Implementing an Effective Personal Protective Equipment (PPE) Programme
Introduction Personal protective equipment is preventive equipment which is used by the worker to protect his safety in many organisations and workplaces, from hard hats to protect the head, gloves to protect hands, glasses to protect the eyes or sunscreen to protect skin from the harsh weather conditions in the Middle East. It can however be one of the most commonly misused items when looking at risk reduction within a business. PPE by design will not prevent any hazards from occurring, all it can do is to lessen the severity or provide you with some time before the hazard really hurts! PPE should always be the last line of defence. Hazards should be managed through a process of controls as outlined in this document. PPE is defined in the OSHAD-SF Glossary of Terms as: Any device, appliance or equipment (including clothing or sunscreen affording protection against the weather) designed to be worn or held by an individual for protection against one or more health and safety hazards, or minimize their exposure to workplace risks. It includes, but is not limited to, items such as facemasks and respirators, eye protection, high visibility clothing, coveralls, goggles, helmets, safety harnesses, gloves and footwear. PPE does not apply to general clothing worn whilst at work, such as corporate clothing with the primary purpose of presenting a corporate image. However any uniform or clothing provided to protect against a specific risk, such as high visibility vests, would be considered as PPE. It is important to note that employers must not charge for the issue or re issue of any item that has been deemed as PPE, regardless of how many times it needs to be replaced. 01
Why is PPE important? Starting point: Risk Assessment Even with the most robust risk control strategies in place, risk will still be present in our workplaces. It is this risk that PPE can help protect your emloyees against. All entities within Abu Dhabi must develop and implement a risk management program that aligns with the requirements of OSHAD-SF Element 2 Risk management and as part of this, the hierarchy of risk control should be considered as shown in the figure below which includes PPE. Even with the best controls in place, some hazards may still pose a risk to the safety and health of your workforce. As an example you may work with a lot of glass and although you have installed control measures such as barricades to prevent access there is still a risk of broken glass and as such you should consider PPE such as gloves, glasses and footwear for your staff to help prevent injury. The use of personal protective equipment and administrative controls are the lowest on the hierarchy of control measures. These controls should not be relied on as the primary means of risk control until the higher options have been exhausted. As with everything in Safety and Health, the first step is always to assess the risks that are present in your workplace and from this decide what control measures you can introduce to eliminate the risk. If you are unable to eliminate the risk then you need to look at alternative measures to reduce the risk, this may include the provision of PPE. OSHAD-SF Element 2 Risk Management sets the requirements that all risk assessments must consider when developing a risk management program and OSHAD-SF TG - Process of Risk Management provides advice and guidance on how to implement this program. It is important to note that providing PPE should always be considered as a last resort in the control of risk. There are many reasons for this however one of the main ones being that PPE only protects the user if it is used correctly and therefore relies on that person 100% of the time. Other reasons PPE may not offer protection against hazards could be: Not working or fitted properly ELIMINATION SUBSTITUTION ENGINEERING CONTROLS/ ISOLATION ADMINISTRATIVE CONTROLS Personal Protective Equipment (PPE) Eliminate the risk by removing the hazard Substitute less hazardous materials, equipment, processes or substances Make structural changes to the work environment, work system, tools or equipment. Use mechanical aids or manual handling devices. Enclose or isolate the hazard through the use of guards or remote handling techniques. Provide local exhaust ventilation. Appropriate administrative procedures such as policies, guidelines, standard operating procedures (SoPs), register, work permits, safety signage, job rotation, job timing, routine maintenance and housekeeping. Provide training on the hazards and correct work procedures. Provide correctly fitted and properly maintained personal protective equipment (PPE), and / or protective clothing and the training in its use. Theoretical levels of protection are seldom reached in practice. The use of PPE restricts the wearer to a degree. The wearer feels more protected than they actually are It is not maintained correctly Use of personal protective equipment should only be considered as a control measure when exposure to the risk cannot be reduced in any other way. Use of personal protective equipment can be regarded as a temporary or an interim measure until further controls are put in place. PPE can also be used effectively in conjunction with other measures to manage exposure to a risk. 02 03
