Personal Protective Equipment

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2 Chief Content Officer: Founder: Managing Editor Safety: Legal Editor: Manager CMS: Art Direction: Content Production Specialist: Ed Keating Robert L. Brady, JD David L. Galt Ana Ellington Isabelle B. Smith Vincent Skyers Sheryl Boutin This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional services. If legal advice or other expert assistance is required, the services of a competent professional should be sought. (From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers.) 2013 BLR BUSINESS & LEGAL RESOURCES All rights reserved. This book may not be reproduced in part or in whole by any process without written permission from the publisher. Authorization to photocopy items for internal or personal use or the internal or personal use of specific clients is granted by Business & Legal Resources. For permission to reuse material from Top 10 Best Practices in Safety Management for 2013, ISBN , please go to or contact the Copyright Clearance Center, Inc. (CCC), 222 Rosewood Drive, Danvers, MA 01923, CCC is a not-forprofit organization that provides licenses and registration for a variety of uses. ISBN Printed in the United States of America Questions or comments about this publication? Contact: BLR Business & Legal Resources 100 Winners Circle, Suite 300 P.O. Box Nashville, TN

3 TABLE OF CONTENTS Personal Protective Equipment...1 OSHA PPE rules...1 OSHA General Duty Clause...2 Hazard assessment...2 Payment for PPE...3 Best practice: 4 steps to effective worker protection...4 Frequently Asked Questions...6 Personal Protective Equipment iii

4 Personal Protective Equipment Employers must provide personal protective equipment (PPE) and training to each employee who is or may be exposed to physical or health hazards in the workplace when engineering and administrative controls cannot feasibly or effectively reduce exposures to safe levels. PPE is designed to protect your workers from serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Besides face shields, safety glasses, hard hats, and safety shoes, protective equipment includes a variety of devices and garments such as goggles, coveralls, gloves, vests, earplugs, and respirators. Hazard assessment. To determine if hazards are present, or are likely to be present, that require the use of PPE, OSHA requires you to assess your workplace and the jobs employees perform. If hazards are present, or likely to be present, you must: 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; Communicate selection decisions to each affected employee; and Select PPE that properly fits each affected employee. The two basic objectives of any PPE program are to: Protect the wearer from workplace hazards. Prevent the wearer from being injured if there is a malfunction of PPE or if he or she uses the equipment incorrectly. OSHA PPE rules General industry. The most commonly applicable regulations are found at: 29 CFR PPE: General Requirements 29 CFR Eye and face protection 29 CFR Respiratory protection 29 CFR Head protection 29 CFR Foot protection 29 CFR Hand protection 29 CFR Occupational Noise Exposure 29 CFR (c) and (g) HAZWOPER Personal Protective Equipment 1

5 Construction industry. The PPE requirements for the construction industry are located at Personal Protective and Life Saving Equipment (29 CFR to ). OSHA General Duty Clause OSHA may also apply its General Duty Clause to PPE-related situations. The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), requires an employer to furnish to its employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees. Role of other federal agencies National Institute of Occupational Safety and Health (NIOSH). Though NIOSH does not have regulatory authority, OSHA rules have incorporated by reference several NIOSH standards for the design and use of respirators. Environmental Protection Agency (EPA). The EPA regulates the use of PPE for pesticide applications, emergency response to releases or spills of hazardous substances, and for protection against exposure to significant new uses of hazardous substances. United States Coast Guard (USCG). The USCG regulates PPE requirements for facilities and operations on the Outer Continental Shelf (OCS). National consensus standards. The American National Standards Institute (ANSI) has developed specifications for various types of PPE (gloves, footwear, eyewear, and headwear) and for measuring their effectiveness and quality. The American Society for Testing and Materials (ASTM) has developed specifications for electrical equipment and PPE. Though ANSI and the ASTM do not have regulatory authority, several of their industry consensus standards have been incorporated into OSHA rules by reference. Hazard assessment Each employer must assess the workplace to determine if hazards are present, or are likely to be present, and necessitate the use of PPE. Every job in the workplace must be evaluated. The employer must certify in writing that the PPE hazard assessment has been performed. The written certification must identify: The workplace evaluated The date of the assessment Personal Protective Equipment 2

6 The person certifying that the evaluation has been performed The hazards found The PPE selected Employers must determine what types of PPE are appropriate for their workers and ensure that workers know how to use PPE items properly. OSHA has supplied what it calls nonmandatory compliance guidelines to aid employers in the hazard assessment and PPE selection process (29 CFR 1910, Subpart I, Appendix B). Payment for PPE Employers must pay for most types of PPE when used by employees exclusively in the workplace (i.e., not for personal use at home or other nonworkplace activities). PPE replacement. Employers must pay to replace worn or damaged PPE as part of the employer s obligation to ensure that the PPE is in good condition. The employer is not required to pay for replacement when the employee has lost or intentionally damaged the PPE. Employee-owned PPE. When an employee voluntarily purchases and wears his or her own PPE and is allowed to use it at the workplace, the employer is not required to reimburse the employee for that equipment. If employees are allowed to use their own PPE, however, the employer is responsible for its adequacy, maintenance, and sanitation. If an employee has provided his or her own PPE but the employer s hazard assessment determines that an upgrade to or replacement of PPE is required, the employer must pay for the upgrade or replacement regardless of who paid for the original PPE. Personal Protective Equipment 3

