Personal Protective Equipment, Personnel Safety

How Are Your PPE Programs?

When you hear “personal protective equipment” (PPE), do you automatically think “respirators”?

Respiratory protection has dominated everyone’s attention over the past 2 years during the COVID-19 pandemic.

Maybe you even found yourself locked in competition with consumers and other employers for existing supplies of N95s in early 2020. Spikes in demand for respirators during the pandemic led to supply shortages across industries.

Federal officials temporarily allowed the use of foreign-made respirators that were not tested and approved by the National Institute for Occupational Safety and Health (NIOSH). They even allowed extended use and decontamination and reuse of disposable respirators.

However, there are many other types of PPE. The Occupational Safety and Health Administration’s (OSHA) PPE regulations also include electrical protective equipment, eye and face protection, fall protection systems, foot protection, hand protection, hearing protection, and head protection.

As an employer, you typically have to pay for a wide variety of your employees’ PPE, including:

  • Firefighting PPE for emergency response crews (boots and full gear, gloves, helmets, and proximity suits);
  • Goggles and face shields;
  • Hard hats;
  • Hearing protection;
  • Metatarsal foot protection;
  • Nonprescription eye protection and prescription eyewear inserts/lenses for full-face respirators;
  • Rubber boots with steel toes; and
  • Welding PPE.

However, you do not have to pay for lifting belts, as OSHA considers them to have questionable value. You also don’t have to pay for ordinary clothing like long-sleeve shirts, long pants, street shoes, and normal work boots; winter coats and gloves; nonspecialty safety-toe protective footwear that employees wear off the jobsite (including steel-toe shoes or boots); and nonspecialty prescription safety eyewear that employees are permitted to wear off the jobsite.

According to OSHA, you also do not have to pay for hair nets and gloves worn in food service for consumer protection.

PPE follows other controls, begins with assessments

You need to perform hazard assessments to identify your employees’ PPE needs. However, you also need to understand that PPE is the last element in the industrial hygiene “hierarchy of controls” for workplace health and safety hazards. PPE comes after hazard elimination, substitution, engineering controls, and administrative controls.

Following a hazard assessment and the use of other controls, you need to:

  • Identify and provide appropriate PPE for your employees.
  • Train employees in the use and care of the PPE.
  • Ensure your employees properly wear and use their PPE.
  • Maintain PPE, and replace worn or damaged gear.
  • Periodically review and update your PPE program, evaluating its effectiveness.

In addition to training employees in the care and use of PPE, you also must communicate its limitations.

You may need to provide additional training or retraining when there are changes in the workplace or in the type of required PPE that would make prior training obsolete. You also may need to retrain employees if you believe any of your previously trained employees do not demonstrate the proper understanding and skill level in the use of PPE.

Moreover, you must document the training you provide all your employees required to wear or use PPE, preparing certification containing the name of each employee trained, the date of training, and clear identification of the subject of the certification.

Additionally, you should familiarize yourself with standard PPE practices in your industry. For example, the Occupational Safety and Health Review Commission vacated an OSHA citation because of accepted industry practice.

The agency had cited a security contractor for not ensuring a guard was wearing a bulletproof vest at the time of a robbery attempt. However, OSHA’s citation was undercut by the Department of Labor’s (DOL) own expert, who testified that he knew of no security agencies that mandated the use of bulletproof vests for armed guards and that there were no consensus standards in the security industry requiring the use of such vests.

The commissioners concluded that the employer had provided its employees with bulletproof vests out of an abundance of caution—an extra level of “safety”—not because the employer recognized them as necessary.

Eye and face protection

You need to select eye and face protection and ensure your employees use it to prevent occupational eye injuries. According to OSHA, thousands of workers are blinded each year from work-related eye injuries.

OSHA has eye and face protection for four industry groups: general industry (29 Code of Federal Regulations (CFR) §1910.133), shipyard (§1915.153), longshoring (§1918.101), and construction (§1926.102). The agency’s construction industry standard is its eighth most frequently cited standard. OSHA cited 1,452 violations in fiscal year 2021 (October 2020–September 2021).

The most common occupational eye injuries are caused by small objects or particles such as cement chips, dust, metal slivers, and wood chips scraping or striking the eye. Objects may fall from above a worker, be ejected by tools, or be windblown. Sometimes larger objects may strike the eye or face, or a worker may run into an object, causing blunt-force trauma to the eyeball or eye socket.

On a construction worksite, nails, staples, or slivers of metal or wood may penetrate the eyeball, leading to a permanent loss of vision. Welders are at risk for thermal burns to the eye, damaging workers’ eyes and the surrounding tissue.

Acids or caustic liquids, chemical gases or vapors, flying particles, liquid chemicals, molten metal, and light radiation (such as lasers, torches, and welding) also pose eye and face hazards. Cleaning products and industrial chemicals are common causes of chemical burns to one or both eyes.

