Back to Basics is a weekly feature that highlights important but possibly overlooked information that any EHS professional should know. This week, we examine OSHA’s requirements for personal protective equipment.
When engineering controls, administrative controls, and work practices aren’t enough to protect your employees from exposures to a safety or health hazard, you have to provide them with personal protective equipment (PPE). It’s last in the industrial hygiene hierarchy of controls, but PPE is designed to protect workers’ eyes, face, feet, hands, and heads. Protective clothing can protect them from chemical, electrical, or thermal hazards.
The Occupational Safety and Health Administration (OSHA) vigorously enforces its construction, general industry, longshoring, and maritime PPE standards.
In fact, the agency’s construction agency’s eye and face protection standard (29 Code of Federal Regulations (CFR) §1926.102) is one of its top 10 most-cited standards. In fiscal year 2023, OSHA cited 2,074 violations, making §1926.102 the agency’s ninth most-cited standard.
The agency also has eye and face protection standards for general industry (§1910.133), shipyard (§1915.153), and longshoring (§1918.101) employment.
Preventing work-related eye injuries
According to OSHA, thousands of workers are blinded every year from work-related eye injuries. But, when properly used, eye and face protection can prevent these types of injuries.
Accidents that can result in eye injuries include getting scraped or struck by an object. Most eye injuries occur because small objects or particles like cement chips, dust, metal slivers, or wood chips scrape or strike the eye. Particles or small objects can fall from above, can be ejected by tools, or may be windblown.
A worker who runs into an object can sustain blunt-force trauma to the eyeball or eye socket. Large objects may strike the eye or face, and nails, staples, or slivers of metal or wood can penetrate the eyeball, resulting in permanent vision loss.
Chemical or thermal burns can also injure the eyes, and cleaning products and industrial chemicals are common causes of chemical burns to the eyes.
Workplace substances that pose eye and face hazards include acid or caustic liquids, chemical gases, or vapors. Those often involve cleaning products used in healthcare facilities.
For example, a National Institute for Occupational Safety and Health (NIOSH) investigation at a multispecialty hospital found that employees who were exposed to a new cleaning product reported symptoms that included burning eyes, nose, and throat; cough; dizziness; worsening asthma; headache; nausea; nose bleeds; runny nose; and burns and rashes.
Investigators narrowed their focus to a sporicidal product containing hydrogen peroxide, peracetic acid, and acetic acid. All three substances were found in full-shift air sampling. Researchers also found that splashes and spills of the cleaning product resulted in eye or skin irritation.
In this instance, NIOSH investigators recommended that employees wear goggles or a face shield, as well as extended-cuff nitrile or rubber gloves, when using the cleaning supplies.
Thermal burns may injure welders’ eyes and can also injure the surrounding tissue. OSHA’s welding, cutting, and brazing standard contains its own eye protection requirements (§1910.252(b)(2)). Required PPE includes goggles, helmets, and shields, and the standard requires a specific level of shading for lenses.
For occupations or tasks involving exposure to lasers, you must provide employees with suitable laser safety goggles designed to protect them from the specific wavelength of the laser and that have an optical density (O.D.) that’s adequate for the energy involved. §1926.102(c)(2)(i) contains a table for selecting the appropriate laser safety glasses. These glasses must be marked with the laser wavelengths they’re intended for, the O.D. for those wavelengths, and visible light transmission.
Industry consensus standards
The eye and face protection devices you provide your employees must meet the specification of one of the industry consensus standards for safety gear: American National Standards Institute (ANSI)/International Safety Equipment Association (ISEA) Z87.1-2010, Occupational and Educational Personal Eye and Face Protection Devices; ANSI Z87.1-2003, Occupational and Educational Personal Eye and Face Protection Devices; or ANSI Z87.1-1989 (R-1998), Practice for Occupational and Educational Eye and Face Protection.
Eye protection must be maintained in good working condition, and you must clean and disinfect an eye protection device before issuing it for another employee’s use. If an employee wears prescription eyeglasses, you must provide the worker with eye protection that can be worn over glasses. However, your employees may wear prescription safety glasses instead if the glasses provide an equivalent level of eye protection.
Any side protection must be attached to or integrated into the eye protection gear, as well. Examples of side protection include clip-on or slide-on side shields.
Eye and face protection gear must provide adequate protection from the hazards it was designed for, and it must be clearly marked with the manufacturer’s identity. Gear must fit snugly but must also be reasonably comfortable and not interfere with the wearer’s movements or ability to perform work tasks. Gear also must be durable, easily cleanable, and capable of being disinfected.
Eyewashes offer another critical form of protection from eye injury and are required under OSHA’s first-aid standard (§1910.151).
You can find guidance for workplace eyewashes and emergency showers in the ANSI/ISEA Z358.1, Emergency Eyewash and Shower Equipment consensus standard, which covers location and flow specifications.
