Category: Safety

OSHA standards require the use of PPE to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing these exposures to acceptable levels. Employers are required to determine if PPE should be used to protect their workers and they must also make sure employees use and maintain PPE in a sanitary and reliable condition.

Employer Responsibilities

In general, employers are responsible for:

• performing a “hazard assessment” of the workplace to identify and control physical and health hazards;
• identifying and providing appropriate PPE for employees;
• training employees in the use and care of the PPE;
• maintaining and replacing worn or damaged PPE; and
• periodically reviewing, updating and evaluating the effectiveness of the PPE program

Employee Responsibilities

In general, employees should be:

• properly wearing PPE,
• attending training sessions on PPE,
• caring for, cleaning, and maintaining PPE, and
• informing a supervisor of the need to repair or replace PPE

Defective or damaged personal protective equipment must not be used. It’s important to inspect PPE regularly, and before each use, to make sure it’s capable of adequately protecting an employee from exposure to hazards. Remember, PPE that is defective is not PPE.

Do employers have to pay for PPE?

With few exceptions, OSHA requires employers to pay for personal protective equipment used to comply with OSHA standards.

Employers cannot require workers to provide their own PPE. Employees who use their own PPE must do so voluntarily. Even if an employee provides his or her own PPE, the employer must still ensure the equipment is adequate to protect the worker from hazards at the workplace.

Employers must pay for the following:

• metatarsal foot protection
• rubber boots with steel toes
• non-prescription eye protection
• prescription eyewear inserts/lenses for full face respirators
• goggles and face shields
• firefighting PPE (helmet, gloves, boots, proximity suits, full gear)
• hard hats
• hearing protection
• welding PPE

Payment Exceptions under the OSHA Rule

Employers are not required to pay for some PPE in certain circumstances:

• Non-specialty safety-toe protective footwear (including steel-toe shoes or boots) and non-specialty prescription safety eyewear provided that the employer permits such items to be worn off the job site. OSHA based this decision on the fact that this type of equipment is very personal, is often used outside the workplace, and that it is taken by workers from jobsite to jobsite and employer to employer.
• Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots.
• Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.
• Lifting belts because their value in protecting the back is questionable.
• When the employee has lost or intentionally damaged the PPE and it must be replaced.

How does an employer select PPE?

To help determine the best PPE for the job, conduct a hazard assessment of each employee’s task, the likelihood that the employee would be injured without PPE, and the severity of a potential injury. For example:

The task: A worker uses a plasma cutter to remove the bottom of a 55-gallon drum that contains traces of motor oil. His only PPE is a pair of synthetic gloves. The outcome: The drum explodes and the worker receives severe burns on his face and hands. An effective PPE hazard assessment would produce the following information:

• Task: Using a plasma cutter.
• Hazards: The plasma-cutting arc produces hot metal and sparks, especially during the initial piercing of the metal. It also heats the work piece and the cutting torch. Never cut closed or pressurized containers such as tanks or drums, which could explode. Do not cut containers that may have held combustibles or toxic or reactive materials unless they have been cleaned, tested, and declared safe by a qualified person.
• Likelihood of injury without PPE: High
• Severity of a potential injury: Life-threatening burns PPE necessary for the task:
  • Body: dry, clean clothing made from tightly woven material such as leather, wool, or heavy denim
  • Eyes and face: safety glasses with side shield or face shield; welding helmet with shaded eye protection for welding tasks
  • Feet: high-top leather shoes or boots
  • Hands: flame-resistant gloves

Check out: PPE Hazard Assessment and Certification

Train Employees on PPE Use

The PPE standard mandates the employer must provide “hands-on-how-to” (practice) training to each employee who is required to use Personal Protective Equipment. To meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:

1. when PPE is necessary;
2. what PPE is necessary;
3. how to properly don, doff, adjust, and wear PPE;
4. the limitations of the PPE; and
5. the proper care, maintenance, useful life, and disposal of the PPE.

So far, we meet minimum OSHA requirements… but one very important element is missing: The PPE standard does not specifically require education on “why” PPE is necessary.

Check Out: The Basics of PPE Training

So, why is this element so important? Because study after study tells us the most common reason employees don’t follow rules in the workplace is because they don’t know why the rules are important.

Types of PPE

Protective eye and face devices must comply with ANZI Z87.1, “American National Standard Practice for Occupational and Educational Eye and Face Protection,” and OSHA Standard 1910.133, Eye and Face Protection.

