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This material is for training purposes only. Its purpose is to inform employers and employees of best practices in occupational safety and health and general OSHA compliance requirements. This material is not a substitute for any provision of the Occupational Safety and Health Act or any standards issued by OSHA.
MODULE 1: 1910.132 GENERAL REQUIREMENTS
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What is required?
An employer has an obligation to provide protective equipment PPE, including personal protective equipment for eyes, face, head, and extremities, and protective clothing and barriers. The employer must also make sure employees use and maintain PPE in a sanitary and reliable condition.
What is proper use?
Personal Protective Equipment must be worn and used in a manner which will make full use of its protective qualities.
Take a look at the photo to the left. If you came upon an employee using PPE improperly in your workplace, what would you recommend? What recommendation would you make to this employee?
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Low rates of compliance in wearing PPE usually indicate the safety management system is failing in some way. Any one of the following root causes may result in general non-compliance:
- the employer does not provide quality PPE
- the employer does not properly supervise the use of PPE
- the employer fails to enforce the use of PPE, or
- the employer does not properly train employees on the use of PPE
Who pays for PPE?
The employer is obligated to provide and to pay for personal protective equipment required by the company for the worker to
do his or her job safely and in compliance with OSHA standards. Where equipment is very personal in nature, such as safety
shoes, and is usable by workers off the job, the matter of payment may be left to labor-management negotiations. However,
items such as safety shoes which are subject to contamination by carcinogens or other toxic or hazardous substances, and
which cannot be safely worn off-site, must be paid for by the employer.
What are the different categories of PPE?
PPE includes:
- Face and eye protection
- Head protection
- Foot protection
- Hand protection
- Protective clothing
- Protective ointments
- Shields
- Barriers
- Restraints
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When and where is PPE required?
PPE is required wherever the following conditions are encountered that are capable of causing injury or impairment by being absorbed, inhaled, or physically contacted:
- hazards of processes
- environment hazards,
- chemical hazards,
- radiological hazards, or
- mechanical irritants
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What about employee-owned equipment?
The intent of the PPE standard assigns responsibility to the employer to pay for and provide PPE to the employee when it's required by the employer. Although employers may arrange for employees to provide their own protective equipment, it's important to understand that in such circumstances the employer remains responsible and accountable to assure its adequacy, including proper maintenance, and sanitation of such equipment.
PPE Design
All personal protective equipment must be of safe design and construction for the work to be performed.
What should not be worn?
The PPE rules require that rings, wristwatches, earrings, bracelets, and other jewelry must not be worn if it's possible for it to come into contact with power driven machinery or electric circuitry.
Why this rule? Read how this rule might have prevented some serious injuries.
De-gloving of a finger caused by a ring. From Bob F.
The accident occurred when the individual was jumping off the
side of an Army tow truck. He placed his hand on the railing
of the bed and jumped off. The ring caught on the side of
truck bed. Upon reaching the ground, the ring had removed all
the skin from the finger, leaving the muscles, bone and
fingernail exposed.
The individual was rushed to an emergency room where the finger
was inserted into the wall of the stomach area. A pedicle graft
was performed using the skin from the stomach area. After more
than eight operations and over a 100 plus days in the hospital
the finger is semi-useable.
Nothing but air? NOT! From Joan R.
I took care of a man who got his ring caught on a basketball hoop as he made a dunk and pulled his whole finger off---skin, bone, and all at the knuckle. Not a pretty site.
What about back belts?
It's important that you understand that back belts should not be considered personal protective equipment in that they physically "protect" you from back injuries.
Devices such as back belts are not recognized by OSHA as control measures to prevent back injury. While they may be accepted by individual workers because they feel as if they provide additional support, if used improperly, they may restrict the body's range of motion and possibly aggravate other ergonomic stressors in the job. Research indicates that the primary value in back belts, when used properly, is that they "remind" the employee to use proper lifting techniques. As a result, fewer back injuries occur. Thus, OSHA does not forbid the use of back belts and similar devices, nor does it endorse their use.
