Few words are more unfortunate than: “If only he had worn a hardhat.” Or eye protection, steel-toed boots, earplugs. You get the idea.
Personal protective equipment is the most basic of safety requirements, and yet it is the one this magazine sees most frequently ignored. Photographers we send to work sites for our contractor profile articles have instructions to make sure the workers in their pictures are properly outfitted with PPE. In a shocking percentage of cases, they are not.
The employees don’t seem concerned, and often it seems even the supervisors and owners can’t be bothered with such details. The way to learn the importance of PPE is not by having an employee seriously and permanently injured by not wearing it. And so, here is a review of the basics of PPE, based on information provided by OSHA.
What employers must do
OSHA insists that it takes a cooperative effort between employers and employees to establish and maintain a safe and healthful work environment – one that includes PPE. In general, employers are responsible for:
• Performing a hazard assessment of workplaces to identify and control physical and health hazards
• Identifying and providing appropriate PPE for employees
• Training employees in the use and care of the PPE
• Maintaining PPE, including replacing worn or damaged items
• Periodically reviewing, updating and evaluating the effectiveness of the PPE program.
In general, employees should wear PPE properly, attend training sessions on PPE, care for, clean and maintain the equipment, and let a supervisor know if PPE needs repair or replacement. Specific requirements for PPE appear in many OSHA standards, published in 29 CFR. Some standards require that employers provide PPE at no cost to employees, while others simply state that the employer must provide PPE.
The hazard assessment
The first critical step in developing a comprehensive safety and health program is to identify physical and health hazards in the workplace that require PPE. OSHA calls that process a hazard assessment. Hazards may be physical or health-related, and a comprehensive hazard assessment should identify hazards in both categories.
Physical hazards include moving objects, fluctuating temperatures, high-intensity lighting, rolling or pinching objects, electrical connections and sharp edges. Health hazards include overexposure to harmful dusts, chemicals or radiation. The hazard assessment should begin with a walk-through survey of work sites to develop a list of potential hazards in several basic categories:
• Impact
• Penetration
• Compression (roll-over)
• Chemical
• Heat/cold
• Harmful dust
• Intense light
• Biological.
In addition to noting the basic layouts of the work sites and reviewing any history of occupational illnesses or injuries, things to look for during the walk-through include:
• Sources of electricity
• Sources of motion, such as machines or processes where movement may exist that could result in an impact between personnel and equipment
• Sources of high temperatures that could result in burns, eye injuries or fire
• Types of chemicals used in the workplace
• Sources of harmful dusts
• Sources of light radiation, such as welding and cutting
• The potential for falling or dropping objects
• Sharp objects that could poke, cut, stab or puncture
• Biologic hazards such as blood or other potentially infected material.
When the walk-through is complete, the employer should organize and analyze the data so that it may be efficiently used in determining the types of PPE the workplace requires. The employer should know about the different types of PPE available and the levels of protection each one offers.
It is definitely a good idea to select PPE that will provide a level of protection greater than the minimum required to protect employees from hazards. The workplace should be periodically reassessed for any changes in conditions, equipment or operating procedures that could affect occupational hazards.
Taking action
This periodic reassessment should also include a review of injury and illness records to spot any trends or areas of concern and taking appropriate corrective action. The suitability of existing PPE, including an evaluation of its condition and age, should be included in the reassessment. Documentation of the hazard assessment is required through a written certification that includes:
• Identification of the workplace evaluated
• Name of the person conducting the assessment
• Date of the assessment
• Identification of the document certifying completion of the hazard assessment.
Have you completed a hazard assessment of your work sites? As a result, do you know definitively what PPE your employees need? And do you and your supervisors enforce those requirements rigorously?
If not, there is no time like the present to take corrective action. That’s far better than at some future date having to say those tragic words: “If only ...”