7 Best practice: 4 steps to effective worker protection As an employer, you have two important safety goals to keep in mind: 1. Protect your employees as they perform their duties. 2. Comply with OSHA regulations that apply to your workplace. These two goals must be considered for all phases of your operations, but they are clearly paramount in the case of PPE. As the name clearly states, the purpose of the regulation is employee protection, and OSHA spells out exactly how this protection must be achieved. 1. Hazard assessment. Section (d)(1) of the OSHA standard says that employers must assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment. Think head-to-toe protection and be sure to consider all the hazards falling objects, chemical exposures, flying objects, sharp objects, and rolling or pinching objects as well as all the protections hard hats, safety glasses and goggles, respirators, gloves, safety shoes, and other clothing and equipment. The better you identify and understand the impact of specific hazards, the better able you will be to take the next step and select the most appropriate PPE. 2. Equipment selection. Section (d)(1) also says that if such hazards are present or are likely to be you must: Select, and have affected employees use, the types of PPE that will protect them from the hazards you have identified. Communicate selection decisions to employees. Select PPE that fits each affected employee properly. Section (h) states that PPE, with only a few exceptions, must be provided by the employer at no cost to the employee. The exceptions are as follows: Nonspecialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots), provided the employer permits such items to be worn off the jobsite Nonspecialty prescription safety eyewear, provided the employer permits such items to be worn off the jobsite Shoes or boots with built-in metatarsal protection that the employee chooses instead of metatarsal guards provided by the employer Logging boots required by 29 CFR (d)(1)(v) Personal Protective Equipment 4

8 Hazard assessment and equipment selection the first two steps are actually the easy part. The hard part is encouraging employees to actually use the PPE. The next two steps training and follow-up present the challenge of reaching employees and communicating your important message. 3. Train employees. Section (f)(1) requires you to train employees concerning each type of PPE before allowing them to perform any work requiring its use. At a minimum, your PPE training program must include the following information: When PPE is necessary; What PPE is necessary; How to properly don, doff, adjust, and wear PPE; Limitations of the PPE; and Proper care, maintenance, useful life, and disposal of the PPE. The regulations [ (f)(3)] also require you to retrain whenever: Changes in the workplace render previous training obsolete; Changes in the types of PPE to be used render previous training obsolete; or Inadequacies in an employee s knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill. 4. Follow up Reinforce and enforce. You have to accept the fact that no matter what you do, a few employees will still forget to use their PPE, ignore the rules, think that PPE is for wimps, or believe that accidents happen to someone else. Daily monitoring is essential to see that employees are actually wearing their PPE. Try these suggestions to motivate your employees and keep your PPE program from going down the drain: Use a behavioral approach. As you walk around the department every day, give employees positive feedback for using PPE. Make it easy to get and exchange PPE. If it s a hassle for employees to get PPE or exchange damaged or worn articles for new ones, they probably won t bother and will opt for just not using it. Recognize and reward employees for using PPE. At safety meetings, praise employees for using PPE. Personal Protective Equipment 5

9 Recognize proper use of PPE in performance appraisals. Be sure that employees realize that this will be part of their evaluations. Enforce PPE policies. Use discipline, if necessary, as a last resort to show employees you are serious about their wearing assigned PPE. Like any other program, your PPE program should be reviewed periodically to make sure it still meets your company s needs and OSHA requirements. Following the four essential steps, however, should also give you confidence that you are complying with OSHA regulations and are doing all that is possible to keep your employees safe. Frequently Asked Questions Q. I wear prescription lenses; what are my safety eyewear options? A. Workers who wear prescription lenses must wear a pair of safety glasses that incorporate the prescription in its design, or wear safety glasses that can be worn over prescription lenses without disturbing the proper position of either. Q. How should I maintain my protective eyewear? A. Safety eyewear must be maintained properly in order to provide you with maximum protection. Protective eyewear should be cleaned according to the manufacturer's instructions. If no instructions are available, clean or soak the eyewear with mild soap and warm water (120 F). Rinse thoroughly and allow to air dry. Q. What size respirator should I order: small, medium, or large? A. Even though approximately 80 percent of people wear a mediumsized respirator, the only way to determine the correct size mask is to perform a fit test. When performing a fit test, start with a medium mask. If during the fit test it is determined that the mask does not fit properly, proceed testing with the next possible appropriate size for the person being tested. Q. How do I go about selecting the proper cartridge for my application? A. Cartridges do have limitations. A chemical cartridge contains activated charcoal. The charcoal is activated based on the contaminant it is designed to absorb. To determine the proper cartridge for air-purifying respirators, either contact a safety professional or consult the Safety Data Sheet (SDS) of the substance that needs to be filtered. All cartridges are assigned a color designating the type of contaminant they will filter. Personal Protective Equipment 6

10 Q. Can I wear my hard hat backward? A. In January 2009, ANSI updated the Z89.1 standard to include three non-mandatory tests that hard hat manufacturers can use to evaluate their product. One of these tests is the Reverse Donning test. Helmets marked with a "reverse donning arrow" can be worn frontward or backward in accordance with the manufacturer's wearing instructions. Hard hats marked with this "arrow" pass all testing requirements, whether worn frontward or backward. Q. What is a Noise Reduction Rating (NRR)? A. The Noise Reduction Rating (NRR) is defined as the maximum number of decibels (db) the sound level will be reduced when the hearing protector is worn. Personal Protective Equipment 7

11 We have what you need to help keep your people and facility protected. Call, click or stop by a branch today W.W. Grainger Inc. The Grainger shipping box design is a registered trademark of W.W. Grainger, Inc.

OSH INFORMATION MEMORANDUM 95 X 96. Inspection Guidelines for the Revised Personal Protective Equipment Standards for General Industry

OSH INFORMATION MEMORANDUM 95 X 96 TO: FROM: All OSH Compliance Personnel W. M. Lybrand DATE: August 8, 1995 SUBJECT: Inspection Guidelines for the Revised Personal Protective Equipment Standards for General