Eye protection includes face shields or welding shields, goggles and laser safety goggles, and safety glasses.

The industry consensus standard for eye and face protection is “Occupational and Educational Personal Eye and Face Protection Devices” (American National Standards Institute (ANSI) Z87.1). ANSI Z87.1-2020 is the current standard for safety glasses.

Head protection

Hard hats made of aluminum, fiberglass, or plastic can protect your workers from falling tools or materials. A hard hat has a suspension system inside made of nylon, plastic, or a combination that absorbs the energy of a striking object.

The consensus standard for head protection is ANSI Z89.1, “Industrial Head Protection.”

There are three classes of hard hats:

  • General hard hats that provide impact and penetration resistance, along with limited voltage protection (up to 2,200 volts);
  • Electrical hard hats that provide protection from impact and penetration hazards from flying/falling objects but also the highest level of protection against electrical hazards, with high-voltage shock and burn protection (up to 20,000 volts); and
  • Conductive hard hats that provide lightweight comfort and impact protection but offer no protection from electrical hazards.

You need to check that your employees are wearing the appropriate hard hats for identified hazards. Each hard hat should have a label inside the shell listing the manufacturer, ANSI designation, and class of the hat.

There also are “bump hats” on the market, which are designed for work in areas with low head clearance. However, these “bump hats” are not designed for protection from falling objects and are not ANSI-approved.

Hand protection

Exposures to harmful substances also pose risks to workers’ hands, such as chemical burns, severe abrasions, cuts or lacerations, and skin absorption, as well as thermal burns and harmful temperature extremes, necessitating the use of hand protection.

Because of the variety of workplace hazards, there are many types of gloves, including:

  • Gloves made of canvas, leather, or metal mesh;
  • Fabric and coated fabric gloves;
  • Chemical- and liquid-resistant gloves; and
  • Insulating rubber gloves.

Chemical- and liquid-resistant gloves include butyl, natural latex rubber, neoprene, and nitrile gloves. The selection of the appropriate glove will depend on the chemical present.

Foot protection

Work situations in which your employees may need protective footwear include:

  • When heavy objects such as barrels and other materials and tools might fall or roll onto an employee’s foot;
  • Work with sharp objects like nails and spikes that could pierce the soles and uppers of ordinary footwear;
  • Exposure to molten metal that could splash onto a worker’s feet or legs;
  • Work on or around hot, wet, or slippery surfaces; and
  • A work environment in which electrical hazards are present.

Safety shoes have impact-resistant toes and heat-resistant soles, protecting workers from hot work surfaces common to hot metal industries, paving, and roofing. Some shoes also have metal insoles to protect against puncture wounds.

Other shoes are designed to be electrically conductive to prevent the buildup of static electricity in areas with explosive atmospheres or nonconductive to protect employees from electrical hazards.

Nonconductive shoes should never be worn in hazardous, explosive atmospheres, and conductive shoes should never be worn where employees could be exposed to electrical hazards.

Foot powder should not be used with conductive shoes, as the powder provides insulation, reducing the conductive capabilities of the shoes. Nylon, silk, and wool socks can produce static electricity and should not be worn in explosive atmospheres.

Foundry shoes keep hot metal from lodging in shoe eyelets, tongues, or other shoe parts. Foundry shoes are snug-fitting leather or leather substitute shoes with leather or rubber soles and must have built-in safety toes.

Safety footwear must meet industry standards for minimum compression and impact performance. The industry consensus standard for foot protection is ASTM International’s F 2413, “Specification for Performance Requirements for Protective Footwear.” ASTM also has a standard for foot protection testing (F 2412).

The future: Heat

In its heat illness prevention rulemaking, OSHA acknowledged the potential for PPE and auxiliary body-cooling methods to reduce the risk of heat strain in those working in hazardous heat conditions. These include cooled or iced vests, jackets, or other wearable
garments. For example, reflective and breathable clothing, cooling neck wraps, and cooling vests or jackets may provide enhanced protection to some workers.

The agency asked stakeholders for information on their experience with PPE and other controls for heat stress risks.

OSHA published an advance notice of proposed rulemaking (ANPRM) in the rulemaking on October 27, 2021. The rulemaking remains in the prerule stage, and the proposed and final rule text may or may not contain PPE requirements.

However, safety equipment makers already offer cooling garments.

For example, Cincinnati, Ohio-based Vortec makes a personal “air-conditioning” vest that consists of a cooling tube with a belt that pumps cold compressed air to provide air flow to the worker and a plasticized PVC vest through which the cold air flows to cool the worker’s torso.

It’s important to remember that manufacturers continue to develop new PPE, standards-setting organizations regularly update their standards for PPE, and OSHA continues to look at new PPE uses.

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