Each day countless workers put on gear in order to protect themselves from workplace hazards. This gear is called personal protective equipment, or PPE. Unfortunately, some of these workers aren't being protected enough - or in some cases - at all. It turns out that certain fundamentals must be met in order for you to have a successful PPE program that both complies with OSHA requirements and protects your workers.
For starters, your workplace hazards need to be identified. What jobs and tasks are your workers performing? What potential hazards are associated with these jobs and tasks? Is there a risk of coming in contact with chemicals, loud noises, or being struck by something? The list of hazards is actually much longer and also includes extreme temperatures, electric shock, sharp objects and surfaces, and light sources such as lasers and welding arcs.
You may guess that you're ready to select PPE once your workplace hazards are identified. This is not the case, however. Instead OSHA requires that employers investigate other more robust means of protection. Can the hazard be eliminated altogether, or can a safer material or item be substituted into the workplace? Can physical changes such as barriers and enclosures be made to protect the worker from the hazards? Can ventilation be installed? Can safe work practices be established or can workers be rotated through hazardous areas or tasks in a way that minimizes their exposure to the hazard?
OSHA allows PPE in the workplace after you've investigated the approaches described above and determined them to be infeasible. OSHA interprets infeasible to mean that implementing the approach is economically impracticable - the employer would not be able to afford to stay in business if it invested in the approach. Infeasible can also mean that the approach is technologically impracticable or even unavailable. In other words, there may not be a way to eliminate a hazardous chemical or design a device that isolates a hazard.
Why is so much emphasis put on other hazard protection mechanisms and why is PPE the least preferred method? It's because successful PPE programs depend on many factors, starting with the employer. Was the right type of PPE selected? Sometimes employers don't understand or perhaps overlook the fact that almost every type of PPE has performance guidelines, capabilities, and limitations. For example, has the glove material been tested against the chemical of concern? If so, what is the penetration and/or permeation rate? Will the respirator or cartridge material prevent the inhalation of an air-borne chemical? Are the safety glasses and faceshield manufactured according to ANSI 87.1 guidelines? Do the ear plugs or ear muffs have a noise reduction rating (NRR) that adequately reduces noise exposures?
Assuming that the correct type of PPE has been chosen, the employer can now focus on other obligations. First and foremost, OSHA requires that virtually all PPE be provided at no cost to the employee. In addition, is it readily available and in sizes that fit each employee? Has management and supervision communicated the PPE selections to the employees? Have the employees been trained on the proper use of PPE? And last but not least, does the employer have an OSHA-required written certificate of hazard assessment that identifies the workplace evaluated, the person certifying that the evaluation has been performed; the date(s) of the hazard assessment?
Let's move on to the employees, as they also play a major role in your PPE program. Are they wearing the PPE when they are required to do so? Are they properly inspecting, wearing, and storing it? Replacing it when needed? Properly discarding it when it no longer is suitable? Are they sharing questions and concerns about their PPE with their employer?
The many employer and employee requirements and responsibilities outlined above depend on people doing things correctly. Any failure puts your PPE program - and the safety and health of your employees - in jeopardy. This is why PPE is the OSHA's least preferred way of protecting employees from workplace hazards.
Don't shortcut or skimp on your PPE program. Understand your own capabilities and limitations. Do you have the background and education needed in order to develop a PPE program that meets OSHA requirements, but more importantly protects your workers? A Certified Industrial Hygienist from Cashins & Associates has the experience and credibility to help you develop and implement PPE and other Health and Safety programs. Click on the link below for more information.