of the assessment; and
• Identification of the document certifying completion of the hazard assessment.
In addition to conducting a hazard assessment, employers are also required to train each employee in the proper use of PPE. At minimum, employers should be trained to know when PPE is necessary; what PPE is necessary; how to properly put on, take off, adjust and wear the PPE; and proper care, maintenance, useful life and disposal of PPE.
So what kinds of PPE are appropriate for your business? The forest products industry is diverse, so there is not a one-size-fits-all PPE plan. However, there are general guidelines outlined by OSHA to take into consideration when assessing individual PPE needs. For the purposes of this article, four types of protection will be addressed: eye protection, head protection, hearing protection, and body protection.
Among others, OSHA suggests that carpenters, mechanics, assemblers, sanders, grinding machine operators, sawyers, timber cutting and logging workers use routine eye protection while working. When selecting the most suitable eye and face protection for employees, consider the following elements:
• Ability to protect against specific workplace hazards.
• Should fit properly and be reasonably comfortable to wear.
• Should provide unrestricted vision and movement.
• Should be durable and cleanable.
• Should allow unrestricted functioning of any other required PPE.
It is permissible for employers to provide one pair of protective eyewear for each position rather than individual eyewear for every employee. However, if this the case, the employer must make sure that employees disinfect shared protective eyewear after each use. Of course, protective eyewear with corrective lenses may only be used by the employee for whom the corrective lenses was intended and may not be shared by other employees.
Another type of PPE appropriate for many in the forest products industry is head protection. Employers are required to ensure that their employees wear protected headgear if any of the following apply:
• They might bump their heads against fixed objects, such as exposed pipes or beams;
• Objects might fall from above and strike them on the head;
• There is a possibility of accidental head contact with electrical hazards.
Some head protection allows for the use of various accessories to help employees deal with changing weather conditions, such as slots for earmuffs, safety glasses, face shields and mounted lights. Optional brims may provide additional shade from the sun or keep rainwater away from the face. Keep in mind, however, that headgear accessories must not compromise the safety elements of the equipment.
Periodic cleaning and inspection can prolong the useful life of protective headgear. A daily inspection of the hard hat shell, suspension system and other items for holes, cracks, tears, or other damage is essential as paints, paint thinners, and some cleaning agents can weaken the shells and even eliminate electrical resistance. Employees should not drill holes, paint, or apply labels to hard hats as this may reduce the effectiveness of the protection. Employees should also refrain from storing protective headgear in direct sunlight as sunlight and extreme heat can damage them. OSHA recommends replacing hard hats for any of the following defects:
• Perforation, cracking, or deformity of the brim or shell;
• Indication of exposure of the brim or shell to heat, chemicals or ultraviolet light and other radiation (in addition to a loss of surface gloss, such signs include chalking or flaking).
A hard hat should always be replaced if it sustains an impact, even if there is no notable damage. Suspension systems are available as replacement parts and should be substituted when damaged or excessive wear is noticed.
A third type of PPE is hearing protection. Employee exposure to excessive noise depends on several factors, including:
• The loudness if the noise as measured in decibels (dB).
• The duration of each employer’s exposure to the noise.
• Whether the employees move between work areas with different noise levels.
• Whether noise is generated from one or multiple sources.
As a general rule, the louder the noise, the shorter the exposure time before hearing protection should be used. For a more detailed discussion of the requirements for a thorough hearing conservation program, see OSHA Publication 3074 (2002), “Hearing Conservation” or refer to the OSHA standard at 29 CFR 1910.95, Occupational Noise Exposure, section (c).
Finally, body protection is another type of PPE that should be used in many workplaces. Employees who face potential bodily injury of any kind that cannot be eliminated through engineering, work practice or administrative controls are required to wear appropriate body protection while working. Employers are only required to ensure that their employees wear PPE only for the parts of the body exposed to potential injury.
There are varieties of protective clothing offered for particular hazards including laboratory coats, coveralls, vests, jackets, aprons, surgical gowns and full body suits. Protective clothing comes in a variety of materials, each effective against specific hazards, such as:
· Paper-like fiber used for disposable suits provide protection against dust and splashes.
· Treated wool and cotton adapts well to changing temperatures, is comfortable and fire-resistant, and protects against dust, abrasions, and rough and irritating surfaces.
· Duck is a closely woven cotton fabric that protects against cuts and bruises when handling heavy, sharp, or rough materials.
· Leather is often used to protect against dry heat and flames.
· Rubber, rubberized fabrics, neoprene and plastics protect against certain chemicals and physical hazards. When chemical or physical hazards are present, check with the clothing manufacturer to ensure that the material selected will provide protection against the specific hazard.
If these suggestions warrant further questions or concerns, OSHA consultation assistance is available upon request to employers who want help in establishing a safe and healthful workplace. Primarily developed for smaller employers in more hazardous industries, the consultation service is delivered by state governments that employ professional safety and health consultants. For more information concerning consultation service, see the OSHA Web site at www.osha.gov.
Information for this article was taken from the OSHA Web site and can be found at http://www.osha.gov/Publications/osha3151.pdf.