Eye and Face Protection

Glasses

Protective eyeglasses or spectacles are made with safety frames, tempered glass or plastic lenses, temples and side shields which provide eye protection from moderate impact and particles encountered in job tasks such as carpentry, woodworking, grinding, scaling, etc. Safety glasses are also available in prescription form for those persons who need corrective lenses.

Goggles

• Vinyl-framed goggles of soft pliable body design provide adequate eye protection from many hazards. These goggles are available with clear or tinted lenses, perforated, port vented, or non-vented frames.
• Single-lens goggles provide similar protection to spectacles and may be worn in combination with spectacles or corrective lenses to ensure protection along with proper vision.
• Welders goggles provide protection from sparking, scaling, or splashing metals and harmful light rays. Lenses are impact resistant and are available in graduated shades of filtration.
• Chipper/Grinder goggles provide eye protection from flying particles. The dual protective eye cups house impact resistant clear lenses with individual cover plates.

Face Shields

These normally consist of an adjustable headgear and face shield of tinted/transparent acetate or polycarbonate materials, or wire screen. Face shields are available in various sizes, tensile strength, impact/heat resistance and light ray filtering capacity.

Face shields will be used in operations when the entire face needs protection and should be worn to protect eyes and face against flying particles, metal sparks, and chemical/biological splash.

Welding Shields

These shield assemblies consist of:

• vulcanized fiber or glass fiber body
• a ratchet/button type adjustable headgear or cap attachment
• a filter and cover plate holder

These shields will be provided to protect workers’ eyes and face from infrared and ultraviolet light burns to the retina, flying sparks, metal spatter, and slag chips encountered during:

• welding;
• brazing;
• soldering;
• resistance welding;
• bare or shielded electric arc welding;
• oxyacetylene welding; or
• cutting operations.

Respiratory Protection

Respiratory Protection is important when employees are exposed to potentially hazardous atmospheres. Respirator use must conform to ANSI/ASSE Z88.2, Practices for Respiratory Protection, and OSHA Standard 1910.134, Respiratory Protection.

Respirator Types

To understand how respirators can be used to protect employees, it is important to understand what a respirator is and what it is not. A respirator protects against respiratory hazards by removing specific air contaminants from the ambient (surrounding) air or by supplying breathable air from a safe source.

• Air-purifying respirators: Respirators that remove contaminants from the ambient air are called air-purifying respirators. Particulate respirators are a type of air-purifying respirator. The part of a respirator that forms a protective barrier between the user’s respiratory tract and air contaminants is called an inlet covering. Most inlet coverings are classified as either tight-fitting or loose-fitting.
• Tight-fitting respirator: A tight-fitting respirator has an inlet covering, also called a face piece or mask, designed to form a seal with the face of the wearer. It is available in three types: quarter mask, half mask, and full face piece.
• Loose-fitting respirator: A loose-fitting respirator has an inlet covering that typically covers the user’s head and may extend over the shoulders. It is designed to form a partial seal with the face. These include loose-fitting face pieces, as well as hoods, helmets, or full suits, all of which cover the head completely.
• Atmosphere-supplying respirators: Respirators that supply air from a safe source other than the ambient air are called atmosphere-supplying respirators. There are two types of atmosphere-supplying respirators: Supplied-Air Respirators (SARs) and Self-Contained Breathing Apparatus (SCBA).

Head Protection

There are primarily two situations when employees must wear protective helmets.

1. Falling Objects

When there is a potential in the workplace for injury to the head from falling objects, the employer must make sure that each affected employee wears a protective helmet.

Some examples of work that might require helmets to protect from falling objects include:

• working below other workers who are using tools and materials which could fall;
• working around or under conveyor belts which are carrying parts or materials; and
• working below machinery or processes which might cause material or objects to fall.

Some examples of occupations for which head protection should be routinely considered are:

Electrical Protective Gloves

Protector gloves must be worn over insulating gloves. An exception is when using Class 0 gloves, under limited-use conditions, where small equipment and parts manipulation necessitate unusually high finger dexterity. But, it’s important to note that extra care must be taken while visually examining the glove. Also, make sure to avoid handling sharp objects.

Any other class of glove may be used for similar work without protector gloves if the employer can demonstrate that the possibility of physical damage to the gloves is small and if the class of glove is one class higher than that required for the voltage involved. Insulating gloves that have been used without protector gloves may not be used at a higher voltage until they have been tested.

Cut Resistant Gloves

If employees are subject to sharp objects in the workplace, such as metal banding, sheet metal, or even razor blades, it is advised to wear a cut protection glove.