Selecting PPE i- It is appropriate for the risk or risks involved, the conditions at the place where exposure to the risk may occur, and the period for which it is worn; Once you have decided that PPE is required in your workplace you now need to start thinking about the different types that are available and what will best suit your workplace and your workforce. The PPE you source must meet the national criteria stated in the Council of Ministers Decision No. 3 of 2016 Regarding the UAE Regulation for Personal Protective Equipment, the international standards stated in that regulation, and any international standards approved by the Emirates Authority for Standardization and Metrology (ESMA) in fulfillment of that regulation. The national regulation allows ESMA to approve any product carrying the Emirates Quality Mark or any Mark that is approved by ESMA. The risks that are present in the workplace will determine the type of PPE that you will require, what is important is that you choose PPE that will offer the correct level of protection and suits your workforce. You may wish to speak to your PPE supplier to get additional advice on the type of PPE available or also consider contacting the manufacturer to get advice on their products and how suitable it is against the risks in your workplace. It is important to remember that the PPE you are buying is the last layer of protection for your workforce against that particular hazard so never just look for cheapest solution as this may not offer the correct level of protection and may in some cases bring additional risk to the workplace. When selecting PPE there are a number of issues that you need to take into consideration to ensure you have the best solution. OSHAD-SF COP 2.0 - Personal Protective Equipment has the following requirements that you must consider when selecting PPE: ii- iii- iv- Choose the right PPE to match the hazard and the workplace it is being used within. Certain types of gloves may protect your workforce against cuts but if you also work in a cold or hot workplace then these additional hazards will also need to be considered. Eye protection designed to protect against chemicals may not offer the right level of protection if using a grinder or cutting stone. Consider how long the PPE will be worn for, this will also have an effect on the type of PPE to source. It takes account of ergonomic requirements and the state of health of the person or persons who may wear it, and of the characteristics of the workstation of each person; The people that are wearing the PPE are all different, this again will affect the type of PPE you source. If the PPE is heavy or cumbersome, the person may not be able to perform his duties safely or if it is difficult to put on or wear, again the likelihood of the person wearing it correctly decreases along with the effectiveness of the actual PPE. It is capable of fitting the employee correctly, if necessary, after adjustments within the range for which it is designed; As mentioned above everyone is different in shapes and sizes, and this will affect the PPE and how effective it is in protecting your workforce. Small things like having a beard will affect the way a facemask will protect an employee. Those who wear sight glasses will need different eye protection against those who don t. Where the PPE is provided for protection against chemicals, chemical protection / penetration is assessed and factored into the PPE replacement; and You must consider this as part of your assessment and ensure you are aware of the lifespan of the PPE you are providing. Certain types of PPE are designed for use with different types of chemical and will offer protection at a certain level for a period of time. 04 05
v- So far as is reasonably practicable, it is effective to prevent or appropriately control the risk or risks involved without increasing overall risk. Does the PPE you are going to provide control the risks that you have identified within your risk assessment? As you have now introduced an additional factor to the workplace, you need to assess this through your risk assessment. An example of where additional risk can be introduced would be the wearing of hearing protection. This may reduce the person, s ability to hear warning signals from moving machinery or alarms. Consultation When selecting PPE always ensure you consult with your employees on all matters that will affect their Safety and Health t. You may find that the type of PPE that you had considered most suitable does not actually work in site. vi- Employers shall ensure that where the presence of more than one risk to health or safety makes it necessary for employees to wear or use simultaneously more than one item of PPE, such equipment is compatible and continues to be effective against the risk or risks in question. Where your risk assessment has identified that several types of PPE are required to protect your workforce, you need to check that they are compatible and do not add additional risk to the person. For example does using a respirator make it difficult to fit eye protection properly? vii- Employers shall ensure that where they supply non- PPE clothing and footwear (e.g. corporate uniforms) that an appropriate risk assessment is performed as per the requirements of OSHAD-SF Element 2 Risk Management. As mentioned above if you supplied corporate clothing then you have introduced an additional factor to the workplace and you must ensure that this doesn t add any additional risk to your employees. It is good practice to try and source several options of the PPE that will offer the correct protection and from this trial them within the workplace. Offer your staff the opportunity to try these and give feedback on which is the most comfortable whilst still protecting them against the risks. You may also want to involve the PPE supplier and / or the manufacturer in this consultation process. Things you should discuss during this phase include: Discuss the specific safety and health issue and the types of protection required; Feedback on the trials undertaken on different types of PPE; Consider any concerns on the PPE offered; Consider all feedback, from the supplier / manufacturer, your workforce before making a decision on what is purchased; Consider workers medical conditions, which can influence whether they can use certain items of equipment. Ensure that all those who are affected by the need for PPE have the opportunity to give feedback or raise their views. This doesn t mean you need to let your entire workforce try the different types or attend meetings ect, however make sure they are aware of the trials ongoing, who is participating and how they can put their views forward. By including your staff in this process, it is proven that they are more likely to accept the PPE and also understand the need to wear it. 06 07