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Work Clothing
Clothing must be worn which is appropriate to the work performed and conditions encountered.
Loose sleeves, ties, lapels, cuffs, or other loose clothing must not be worn near moving machinery.
Make sure that you immediately remove clothing that becomes saturated or impregnated with flammable liquids, corrosive or toxic substances, irritants, or oxidizing agents. Don't wear it again until it's properly cleaned. |
Defective and Damaged Equipment
Of course, defective or damaged personal protective equipment must not be used. It's important to inspect PPE regularly, and before each use to make sure it's capable of adequately protecting an employee from exposure to hazards. Remember, PPE that is defective...is not PPE.
Hazard Assessment
A hazard assessment the most important strategy for surveying the workplace. It is an important element of a PPE program because it produces the information needed to select the appropriate PPE for any hazards present or likely to be present at particular workplaces. Your employer is then capable of determining and evaluating the hazards of a particular workplace. Paragraph d. (see below) of the PPE standard details hazard assessment requirements. It is a performance-oriented provision that simply requires management to use their awareness of workplace hazards to enable them to select the appropriate PPE for the work being performed. Paragraph (d) clearly indicates that management is accountable both for the quality of the hazard assessment and for the adequacy for the PPE selected.
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1910.132 General Requirements
(d) Hazard assessment and equipment selection
(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
(ii) Communicate selection decision to each affected employee; and,
(iii) Select PPE that properly fits each affected employee.
Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.
(2) 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.
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Six-Step PPE Hazard Assessment Process
Sample PPE Hazard Assessment Form
If the person conducting the hazard assessment discovers that hazards requiring PPE are present, or likely to be present, then management must:
- select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazard identified in the hazard assessment;
- communicate selection decisions to each affected employee; and,
- select PPE that properly fits each affected employee.
PPE Selection - One does not fit all
All PPE clothing and equipment should be of safe design and construction, and should be maintained in a clean and reliable fashion. Employers should take the fit 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 of PPE. 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.
OSHA requires that many categories of PPE meet or be equivalent to standards developed by the American National Standards Institute (ANSI). ANSI has been preparing safety standards since the 1920s, when the first safety standard was approved to protect the heads and eyes of industrial workers. Employers who need to provide PPE in the categories listed below must make certain that any new equipment procured meets the cited ANSI standard. Existing PPE stocks must meet the ANSI standard in effect at the time of its manufacture or provide protection equivalent to PPE manufactured to the ANSI criteria. Employers should inform employees who provide their own PPE of the employer's selection decisions and ensure that any employee-owned PPE used in the workplace conforms to the employer's criteria, based on the hazard assessment, OSHA requirements and ANSI standards. OSHA requires PPE to meet the following ANSI standards:
- Eye and Face Protection: ANSI Z87.1-1989
- Head Protection: ANSI Z89.1-1986
- Foot Protection: ANSI Z41.1-1991
Your employer must 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.
Controlling Hazards
PPE devices alone should not be relied on to provide protection against hazards, but should be
used in conjunction with engineering controls and other management controls.
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Engineering Controls
Workplace hazards may be corrected using engineering controls which may be thought of as replacing or redesigning machinery, equipment, and tools, and/or substituting materials. Engineering controls are the "first line of defense" against injury/illness, because they have the potential to completely eliminate a hazard, and do not rely on human behavior to be effective. For instance, rather than require employees to wear respiratory protection which must be monitored, inspected, trained, managed, it's much more effective to install a ventilation system that does not require any of those management activities. |
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Administrative or Management Controls
Management controls can be accomplished with the stroke of the pen. It involves changing or redesigning work procedures, rescheduling breaks, changing the number of workers doing a job, and using personal protective equipment to reduce the frequency and duration exposure to the hazards of tasks. Using management controls alone is not as effective as engineering controls because, in most cases, they only reduce exposure - they don't eliminate the hazard. And even more importantly, management controls do rely on human behavior (which introduces many variables in the long run) which must be managed. |
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