There are many different rating for cut protection gloves, I explain the ratings below:

ANSI cut levels

EN 388 Cut levels

Risk of injury is an inherent part of many workplaces, and sometimes the risks are unknown or unidentified. We can’t eliminate risk entirely but we can reduce the risk and control it using standard procedures and good work practices. Or, we can just accept the risk as a normal part of doing a job. The question becomes “How much risk are you and your employees willing to accept?”

Accepting Risk

Risk is with us every day and on every task. Risk is determined by frequency (how often we’re exposed to it), probability of something bad happening, and the severity of the outcome. We make decisions about accepting risk every day. Another real question is “Do we understand the risk and are we willing to accept it?”.

Acceptance of risk begins at the organizational level and is forced down stream to the local level. Controlling risk is typically a management function and fortunately, there are some good tools available to help understand risk and keep it at an acceptable level. One tool commonly used today is the Job Safety Analysis.

At the lowest management level, risk has to be controlled by the people doing the work and their immediate supervisors. In both the planning and execution of a task, it is essential to make sure that all those who need to be involved are given an adequate opportunity to be involved and are kept informed of developments that might increase the risks and change the measures needed to deal with them.

Evaluating Work Site Hazards

Workers really are very good at spotting hazards, but not as good at mentioning them. Most incident investigations (my opinion) have found that workers in the area knew the hazard existed. Some thought the hazard was normal and some say they just thought the risk was “acceptable”. How do we, as managers, get our employees involved and help reduce risk?

The goal is to establish a common level of risk tolerance among the team members and there are several things that can affect this process. On any job, the judgment and decisions of the supervisory staff and employees are the most critical part of work area risk assessment and communication of local hazards. A good understanding of the nature of the work, the work environment and the health and safety hazards involved is required of the individuals making decisions on the best way to control the hazards.

The fact that each person’s perception of risk and level of risk tolerance is different is one of the things that complicates communication of risk on a construction site. The JSA is a tool used to improve and document the communication process and ensure mutual understanding of risks and controls by all the people involved.

Managing The Risk

A Job Safety Analysis is an important part of the risk management process in heavy industry. As part of the risk management process, the JSA is a management tool used to reduce the level of risk to the lowest possible acceptable level by allowing all members of a team to interact and develop a common understanding of the task, procedures and hazards associated with completing the task. The tool is available, using it for the greatest benefit is another matter.

The good, bad or indifferent perception of the JSA as planning tool by the person completing it has a significant effect on the quality of information on the document and the level of input by workers involved.

How much individuals are trusted and internal power relations can significantly influence the willingness of employees to communicate and control risk. Other personal factors that can influence communication include individual experience, risk assessment and individual perception of a particular risk with respect to other people on the team or in the area.

Other factors that may influence local risk management include the physical environment of the work area, work procedures (safe work practices), tools and resources available to eliminate or reduce the hazard.

A Basic Guide to Conducting a Risk Assessment

One of the best ways to carry out a risk assessment is to use the experience and expertise of a competent person or persons with experience and relevant competency in their field. A competent person does not mean just qualified. It is important that the person or persons have worthwhile experience and an understanding in what they are assessing. To sum this up, a competent person should have knowledge, experience and a relevant qualification. It is important that the person refreshes their knowledge to ensure that it up to date and relevant.

At this point, it must be made clear that it is not the written document that makes a particular task or job safe, but the control measures that are put in place and reviewed on a regular basis. A suitable and sufficient risk assessment should identify the hazards, evaluate risks, determine appropriate measures necessary and ensure that it is appropriate to the nature of the work whilst being valid for a reasonable period of time.

A hazard is something with the potential to cause harm, whereas risk is the likelihood of harm occurring. The principles of a risk assessment follows a systematic process, which should be considered as a 5 step plan

Step one is identifying hazards. This would be anything that has the potential to cause harm. This could include any item, object, chemical, environmental or work process that has the potential to cause harm.

Check Out: How to Conduct a Job Hazard Analysis

Step two is to identify who may actually be harmed. In a risk assessment, everyone who comes into contact either directly or indirectly with the hazard needs to be included in the finished report. This will include employers, employees, visitors, contractors and anyone else that is affected by the hazard or hazards identified.

Step three is for the evaluation of the risk by considering all existing precautions that already in place. This would be a list of anything and everything that is done to prevent something from causing harm.

Step four is the recording of all findings. This step involves a written documentation (If five or more staff are employed) of all the hazards and the attributed risks as well as all the precautions in place.

Check Out: Job Safety Assessment Form

Step five is the reviewing and revision of the risk assessment as and when necessary. A review could take place on a periodic basis, whereas when necessary would involve an introduction of a new work process, new machinery or new environment, or even if a new hazard or risk has been discovered.