Training and Information It is a requirement under OSHAD-SF CoP 2.0 Personal Protective Equipment that you train your staff on the use of the PPE that is being provided. It is also important to note that you should also train staff who may be affected by the misuse of the PPE and what hazards that may pose in the workplace. Items of personal protective equipment must be used in accordance with accompanying instructions, to ensure the desired level of protection is gained. The manufacturer or supplier of the equipment should provide instructions about how to use (and fit) the item of equipment. When designing training to cover the use of PPE, the following must be included in that program: the risk(s) which the PPE shall avoid or limit; the limitations of the PPE; when and where the PPE shall be worn; what PPE shall be worn; how to correctly don, doff, adjust and wear PPE; the correct care, cleaning, useful life, maintenance and disposal of the PPE; identification of defects and reporting procedures; correct storage of PPE; inspection of PPE prior to, during and after use; and procedures for recording issue and use of PPE. The training you give can be delivered in many ways, either to groups or individuals and can be a mix of theory and practical job. You must also ensure that those who supervise your workforce are fully aware of the PPE requirements, the risks involved and how PPE should be worn as they will be the front line checking this requirement. You should also incorporate a test of knowledge at the end of the training session to ensure that those who have attended the session have taken the right level of knowledge on board and are fully aware of the requirements. The test of knowledge or exam should include a mix of both practical and theory. If some of your workforce are not able to display a sound understanding of the requirements, then you must ensure that they are not allowed to operate or use the PPE until such times that they have been retrained and can demonstrate sufficient knowledge to be able to use the relevant PPE safely. The level of training provided should vary with the level of risk involved and the complexity and performance of the equipment. For instance, the use of respirator equipment will require comprehensive training with regular refresher courses. Once you have completed training, ensure that you record the results and keep records of the training. There may be a need to undertake refresher training for certain types of PPE, the manufactures instructions will let you know about this, however it is good practice to continually refresh training to ensure your workforce is fully up to date on how to use the PPE safely. This is to ensure that personal protective equipment is continuing to be used properly. Training should also be provided to workers when work practices and/or equipment are up-dated. 08 09
Inspection, Maintenance and Storage of PPE Every type of PPE should be inspected prior to use to make sure that it is still in good working order and has no obvious defects that will affect the performance. The training you provide should give your workforce sufficient information on how to undertake these inspections and spot any defects. PPE that is found to be defective must be replaced immediately by the employer, free of charge. There is also a need to ensure that PPE is maintained as required, this again will be detailed in the manufacturer s instructions and should form part of the training that is given to the people that have to use the PPE. Where maintenance is required, ensure that you keep replacement parts in stock that match the original. Monitoring Once you have implemented your PPE program and provided your staff with the correct PPE, there is a need to ensure that you monitor the program for effectiveness. This can be done through a variety of ways including audits and inspections. Signs should be posted in conspicuous locations at the workplace wherever it is necessary to use personal protective equipment. These signs serve as a useful reminder of the kind of personal protective equipment that should be worn. You should check that the PPE is being worn correctly by your workforce and if you find that this is not the case, look at why it is not being worn correctly, this may point to the wrong type of PPE or understanding of the training. Check that the signage you have provided to inform your workforce of the need to wear the correct PPE is still in place and up to date. Consult with your workforce on a regular basis to get their feedback on the PPE and how it is working. As part of your program, you should detail what maintenance is required for all the PPE that you use within the workforce, including the timescales and who is responsible for undertaking this. Also consider how PPE is going to be stored within your workplace, the storage for PPE must ensure prevention of the following issues: Damage from chemicals, sunlight, high humidity, heat and accidental knocks; Contamination from dirt and harmful substances; The possibility of losing the PPE; and Contamination from multi users. A further issue that employers must consider is to ensure that where PPE is designed to be used by one person only, the storage provided should be secure to prevent others from using this PPE. 10 11
Selecting the Right PPE Head Protection Hazards: Falling or flying objects, bumps. PPE Options: Hard Hats, Bump Caps. Eye protection Hazards: Dust, gas, vapor, projectiles, radiation. PPE Options: Safety Glasses, Goggles, face visors or shields. Hearing Protection Hazards: Loud impact noise, continuous noise. PPE Options: Appropriate hearing protection, ear muffs, ear plugs ect. Fall Protection Hazards: Working at heights. PPE Options: Body harness. Respiratory Hazards: Particles such as concrete dust, fiberglass, chemical vapors. PPE Options: Suitable face masks or half/ full face mask. Hand Protection Hazards: Sharp edges, knives, cold/hot surfaces, chemicals, vibration. PPE Options: Suitable gloves for the specific hazard. Visibility Hazards: Footwear Hazards: Low light or foggy conditions PPE Options: High visibility clothing. Dropped objects, crushing, sharps, slippery surfaces PPE Options: Appropriate safety shoes. 12