OSHA’s PPE enforcement procedures
OSHA’s PPE enforcement guidance (CPL 02-01-050) outlines its interpretations of its general industry PPE standards (29 Code of Federal Regulations (CFR) Part 1910, Subpart I) and procedures for enforcing them. The enforcement guidance clarifies which PPE must be provided for employees at no cost, which PPE or replacement equipment employers must pay for, and PPE that employers aren’t required to pay for.
There are a few exceptions to OSHA’s requirement that employers pay for PPE: back belts, everyday clothing, non-specialty footwear worn off the jobsite, ordinary cold weather or rain gear, and everyday prescription eyewear.
OSHA requires you to pay for PPE that’s specified in its standards. During an inspection, agency compliance safety and health officers (CSHOs) will determine the employee-employer relationships at a facility or worksite to establish who must pay for workers’ PPE.
OSHA’s PPE inspection procedures include assessing workplace hazards and whether appropriate equipment has been selected, employer payment for PPE, training, and prevention of the use of damaged or defective PPE.
You must assess hazards that are present or likely to be present in the workplace. OSHA’s requirements for written assessment include verifying the assessment of hazards, identifying the person performing the assessment, and the assessment date. In addition to selecting appropriate PPE, you must communicate your selection decisions to your employees.
During an inspection, agency CSHOs will determine whether you’ve assessed all workplace hazards and selected the appropriate PPE.
PPE training requirements include the following:
- When PPE is necessary and what PPE is appropriate for the job or task;
- How to don, doff, adjust, and wear PPE;
- The limitations of the PPE used; and
- The proper care, maintenance, useful life, and disposal of PPE.
You also need to ensure your employees understand their training and must retrain them if necessary. Retraining is also required whenever there are changes in workplace conditions or the types of PPE used. During an inspection, an agency CSHO will interview employees and supervisors to assess the effectiveness of the training you provide.
Head protection
Head protection includes hard hats or helmets to protect your employees from falling objects and helmets designed to reduce electrical shock.
Last year, OSHA changed its internal policies, replacing traditional hard hats with modern safety helmets to better protect workers when they’re at inspection sites.
While traditional hard hats protect the top of a worker’s head, they offer minimal side impact protection. Hard hats also lack chin straps and can fall off a worker’s head if they slip or trip.
While hard hats are made of hard plastics, safety helmets incorporate a combination of materials, including lightweight composites, fiberglass, and advanced thermoplastics.
During an OSHA inspection, agency CSHOs will look for protective helmets that resist object penetration, absorb the shock of a blow, are water-resistant, and have slow-burning properties. They also will check that you’re following the manufacturers’ instructions for proper adjustment and replacement of the helmet suspension and headband.
In a Safety and Health Information Bulletin (SHIB), OSHA recommended that employers consider providing safety helmets, especially in construction, electrical work, oil and gas extraction and servicing, high-temperature environments, and working from heights.
Foot, hand protection
Your employees must have and use protective footwear whenever there’s the risk of foot injuries from falling or rolling objects or objects piercing the sole.
Protective footwear must meet the specifications of one of the industry consensus standards: ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F-2413-2005,” Standard Specification for Performance Requirements for Protective Footwear”; ANSI Z41-1999, “American National Standard for Personal Protection—Protective Footwear”; or ANSI Z41-1991, “American National Standard for Personal Protection—Protective Footwear.”
During an OSHA inspection, a CSHO will first confirm that you’ve completed an assessment of foot injury hazards. If foot injury hazards are present at your facility or worksite, the CSHO will confirm that workers have footwear that meet the requirements of one of the above industry consensus standards.
The CSHO may also check for the following:
- Metatarsal guards to protect the top of the foot;
- Toe guards;
- Combination foot and shin guards;
- Safety shoes or boots that protect against impact, compression, and puncture hazards or that have heat-resistant soles that protect against hot work surfaces;
- Electrically conductive shoes to protect against the buildup of static electricity;
- Electrical hazard safety-toe shoes or boots; or
- Foundry shoes to insulate the feet from the extreme heat of molten metal.
Hazards requiring hand protection include skin absorption of harmful substances; chemical burns; harmful temperature extremes; punctures; severe abrasions, cuts, or lacerations; sharp objects; and thermal burns.
You must provide employees with the hand protection appropriate for the working conditions and hazards identified in your facility. An agency CSHO will check during an inspection that all affected workers have appropriate hand protection whenever hazards can’t be eliminated through engineering, work practice, or administrative controls.
Electrical protective equipment
Electrical protective equipment includes rubber insulating blankets, rubber insulating covers, rubber insulating gloves, rubber insulating line hoses, rubber insulating matting, and rubber insulating sleeves.
During an OSHA inspection, the CSHO will check whether insulating equipment has been inspected for damage before each day’s use and immediately following an incident that could cause damage; whether protective equipment is maintained in a safe, reliable condition; and that electrical protective equipment has been periodically tested.
Knowing that one of OSHA’s PPE standards is one of its top 10 most cited, it’s worth checking your compliance.