A risk assessment should be reviewed and if necessary modified on a regular basis or after any near miss or accident.

It is a requirement to follow a systematic approach to deciding which control measures need or should be implemented. The hierarchy of control which is basically a systematic process to decide which control measures should be implemented

The first step of the hierarchy of control as well as the most important thing is to try and avoid the risk altogether. If the risk can be taken away, there is no reason to continue the hierarchy of control, as there is no risk of injury.

The second step is substitution. Can the task, equipment, or substance be substituted for something less risky, therefore reducing the harm/

The third step of the hierarchy is enclosure, isolation and separation. Can the work process be enclosed so the workers are not affected by the process and not exposed to the risk?

The fourth step would be the introduction of guarding or safety devices. This would protect all relevant people by preventing them access to dangerous areas.

The fifth stage would be the introduction of a safe system of work, in which procedures must be followed and the staff are made fully aware of what these procedures actually are.

Supervision is the sixth stage of the hierarchy of control. This ensures that effective supervision is in place to monitor that procedures are in place and staff do not take unnecessary risks or short cuts

The seventh stage is training. Training should include all management, supervisors and employees that are involved with the task. The training needs to be relevant to the task in order to make it an effective control

The eighth stage would include information. This information is regarding the hazards and risks in the workplace that have been identified and safe systems that should be followed

The last stage should be the introduction of Personal Protective Equipment (PPE). This is only to be used as a last resort. This is because PPE only protects the wearer from the risk.

It is important to remember that a risk assessment is a systematic process of identifying hazards and risks in the workplace and documenting them. A risk assessment is only a stage in the removal of a hazard and the risk of someone becoming injured or ill at work. A risk assessment is not the last step in regard to health and safety at work, it is a tool to help protect employees, visitors and anyone else affected by the potential hazard as well as the risk.

View the PPE Hazard Assessment Form, then download it below:

PPE is an important component of workplace safety, as no matter how safe you make the workplace with engineering and administrative controls, there will always remain some hazards. Knowing how to pick the right equipment is important, and choosing the wrong equipment can create an unidentified hazard.

After completing your Job Hazard Analysis, and after all engineering and administrative controls are in place, then start consulting these guides to find the optimal PPE for your identified hazards.

No one PPE selection guide is completely comprehensive, so we are offering multiple guides here, plus links to more resources.

What is required when your company implements PPE:

• Only use PPE as a last resort;
• If PPE is still needed after implementing other controls (and there will be circumstances when it is, eg head protection on most construction sites), you must provide this for your employees free of charge;
• You must choose the equipment carefully (see selection details below) and ensure employees are trained to use it properly, and know how to detect and report any faults.

Selection of PPE:

• Who is exposed and to what?
• How long are they exposed for?
• How much are they exposed to?

Check Out: PPE Hazard Assessment and Certification

When selecting and using PPE:

• Choose products which are ANSI marked
• Choose equipment that suits the user – consider the size, fit and weight of the PPE. If the users help choose it, they will be more likely to use it
• If more than one item of PPE is worn at the same time, make sure they can be used together, eg wearing safety glasses may disturb the seal of a respirator, causing air leaks
• Instruct and train people how to use it, eg train people to remove gloves without contaminating their skin. Tell them why it is needed, when to use it and what its limitations are

Other advice on PPE

• Never allow exemptions from wearing PPE for those jobs that ‘only take a few minutes’
• Check with your supplier on what PPE is appropriate – explain the job to them

Download OSHA’s 3151 PPE guide; it is an exhaustive guide for PPE selection:

Download this PPE Selection and Usage Guide if you have a need for medical PPE:

Download the PPE Selection and Use Guide from Duke University, which includes links to Duke University policies for specific safety concerns:

Download this PPE selection guide from UC Davis, it covers PPE with pictures and hazard mitigation suggestions:

Download this PPE Selection Guide from the US Department of Homeland Security for Emergency First Responders:

Links

Michigan State University EHS Department PPE Guidelines

MTSU’s PPE Selection Guide

Tuft’s University PPE Selection Guide

CDC Guidance for the Selection and Usage of PPE in Healthcare setting

UCLA’s PPE Selection Guide for Hazard Assessments

University South Florida Hazard Control and PPE Selection Guide

CIRSA PPE Guide

RAND Corporation PPE Guide for Emergency Responders

University of Washington Guidelines for PPE

Stony Brook University PPE Guide for laboratory researchers

Montana Tech PPE General Guidelines for Selection and Use

OSHAcademy Course 709 PPE Study Guide for selection and use

Central Michigan University PPE Selection Guide

CDC/NIOSH PPE Guide for hazardous materials Incidents