Many years ago, before the PPE Final Rule, OSHA determined that there were an extensive number of injuries related to workers not wearing effective personal protective equipment. In fact, in the Preamble to the Final Rule, OSHA cited various studies indicating there were 320,000 hand and finger injuries, 70,000 eye injuries, 70,000 head and face injuries, and 110,000 foot and toe injuries in 1987. (Roughly 31 percent of the total disabling injuries for that year.) Rightly so, OSHA decided these numbers merited a Standard (CFR 1910.132) to protect workers from these hazards.
Indeed, PPE does work to safeguard workers. Experts estimate that approximately ninety percent of related injuries could be prevented or minimized by wearing the proper equipment. PPE is a vital and necessary tool in the employer’s arsenal to protect workers.
Fast forward to today. Even with PPE Standards fully in place for decades, we still have an alarming number of eye, face, foot, hand and head injuries. For example, NIOSH states, “Each day about 2,000 U.S. workers sustain a job-related eye injury that requires medical treatment. About one-third of the injuries are treated in hospital emergency departments, and more than 100 of these injuries result in one or more days away from work.”
In addition to the effects injuries have on workers, these events can be financially devastating to the organization. Excessive or serious injuries can trigger numerous employer headaches, from high-risk insurance costs to OSHA inspections and penalties. And of course, each injury incident carries indirect costs related to downtime, replacing injured workers, and various related issues.
Given the importance of PPE, let’s look at OSHA’s PPE regulations more closely in this article.
If PPE Prevents Injuries, Why Are So Many Workers Still Getting Hurt?
Often, the answer to this question is an ineffective PPE program, which fails to identify hazards and/or improperly assigns adequate personal protection.
Applying the PPE Standard to your workplace requires more than selecting and providing equipment. Instead, the OSHA PPE standard is a system of mutually supporting actions, each of which must be in place to ensure full protection of workers.
If you’re missing critical elements in your PPE program, you could have serious inadequacies and increased worker injuries.
Check out the following areas to ensure your PPE program is functioning effectively.
To create a comprehensive PPE program, employers must evaluate the workplace and job duty hazards. This is the first and most critical step. If you miss hazards or unsafe conditions, you won’t select the proper PPE and workers will be exposed without protection.
This is not optional. Hazard assessment is required by OSHA under 1910.132(d)(1), which mandates employers determine present or potentially unsafe conditions which may merit PPE. The assessment should be thorough and include a survey of physical and health hazards. And you should consider work environment, as well as specific job duties or tasks.
Examples of hazards include:
- Sharp objects which might pierce the feet or cut hands.
- Rolling or pinching objects which could crush hands or feet.
- Electrical hazards.
- Dust, particulates, flying objects, the potential for objects to strike the worker.
- Hazardous radiation (welding, brazing, cutting, furnaces, heat treating, high-intensity lights, etc.)
- Falling objects or potential for dropping objects.
- Potential sources of impact or motion, such as machinery or processes where any movement of tools, machine elements, or particles could exist.
- High temperatures that could result in burns, eye injury, or ignition of protective equipment, etc.
- Chemical exposures.
- Hazardous atmospheres.
- Exposure to blood or other potentially infectious materials. (Covered under the Bloodborne Pathogen Standard, 29 CFR 1910.1030, but employers may identify areas that apply during a hazard assessment.)
Remember, PPE does not remove the hazard itself, nor does it guarantee full protection. Therefore, in your assessment of the hazards, first see if any engineering controls or other controls may be applied. PPE is considered the last line of defense, and it should only be used when other means to protect workers cannot be used.
For more on this concept, please see our article on the Hierarchy of Controls.
Three areas to consider before you conduct an assessment:
- Past performance does not imply future success. In other words, even if workers aren’t getting injured, it doesn’t mean the hazards don’t exist. If your employees have exposure to unprotected hazards, you’re playing Russian Roulette. It’s only a matter of time before someone is injured when exposed to unsafe conditions.
- Frequently overlooked are secondary or seasonal duties workers perform which put them at risk of new or unusual hazards. For example, employers should review annual or semi-annual maintenance tasks. Likewise, look at other tasks that might be nonroutine. Are there additional hazards that may occur?
- What happens when an employee must cover for another worker? Are they provided the correct PPE and training for those duties?
For background on these areas, we’ve provided additional resources and information on PPE as well as other General Industry compliance requirements, which you’ll want to review prior to conducting your assessment.
OSHA takes your PPE hazard assessment very seriously. It must be written and certified to ensure you’ve performed an adequate evaluation. Aside from compliance with the PPE Standard, certification gives you a dedicated process to complete your assessment.
According to OSHA, the required workplace hazard assessment must:
- Be documented in writing
- Comprehensively identify all hazards or potential hazards
- State name of the person certifying the evaluation
- List the date(s) of the hazard assessment
If you’re looking for a sample format, the Washington State Department of Labor has a useful Hazard Assessment Certification form (as well as a JSA Hazard Assessment) that details the various types of hazards and contains the above items.
This is a step many employers miss. Handing out safety glasses to your workers is not training under the PPE Standard. According to the Standard, employers must:
- Train employees before providing PPE
- Maintain a record of training
- Demonstrate the proper ways to wear all types of required PPE
- Identify various types of PPE and the purpose, as well as levels of protection
- Describe the types of tasks or work environment that pertain to the PPE
For meeting this crucial aspect of the PPE compliance, Convergence Training has several solutions, including PPE Training for the General Industry.
Other, more specific PPE training can match the PPE need, such as this online respirator training course.
Another example, for workers exposed to dangerous levels of noise, is this online hearing conservation training course.
Employers should also ensure workers are taught to inspect PPE prior to wearing and to report damaged safety equipment. Every employee should be aware of how to obtain replacement PPE through training. And under no circumstance should an employee ever wear defective PPE, so employers should have an ample supply of replacement items.
Do you have workers who grumble about PPE or slack off on wearing the safety equipment? Often, this is because it’s uncomfortable or cumbersome. And if you have a sympathetic supervisor who feels the same and looks the other way, you can have an entire department (or company) that is not wearing the provided PPE, unless management is in the plant.
For your PPE program to be successful, employees must wear the required equipment. Improving the comfort and quality of your PPE can often change workers’ mindsets and reduce injuries and incidents almost immediately.
If you have workers who aren’t wearing their PPE, ask them why. And then spend some time brainstorming to solve the issue. There are so many varieties of every kind of PPE, it’s likely you’ll find another selection that is more tolerable for your workers.
For example, safety glasses may fog up in humidity or heat, which can be prevented by anti-fog wipes or anti-fog glasses. Standard ear muffs may cause headaches, while behind-the-head products can offer more comfort. If you explore the possibilities, you can probably solve most employees’ complaints and have a strong PPE program.
The PPE program should be regularly reviewed to ensure no changes or inadequacies are found.
Incident and accident reports can be evaluated to determine areas that may involve PPE failures. For example, if an employee had an eye injury while wearing safety glasses, could safety goggles have changed the outcome?
You can also use your 300 Logs to look for trending injury events which may indicate PPE needs to be improved or changed for various departments or job duties. (It is also possible that employees need to be retrained on the requirements, too.)
But remember, your PPE program should be proactive to be most effective. Don’t wait for accidents and injuries to evaluate it. Frequently review job duties and the environment to look for new potential hazards.
Feel free to download the free JHA Guide below, too.
Job Hazard Analysis Guide
Learn how to perform a job hazard analysis on the job with our free step-by-step guide.