Previous columns have covered the need for hazard assessments. But you must not stop there because you can’t eliminate all potential risks, particularly in a work environment, such as pallet and lumber facilities. Once you have done all you can to eliminate or reduce exposures, you must complete a personal protective equipment (PPE) assessment to identify and document the PPE required while performing tasks done by workers.
PPE is a relatively inexpensive part of protecting employees from hazardous exposures in the workplace. A $4 pair of safety glasses can help keep the employer from labor loss, and prevent a life changing, disabling injury to an employee, ultimately resulting in a very costly worker compensation claim.
As per OSHA 29 CFR Standard 1910.132(h)(1), employers are required to provide at no charge to employees the PPE needed to protect them from the hazardous exposures of their job tasks.
Even when the employee provides their own PPE, the employer is still responsible. In other words, if an employee decides that they would like to buy their own customized safety glasses with a camo design, or wear a hard hat with a NASCAR theme, the employer must insure that the equipment meets American National Standards Institute (ANSI) and or National Institute for Occupational Safety and Health (NIOSH) standards. The employer is also responsible for the training, and in assuring the employee properly inspects, cleans and maintains the equipment.
The PPE assessment identifies what job tasks are completed, and the PPE required while performing the task. (See figure 1) Once the form is completed, you can then use it for documented proof, and as a training document.
Completing a PPE assessment is not a huge task, your safety committee can most likely complete it in a meeting or two. This is also a great task for a department manager, since he or she is normally very familiar with the hazards in their areas.
The form can be as simple as a spreadsheet broken into three sections, and one form can be used to identify PPE requirements for a number of tasks. This PPE assessment is broken up into the following three sections:
• Type of Job Task
• Possible Exposure
• PPE Required
On a spreadsheet, each section is further divided so that the same form can be used for more than one task.
Type of Job Task
This section identifies the job task that is being assessed. It is generally a good idea to break it down to the individual or specific task, instead of the department or overall job.
Examples include:
• Cutting
• Feeding
• Finishing
• Grinding
• Mixing
• Pressing
• Sanding
• Sawing
• Welding / cutting / brazing
Hazardous Exposure
This section identifies the specific hazards associated with the task. Most tasks will have more than one hazard.
Examples include:
• Airborne Contaminants
• Airborne Particles
• Belts / Chains
• Blades
• Chemicals
• Electrical
• Excessive Cold
• Excessive Heat
• Gases / Vapors / Dusts
• Gears / Pulleys
• Heavy Lifting
• Heights above 6’
• Noise
• Overhead Hazards
• Pinch Points / Catch Points
• Repetitive Motion
• Shafts
• Terrain
• Traffic
PPE Required
This section identifies the PPE required to perform the tasks or work within the environment where the task is being performed.
Examples include:
• Eye Protection
• Safety glasses
• Goggles for mixing or pouring chemicals
• Apron
• Hearing Protection
• Head Protection
• Gloves
• Dust Mask
• Special Clothing
• Foot Protection
• High Visibility Clothing
• Fall Protection
• Other
Training for PPE is like any safety related training, it must be completed prior to the employee’s initial assignment, annually, when changes are made, when accident trends merit it, or anytime employees may require additional training. The assessment is a great tool for training, identifying the tasks, hazards and PPE required. This should be reviewed with each employee, and can be used as a training document.
Managers need to understand that when PPE is required according to this form, employees performing the listed tasks must be using the PPE identified on the assessment. The PPE assessment must be considered a policy and procedure for your operation. When an OSHA compliance officer inspects your operation, not only will they want to see the PPE assessment, they will want to see employees following the requirements. Some employees may not want to wear PPE. But that doesn’t really matter because their action can still result in a fine. It is up to management to monitor and enforce policies.
Knowingly allowing an employee to not wear the required PPE is a violation that carries a fine that can be quite high when considered a Serious Violation. In the event that the employee’s lack of PPE use results in a serious injury, a mandatory penalty of up to $7,000 for each violation can be imposed. Allowing it to continue, can result in an added $7,000 per day for each violation, and willful violations can reach $70,000 for each violation. No matter what, the employer is the one that receives the fine. After looking at those dollar figures, it isn’t hard at all to justify mandatory use of PPE according to your PPE assessment. Stay safe.
Editor’s Note: Jary Winstead is a safety consultant, author and trainer who serves a variety of industries including the forest products sector. He owns Work Safety Services LLC and can be reached at SAFEJARY@aol.com.
OSHA Regulations Dealing with PPE
OSHA 29 CFR Standard 1910.132 states:
1910.132(a)
Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.
1910.132(b)
Employee-owned equipment. Where employees provide their own protective equipment, the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment.
1910.132(c)
Design. All personal protective equipment shall be of safe design and construction for the work to be performed.
OSHA 29 CFR Standard 1910.132 states:
1910.132(d)
Hazard assessment and equipment selection.
1910.132(d)(1)
The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
1910.132(d)(1)(i)
Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
1910.132(d)(1)(ii)
Communicate selection decisions to each affected employee; and,
1910.132(d)(1)(iii)
Select PPE that properly fits each affected employee.
1910.132(d)(2)
The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
Like I always say, “If you don’t document it, you might as well not even have done it.” Unfortunately, your word that you have done something will have no weight to an Occupational Safety and Health Administration (OSHA) compliance officer, nor will it carry any validation when faced with a lawsuit. You can never document too much. I have heard more than one compliance officer state, “I can tell by your documentation that I may be just spinning my wheels here.” Or, “I am so impressed with the documentation that I plan on only giving you a warning, instead of a fine for a violation.”
OSHA 29 CFR 1910.132 requires employers to provide PPE training for employees, the standard states:
1910.132(f)(1)
The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:
1910.132(f)(1)(i)
When PPE is necessary;
1910.132(f)(1)(ii)
What PPE is necessary;
1910.132(f)(1)(iii)
How to properly don, doff, adjust, and wear PPE;
1910.132(f)(1)(iv)
The limitations of the PPE; and,
1910.132(f)(1)(v)
The proper care, maintenance, useful life and disposal of the PPE.
1910.132(f)(2)
Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.
