When assessing the hazard controls that are in place to protect workers from hazardous conditions, we look at the hierarchy of controls.
Safety and health representatives must be knowledgeable about the selection of controls and how they work. The following is the standard approach to that selection:
Personal protective equipment may not be the most effective, but it is still a major element in the safety and health system in protecting workers.
What is Personal Protective Equipment?
Personal protective equipment, commonly referred to as “PPE”, is equipment worn to minimize exposure to hazards that cause serious workplace injuries and illnesses. These injuries and illnesses may result from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards.
Personal protective equipment may include items such as gloves, safety glasses and safety shoes, earplugs or muffs, hard hats, respirators, or coveralls, vests, and full body suits.
What Can Be Done to Ensure Proper Use of Personal Protective Equipment?
All personal protective equipment should be safely designed and constructed and should be maintained in a clean and reliable fashion. It should fit comfortably, encouraging worker use. If the personal protective equipment does not fit properly, it can make the difference between being safely covered or dangerously exposed.
When elimination, substitution, engineering, and administrative controls are not feasible or do not provide sufficient protection, employers must provide personal protective equipment to their workers and ensure its proper use. Often PPE is combined with other controls to reinforce worker protection.
Training Requirements
Employers are required to train each worker required to use personal protective equipment to know the following:
- When it is necessary
- What kind is necessary
- How to properly put it on, adjust, wear, and take it off
- The limitations of the equipment
- Proper care, maintenance, useful life, and disposal of the equipment
If PPE is to be used, a PPE program should be implemented. This program should address the hazards present, the selection, maintenance, and use of PPE; the training of employees; and monitoring of the program to ensure its ongoing effectiveness.
The OSHA rules require an employer to conduct a PPE hazard assessment to determine what type of PPE is required to be used and inform the worker of that determination. The OSHA PPE Hazard Assessment is required to be certified in writing. The written certification must include the following information:
- Identification of the workplace evaluated.
- The person performing and certifying the evaluation.
- The date the evaluation was conducted.
- The document title: Certification of PPE Hazard Assessment
The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.
Payment for Personal Protective Equipment
Many Occupational Safety and Health Administration (OSHA) standards require employers to provide personal protective equipment, when it is necessary to protect employees from job-related injuries, illnesses, and fatalities. With few exceptions, OSHA requires employers to pay for personal protective equipment when it is used to comply with OSHA standards.
These typically include hard hats, gloves, goggles, specialty safety shoes, safety glasses, welding helmets and goggles, face shields, chemical protective equipment and fall protection equipment: https://www.osha.gov/sites/default/files/Handout_2_Employers_Must_Provide_and_Pay_for_PPE.pdf
And by the way, this rule does include fire resistance and fire-retardant clothing as it is noted on the required PPE hazard assessment certificate. OSHA’s Compliance Directive CPL: 02-01-050 Subject: SUBJECT: 29 CFR Part 1910, Subpart I, Enforcement Guidance for Personal Protective Equipment in General Industry clearly outlines this often-violated rule.
Excerpt from the PPE compliance directive:
“Employers are required to provide, at no cost to employees, FR clothing for applications such as, but not limited to, the handling of flammable chemicals.”
An OSHA Update: Making PPE the Right Fit for All
Personal protective equipment is designed to minimize exposure to hazards that cause serious workplace injuries and illnesses. But it cannot do its job if it does not fit properly. One of the challenges facing workers with various body types and sizes, especially women in the construction industry, is finding the right PPE that works for them.
A survey by The Center for Construction Research and Training found that 77% of 174 tradeswomen said they were exposed to unnecessary hazards because of ill-fitting PPE. Here is the link to the survey: https://www.cpwr.com/research/research-to-practice-r2p/r2p-library/resources-for-stakeholders-and-researchers/construction-personal-protective-equipment-for-the-female-workforce/
It is not hard to see why. A worker may wear protective clothing that is too long, presenting a tripping hazard and falls while working on a job site. A carpenter may put on gloves that are too big that could get caught in machinery and later cut their hand or finger. A sprinkler fitter could ignore that their safety glasses are not properly secured, leaving them unprotected from chemicals or dust.
That is why the Occupational Safety and Health Administration issued a notice of proposed rulemaking to revise the current personal protective equipment standard in construction. Unlike the general industry and maritime standards, the current industry standard does not clearly state that PPE must adequately fit each affected employee. The proposed change would require that equipment fits each affected employee properly to protect them from occupational hazards.
Access to PPE that fits has always been an important safety and health issue for women working in construction. Because women make up about 10% of the construction workforce, many protective equipment manufacturers are reluctant to invest in research and development to produce correctly sized and proportioned products for them.
For years, manufacturers and suppliers have produced and sold protective equipment designed to fit average-sized men. As a result, women either have used PPE that did not adequately protect them or stopped using PPE because the improper fit was uncomfortable.
Workers of any gender or size should not have to choose between their safety and wearing ill-fitting PPE. Making sure that safety gear properly fits every employee and that they are trained in how to use it will help employers provide safe and equitable workplaces.
The OSHA proposed rulemaking is a critical step in addressing the problem of gender and body type disparity in the availability of properly fitted personal protective equipment in the construction industry.
For more information visit OSHA.gov PPE link: https://www.osha.gov/personal-protective-equipment