During workplace safety inspections, I get numerous questions about Personal Protective Equipment (PPE) and what the employer is required to provide. It is a little harder than just saying safety glasses and hearing protection are required in the production area. PPE requirements are one of OSHA’s highly regulated safety compliance areas. OSHA standards are very clear on PPE, and it’s extremely important that management takes PPE seriously. When hazards are present and cannot be eliminated or reduced to a safe exposure, PPE must be in use. PPE has its limitations and is not intended to eliminate the hazard. Important: PPE is always the last line of defense.
The Occupational Safety and Health Administration (OSHA) standard for PPE is as follows:
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.
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.
1910.132(e)
Defective and damaged equipment. Defective or damaged personal protective equipment shall not be used.
1910.132(f)
Training.
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:
Hazard Assessment
You first need to complete a Hazard Assessment of the workplace to identify what hazards are associated with the job tasks performed in your workplace.
OSHA identifies the following steps in order to identify and assess hazards in the workplace:
To identify and assess hazards, employers and workers need to:
• Collect and review information about the hazards present or likely to be present in the workplace.
• Conduct initial and periodic workplace inspections of the workplace to identify new or recurring hazards.
• Investigate injuries, illnesses, incidents and close calls/near misses to determine the underlying hazards, their causes, and safety and health program shortcomings.
• Group similar incidents and identify trends in injuries, illnesses and hazards reported.
• Consider hazards associated with emergency or non-routine situations.
• Determine the severity and likelihood of incidents that could result for each hazard identified and use this information to prioritize corrective actions.
It is highly recommended that the employer involves its employees and safety committee in determining the hazards associated with the tasks performed in the workplace. There are no better people to utilize than those that perform the tasks in order to identify the hazards.
Common Hazards
The following list includes common hazards found in the workplace:
• Airborne Objects
• Blades
• Chemicals
• Electrical
• Flash / Burns
• Gases / Vapors / Dusts
• Gears / Shafts / Chains
• Heavy Lifting
• Heights above 6'
• Noise
• Overhead Hazards
• Pinch / Catch Points
• Repetitive Motion
• Temperature Extremes Heat / Cold
• Traffic / Congested areas
• Vibration
Once the hazards are identified, we can use the Hierarchy of Controls to address each hazard.
Hierarchy of Control
The hierarchy of controls is a structural method for keeping employees safe from occupational hazards. It is widely promoted as the best way to control occupational hazards by various worldwide safety organizations, including the National Institute for Occupational Safety and Health (NIOSH). See the diagram explaining the five components – elimination, substitution, engineering controls, administrative control and personal protective equipment.
1. Elimination
Elimination, or the physical removal of a hazardous exposure from a workplace, is the most effective stage of the hierarchy of controls. When hazards are eliminated or removed from a work environment, they no longer have the potential to negatively impact employees.
Though it’s conceptualized as the most effective stage, elimination is also typically the most challenging to implement, as doing so can be costly and require major overhauls in preexisting workplace processes.
Examples:
• Redesign a process to eliminate the use of hazardous equipment or product.
• Perform tasks at ground level rather than working high above ground.
• Store goods at lower heights so workers don’t have to climb tall heights and risk fall injuries or fatalities.
• Determine whether your workplace needs a chemical or particulate that causes respiratory irritation for the particular process. If the answer is no, remove the product presenting the threat.
• Eliminate chemicals that may cause a dangerous skin reaction.
2. Substitution
Substitution, or replacing a hazardous item or activity with something less hazardous, is the second-most effective stage of safety control. Substitution serves a similar purpose to elimination, as it removes a hazard from the workplace or decreases the potential for the hazard to negatively affect employees. If a workplace process is still in its design or development phase, substitution can be an inexpensive and streamlined method for managing a hazard.
Examples:
• Replace a caustic chemical with a non-toxic alternative.
3. Engineering Controls
Engineering controls, or designing purposeful solutions that physically separate employees from hazards, are the third-most effective stage of safety control. Many organizations favor engineering controls to remove the hazard at the source rather than after an employee comes into contact with a hazard. It’s important to note that while engineering controls can sometimes be costly to implement, they typically result in lower overall operating costs due to the new safety features.
Examples:
• Install dust collection systems for machines.
• Place insulative barriers around loud machinery.
• Move loud equipment such as air compressors outside of the building.
• Fence around dangerous high-voltage equipment.
• Install guardrails at work and egress areas that have a fall hazard.
• Install conveyors and feed systems to prevent repetitive motion.
• Utilize lifting equipment to prevent the need for physical lifting.
• Install padding at workstations where employees stand all day.
4. Administrative Controls
Administrative controls, or changes to the way employees work and perform particular processes, are the fourth-most effective stage of safety control. Administrative controls are typically employed alongside other existing processes in which hazards are not totally controlled.
Organizations sometimes favor administrative controls due to their low-cost nature, but such initiatives are often ineffective and require significant effort on the part of affected employees.
Examples:
• Limit the time a worker is exposed to a hazard.
• Create written formalized operating procedures.
• Train employees in alternative procedures that reduce hazard exposures.
• Install signs, labels, and alarms.
5. Personal Protective
Equipment (PPE)
PPE is considered the last resort in the hierarchy of safety controls. The first four measures should always be a priority in addressing workplace hazards since PPE does not fully reduce or eliminate the hazard.
See the spread sheet example that I use for identifying tasks, hazards, and PPE requirements in the workplace. It’s important to understand that even though a job task may be closely related to another, there can be additional hazards and PPE requirements.
Important Points on PPE:
• PPE must be provided at no cost to the employee.
• It’s always best to require hearing protection so that the maximum exposure is 70 dB, since cumulative exposure can cause permanent hearing damage, and hearing protection must be in use whenever exposure of 85 dB can be expected over an 8-hour period.
• Safety glasses must always be required when airborne particles are present such as dust, chips or shavings.
• Safety goggles are required whenever using hazardous chemicals and while pouring and mixing chemicals.
• Face shields are required whenever airborne particles strike the face or chemicals can splash the face. But remember, face shields do not eliminate the requirement for eye protection.
– Safety glasses for particles and objects
– Goggles for chemicals
• Hardhats are required anytime workers are working above another worker or materials could strike the employee’s head.
• PPE requirements for a specific chemical can be identified in section 8 of the chemical’s Safety Data Sheet.
• Gloves are required when hazards exist to the worker’s hands, such as splinters, cuts, and chemicals. Each hazard may require a different glove material.
• Employees must be trained on the proper selection, use, limitations, maintenance and storage of PPE.
• Dust masks and N95 masks have their limitations and are not intended to be used for multiple shifts.
• Tight fitting Air Purifying Respirators (APR) require medical evaluations, training and fit testing before employees are allowed to wear them. These respirators require specific filter cartridges for the chemical exposure.
As always, I highly recommend that you reach out to your local OSHA office, or safety and health regulatory authority for assistance. It’s always best to ask for assistance in order to reduce workplace hazards, rather than beg for forgiveness, or a lesser fine.
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@gmail.com.
