Personal Protective Equipment: Employer Responsibilities

Employers must provide a safe work environment for their employees, according to the Occupational Safety and Health Administration (OSHA) and Virginia Executive Order 52 (99) Workplace Safety and Health; good business practices, and employee families place similar demands on employers. To do this, the agency must determine what hazards are associated with its operation and what is needed to protect employees from being injured by these hazards or eliminate the hazard altogether.

How is this done? First, the agency should perform a “hazard assessment” of the workplace to identify physical and health hazards. A walk-through survey of the facility and analysis of the agency’s operations can help determine potential sources of injury or exposures. Physical hazards may include impact, penetration, compression (roll-over), and temperature extremes. Health hazards include exposure to high noise, chemicals, harmful dusts, biological, and radioactivity. In many cases, a combination of both types of hazards will be present. After the assessment, the findings should be organized and analyzed to determine the best way to eliminate or control the identified hazards.

Potential Sources of Injuries:

• Electrical hazards
• Motion (such as machines or processes where movement could result in an impact between employee and equipment)
• High temperatures that could result in burns, eye injuries, or fire
• Chemical hazards
• Harmful dusts
• Light radiation – including, but not limited to welding, brazing, cutting, high intensity lights, furnaces
• Falling or dropped objects
• Sharp objects – that could poke, stab, or puncture
• Biologic hazards – such as blood or other possibly infectious materials

Consider engineering and work-practice controls when analyzing the collected information. Changes in these areas will have a more lasting effect than any requiring specific actions by employees, such as using and wearing protective equipment. Engineering controls physically change the machine or work environment to prevent exposure to hazards. Work-practice controls change the way the job is done.

Engineering Controls

• Initial design specifications
• Ventilation
• Substitution of less harmful material
• Enclosure of process
• Isolation of process
• Change the process

Work-practice Controls

• Job rotation of workers
• Wet methods
• Personal hygiene
• Housekeeping and maintenance¹

However, if these controls are not feasible or do not provide sufficient protection, the next step is to determine if and/or what PPE may be required.

In 1994, OSHA established 29 CFR 1910.132-138, the “Personal Protective Equipment” standards. Basically, the “General Requirements” (1910.132) standard requires that employers establish and administer an effective personal protective equipment program for employees. The standard outlines the responsibilities of the employer regarding PPE selection, training, enforcement, and periodic program review. Additional standards outline the requirements for specific PPE and should be used as references when determining what type of PPE will be necessary and the level of protection needed.

OSHA Standards related to PPE

• 29 CFR 1910.132, “General Requirements”
• 29 CFR 1910.133, “Eye and Face Protection”
• 29 CFR 1910.134, “Respiratory Protection”
• 29 CFR 1910.135, “Head Protection”
• 29 CFR 1910.136, “Occupational Foot Protection”
• 29 CFR 1910.137, “Electrical Protective Equipment”
• 29 CFR 1910.138, “Hand Protection”
• 29 CFR 1910.95, “Occupational Noise Exposure”

Research the types of PPE available for the identified exposure and determine which will offer a protection level greater than the minimum required. It is also important to recognize that there may be multiple hazards present and the full scope of protection offered by the PPE should be established. If multiple types of PPE must be used, then possible interference on the overall protection level should be considered in the selection process.

Don’t forget the user! Have potential users try various sizes and models that fit the necessary criteria, and have them provide feedback on comfort and ease of use. This is an important part of selecting PPE, because if it fits and is comfortable, it is more likely to be worn. If it does not fit or fits poorly, it will not provide the necessary protection. Be sure to select the best PPE for the hazard and the user.

Common Types of PPE

• Safety glasses
• Hard hats
• Goggles
• Earplugs and muffs
• Respirators
• Safety shoes
• Gloves
• Lab coats

Once selected, the PPE may be purchased and supplied by the employer, sometimes at no cost to the employee. This is the best way to assure that employees are using appropriate equipment. However, if employees want to use their own PPE, it is the employer’s responsibility to make sure the equipment meets the required criteria.

Once PPE is selected, employees must be trained on the equipment they will be required to use. Training must include when and what PPE is necessary; as well as how to properly put it on, take it off, adjust it, use and wear it. It is also important that the employees using PPE are familiar with the manufacturer’s labels, instructions, and warnings with the goal of knowing the capabilities and limitations of the equipment. They must receive this training and demonstrate the necessary skills and understanding of the PPE before they are allowed to perform the task requiring its use.

Like any other tool or piece of equipment, PPE must be properly maintained. In addition to proper usage, training needs to include how to clean, maintain, and store PPE. It is also critical that employees learn how to inspect the PPE and know when to replace it, and understand how to dispose spent components properly.

Periodic retraining should be performed on a regular basis, especially if previously trained employees are not demonstrating the proper use and care of the PPE. Additional training may also become necessary if there are changes in the facility operation or the type of PPE being used. Document any initial training and retraining, including the trainee’s name, the date of the training, and clear identification of the subject matter. Additionally, documentation should include the hazard assessment results and PPE selection process.

Generally, no program is effective without the most important component – enforcement. It is the agency’s responsibility to assure that employees are properly using all PPE designated for the work being performed. Managers and supervisors should be aware of all applicable PPE requirements and be accountable for exposed employees following the appropriate guidelines.

As with any program, periodic review is necessary to better ensure that the PPE program is providing employees with adequate, up-to-date protection. The program should be evaluated on a regular basis, not only to take into account any changes in processes and procedures, but also to assess overall compliance and effectiveness. Changes in technology may affect what PPE is required or if it is necessary at all. For example, a hazard may have been eliminated or controlled by a newly developed engineering or work-practice control, thus eliminating the need for PPE. In today’s world, these changes can develop quickly, so it is to the employer’s advantage to keep as technologically current as possible.

Each agency has it own unique hazards that vary in the degree of injury that could occur. Engineering and work-practice controls are the most effective way to protect employees from harm and are often attainable. If not, PPE may be the best option. By properly identifying hazards, selecting the right PPE, training employees in care and use, plus enforcing compliance, agencies can assure that employees will end each work day unharmed.

¹ U.S. Department of Labor, Occupational Safety and Health Administration. “Assessing the Need for Personal Protective Equipment.”- Viewed September 28, 2004, at http://www.osha.gov.

References

U.S. Department of Labor, Occupational Safety and Health Administration. “Assessing the Need for Personal Protective Equipment.”- Viewed September 28, 2004, at http://www.osha.gov.

U.S. Department of Labor, Occupational Safety and Health Administration. “Personal Protective Equipment.” Viewed September 28, 2004, at http://www.osha.gov/SLTC/personalprotectiveequipment/index.html.

U.S. Department of Labor, Occupational Safety and Health Administration. “Respiratory Protection.” Viewed September 28, 2004, at http://www.osha.gov/SLTC/respiratoryprotection/index.html.