The importance of a personal protective equipment program

A personal protective equipment (PPE) program, in which employees wear special clothing or equipment as a protective barrier against workplace hazards, is an essential safety component in workplaces where various types of hazards are present. The following information discusses PPE and examples of when this equipment should be used. It also gives guidelines for implementing an effective PPE program to optimize prevention of employee exposure to unsafe equipment and situations.

PPE program – why and how to begin

Engineering and administrative controls, along with good work practices, are the preferred ways to control hazards in the workplace, and should be implemented before PPE is considered. However, in situations where exposures cannot be feasibly controlled using these methods alone, PPE must also be used to ensure employee safety and health.

The basis of any PPE program is compliance with OSHA guidelines. These are the minimum standards enforceable by OSHA and are the focus of this article. Incorporating best practices may also result in additional benefits, such as attracting and retaining employees who share these values.

A PPE program begins with a thorough evaluation of workplace hazards and a determination of what equipment is needed to protect vulnerable parts of the body, including eyes and face, feet and legs, the head, and hands. The evaluation should be in writing and available to employees. Please refer to Travelers “Personal Protective Equipment Hazard Assessment Sample Form” for a sample blank form and a completed example.

PPE can be very effective in helping to minimize risk and ensure safety and health, but to do so it must provide adequate protection, be well maintained, and be used by the worker. Once appropriate PPE is purchased, employees must be trained on its protective limitations as well as its proper use and maintenance. For compliance purposes, you must keep records of this training.

*Note: Hearing and respiratory protection is not discussed in this article, as the need for these types of protective devices cannot be determined by an employer-conducted walk-through survey, but rather require scientific analysis conducted by an industrial hygienist.

Assessment

OSHA requires that all workplaces must be inspected by the employer to determine the need for PPE. A walk-through survey should include observation of the layout of the work area as well as hazards present. Examples of hazards are motion of tools, machinery and personnel; chemical exposures; flying particles, light radiation; sharp objects; electrical hazards; sources of high temperatures; falling or dropping objects; and rolling or pinching objects. A signed document certifying that the workplace walk-through assessment took place is required for compliance purposes. The written assessment document should include the following:

This assessment should be updated periodically. An update is required when there has been a change in employees, work practices, equipment or materials.

Selection of PPE

Selected PPE must be appropriate for the work being performed, and an adequate supply should be provided to the employees, free of charge, to ensure their protection.

Also evaluate the potential for exposure to multiple or simultaneous hazards. For multiple exposures, the highest level of protection for each of the hazards should be provided. Careful consideration should be given to comfort and fit of PPE in order to provide optimum protection with as little discomfort as possible, and to ensure that it will be used. Both supervisors and employees should be involved in identifying needs for and appropriate types of PPE to increase buy-in and compliance with regulations.

Training

If employees are required to wear PPE, they must be aware that PPE does not eliminate the hazard, and that if it fails, exposure may occur. Initial training and refresher courses should include, but not be limited to, the following:

When a training session is completed, each employee should demonstrate proper use of the PPE. If they can’t, they must be retrained. It is a good practice to re-train all employees annually.

Recordkeeping

Keep written records for a minimum of three years and include the names of every person trained, the type of training provided, and the dates when training occurred. Inspection, cleaning, parts replacement, and the service provided should also be recorded and used in analysis of compliance with standards.

Maintenance of PPE

Personal protective equipment should be cleaned regularly and be properly maintained to ensure it will provide maximum protection. A sanitation and maintenance program should be implemented to improve employee confidence in its use. (Equipment manufacturers provide recommendations for maintenance of their equipment.)

Storage and cleaning facilities should be provided to maximize the serviceable life of the PPE and to encourage worker responsibility for its use and care.

Personal protective equipment should not be shared unless it is properly cleaned and sanitized, and contaminated equipment that cannot be decontaminated must be properly thrown away.

Defective or damaged PPE must also be properly disposed of and its user issued new equipment.

Compliance auditing

For your protection and that of your employees, develop a policy of disciplining violators of established rules for PPE use. For example, the employee may be verbally warned after the first violation and provided written warnings after the second or subsequent violations. Warnings should become a part of the employee’s work record.

Have supervisors plan and schedule regular contacts with workers to reinforce personal protective equipment standards.

Employees’ compliance with personal protective equipment standards should be audited on a quarterly basis. As part of the audit, determine the level of protective equipment use against OSHA requirements and the written hazard assessment, check equipment condition, and provide training when needed.

Protective devices

The following information on protective devices for eye/face, head, hand, and foot/leg protection is strictly general. If you need more specific information relating to OSHA compliance, see OSHA 29 CFR 1910.133-138.
Note: All protective devices must be NIOSH or ANSI approved.

Eye/Face Protection. Anyone working in or passing through an area that has been identified as having eye hazards must wear protective eyewear, including those who wear prescription eyeglasses or contacts. An adequate supply of safety glasses/goggles must be available to employees as well as eyewear appropriate for covering prescription eyeglasses or equipment that has prescriptive lenses incorporated into its design. Examples of eye hazards include:

Note: Primary eye protection must be worn under face shields

In eye/face hazard areas, emergency eyewash facilities should be located in easily accessible areas. These emergency eyewash facilities must meet applicable ANSI standards.

Head protection. If hazards in an area possess the potential to result in injury to the head, employees working in that area and all those passing through it must be provided head protection. Hazards from fixed objects require the use of bump/skull caps to protect from lacerations. If there is potential for falling objects or high-impact forces, safety hats must be worn, as they absorb the shock from a blow and resist penetration. Some safety hats also provide protection from electrical shock.

Hand protection. Where injury to the hands or fingers can result from cuts, chemicals, burns, lacerations, or abrasions, suitable hand protection should be required. Since not every glove is suitable for every given task, glove selection should be based on the hazard presented, the characteristics of the glove, and the amount of time it will be in use. All gloves are eventually permeable to chemicals and should only be used for the duration specified based on glove material, thickness, permeation rate, and time.

Foot/leg protection. If a work area presents a significant risk for a heavy object to be dropped, or if sharp objects, molten metal, hot surfaces, or wet surfaces are present, then safety shoes including boots, shoe covers, leggings or other protective foot/leg wear should be worn.

PPE is an essential component of workplace safety programs where physical hazards exist. To ensure a safe workplace, have appropriate equipment on hand, have a training program for employees, regularly maintain your PPE, and have scheduled audits.

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