7.2: The Requirement for PPE

To ensure the greatest possible protection for employees in the workplace, the cooperative efforts of both employers and employees will help in establishing and maintaining a safe and healthful work environment.

In general, employers are responsible for:

■ Performing a “hazard assessment” of the workplace to identify and control physical and health hazards.

■ Identifying and providing appropriate and adequate PPE for employees.

■ Training employees in the use and care of the PPE.

■ Maintaining PPE, including replacing worn or damaged PPE.

■ Periodically reviewing, updating and evaluating the effectiveness of the PPE program.

In general, employees should:

■ Properly wear PPE,

■ Attend training sessions on PPE,

■ Care for, clean and maintain PPE, and

■ Inform a supervisor of the need to repair or replace PPE. Specific requirements for PPE are presented in many different

The Hazard Assessment

A first critical step in protecting employees is to use a “hazard assessment to identify physical and health hazards in the workplace. Potential hazards may be physical or health-related and a comprehensive hazard assessment should identify hazards in both categories. Examples of physical hazards include moving objects, fluctuating temperatures, high intensity lighting, rolling or pinching objects, electrical connections, and sharp edges. Examples of health hazards include overexposure to harmful dusts, chemicals or radiation.

The hazard assessment should begin with a walkthrough survey of the facility to develop a list of potential hazards in the following basic hazard categories:

■ Fall hazards,

■ Impact,

■ Penetration,

■ Compression (roll-over),

■ Chemical,

■ Heat/cold,

■ Harmful dust,

■ Light (optical) radiation, and

■ Biologic.

In addition to noting the basic layout of the facility and reviewing any history of occupational illnesses or injuries, things to look for during the walkthrough survey 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, brazing, cutting, furnaces, heat treating, high intensity lights, etc.

■ The potential for falling or dropping objects.

■ Sharp objects that could poke, cut, stab or puncture.

■ Biologic hazards such as blood or other potentially infectious material.

■ Unprotected edges where fall hazards may exist.

When the walkthrough is complete, the employer should organize and analyze the data so that it may be efficiently used in determining the proper types of PPE required at the worksite.

The employer should become aware of the different types of PPE available and the levels of protection offered. 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.

Then periodically reassess the workplace for any changes in conditions, equipment or operating procedures that could create occupational hazards. 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 the following information:

■ 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.

Selecting PPE

All PPE clothing and equipment must be of safe design and construction, and be maintained in a clean and reliable fashion. Employers should take the fitness and comfort of PPE into consideration when selecting appropriate items for their workplace.

PPE that fits well and is comfortable to wear will encourage employee use. Most protective devices are available in multiple sizes and care should be taken to select the proper size for each employee. If several different types of PPE are worn together, make sure they are compatible. If PPE does not fit properly, it can make the difference between being safely covered or dangerously exposed. It may not provide the level of protection desired and may discourage employee use.

Training Employees in the Proper Use of PPE

Employers are required to train each employee who must use PPE. Employees must be trained to know at least the following:

■ When PPE is necessary.

■ What PPE is necessary.

■ How to properly put on, take off, adjust and wear the PPE.

■ The limitations of the PPE.

■ Proper care, maintenance, useful life, and disposal of PPE.

Employers shall make sure that each employee demonstrates an understanding of the PPE training (i.e., in a language they understand) as well as the ability to properly wear and use PPE before they are allowed to perform work requiring the use of the PPE. If an employer believes that a previously trained employee is not demonstrating the proper understanding and skill level in the use of PPE, that employee should receive retraining. Other situations that require additional or retraining of employees include changes in the workplace or in the type of required PPE that make the prior training obsolete.