Skin Protection: What Employers Must Do

Yesterday we saw how frequent hand washing may lead to a higher incidence of contact dermatitis (an irritation of the skin caused by chemicals). We turn now to the larger issue of skin protection in general, and look at a resource that explains your legal obligations as well as best practices for limiting occupational skin diseases.

Never underestimate the importance of your skin. It acts as a barrier to such harmful elements as dirt, bacteria, temperature extremes, and radiation. However, because it is exposed to so many hazards, skin is vulnerable to a variety of disorders – and they are nothing to be sloughed off.

According to the BLR Safety Audit Checklists:

  • Dermatitis (irritation of the skin caused by chemicals) is the most common job-related disease.

  • The cost of occupational skin diseases is as high as $1 billion per year.

  • The highest rates of skin disease occur in health care, agriculture, and manufacturing occupations.

Our sister publication, the OSHA Compliance Advisor, tell us there are two general types of dermatitis: primary irritation and sensitization.

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Primary irritation usually results from contact with substances–such as strong acids, caustics, and solvents–in significant quantity, concentration, and time. Strong acid solutions–like hydrochloric, sulfuric, and nitric acids–can cause severe burns after only brief contact, as can contact with such strong caustics as sodium hydroxide and potassium hydroxide.

Solvents have a different effect on the skin. Their normal use, removing grease and oil in industrial processes, also removes fats and oils from the skin; because that results in water loss, the skin becomes cracked and dry. Prolonged exposure to oils and waxes, on the other hand, can plug up the skin’s hair follicles and sweat ducts, causing inflammation and acne.

Sensitization results from an allergic reaction to a substance. It is generally established over a long period, to the point where exposure to even a small amount of that substance can produce a severe case of dermatitis.

Legal Issues

From an employer’s perspective, skin exposure hazards by themselves do not typically result in OSHA violations and citations, according to Safety Audit Checklists. However, citations under the Hazard Communication Standard for failing to inform employees of the hazards of the substances they work with are quite common.

OSHA includes a “skin designation” column in Table Z-1 of the standard on air contaminants (29 CFR 1910.1000) to indicate which chemicals on the list pose a hazard to workers’ skin. Employers must provide appropriate protection measures to prevent or minimize skin exposure to these substances.

Management Issues

The key to preventing occupational skin problems is to eliminate or minimize contact with potential irritants or sensitizers. Methods of doing this include:

  • Engineering controls. These include ventilation systems, ventilated hoods, suction apparatus, fans, and splash guards.

  • Administrative controls. These include pre-employment screenings that include checks for eczema, psoriasis, and other conditions to help determine job placement; substituting less toxic materials when feasible; and safety and health training focusing on skin diseases and preventive measures.

  • Personal protective equipment. Aprons, gloves, boots, and other clothing can help shield the skin from mechanical, physical, biological, plant, and chemical agents.

Training Issues

To fulfill your duty to inform workers about the hazards of skin diseases and protective measures, your training should include:

  • New-hire orientation providing information about any skin hazards associated with the job, and training in the use of PPE, as needed,

  • Safety and health walk-throughs with discussions on skin disease and the kinds of hygiene lapses that can lead to it, and

  • Regular safety training that periodically reviews these points.

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In addition to the skin protection overview excerpted above, Safety Audit Checklists provides a comprehensive, 33-point checklist on the topic, a related PPE checklist, and a 10-question quiz to make sure the message got across.

All told, this best-selling program provides you with more than 300 separate safety checklists, keyed to three different criteria:

OSHA compliance checklists, built right off the government standards in such key areas as hazCom, lockout/tagout, electrical safety, and many more. Have your managers complete these lists, and you’ll know exactly what inspectors will be looking for—and you’ll see any issues before they do.

“Plaintiff attorney” checklists, built around those non-OSHA issues that often attract lawsuits. These include workplace stress and violence, alcohol abuse, and insufficient job hazard analysis.

Safety management checklists that monitor the administrative procedures you need to have for topics such as OSHA 300 Log maintenance, training program scheduling and recordkeeping, and OSHA-required employee notifications.

All lists are reproducible — make as many copies as needed for all your supervisors and managers, and distribute. What’s more, the entire program is updated annually. And the cost averages only about $1 a checklist.

If this method of ensuring a safer, more OSHA-compliant workplace interests you, we’ll be happy to make Safety Audit Checklists available for a no-cost, no-obligation, 30-day evaluation in your office. Just let us know, and we’ll be pleased to arrange it.