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This material is for training purposes only to inform the reader of occupational safety and health best practices and general compliance requirements and is not a substitute for provisions of the OSH Act of 1970 or any governmental regulatory agency.


  MODULE 1: 1910.132 GENERAL REQUIREMENTS

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?

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:

  1. the employer does not provide quality PPE
  2. the employer does not properly supervise the use of PPE
  3. the employer fails to enforce the use of PPE, or
  4. the employer does not properly train employees on the use of PPE

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
  • mechanical irritants

Who pays for PPE?

Personal protective equipment (PPE), used during work must be provided by the employer at no cost to employees. However, the employer is not required to pay for non-specialty safety- toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.

When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots.

In addition, the employer is not required to pay for:
  • The logging boots required by 29 CFR 1910.266(d)(1)(v);
  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or
  • Ordinary clothing, skin creams, or other items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses, and sunscreen.
The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE. Where an employee provides adequate protective equipment he or she owns, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment. The employer can not require an employee to provide or pay for his or her own PPE, unless the PPE is one of the exceptions listed in the OSHA PPE standard 1910.132(h)(2) through (h)(5).

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 sight.

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.

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 first critical step in developing a comprehensive safety and health program is to identify physical and health hazards in the workplace. This process is known as a "hazard assessment." 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 walk-through survey of the facility to develop a list of potential hazards in the following basic hazard categories:
  • Impact
  • Penetration
  • Compression (roll-over),
  • Chemical
  • Heat/cold
  • Harmful dust
  • Light (optical) radiation
  • Biological contaminants
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 walk-through 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 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 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.

The workplace should be periodically reassessed for any changes in conditions, equipment or operating procedures that could affect 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; and
  • Identification of the document certifying completion of the hazard assessment.
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.

Below is a sample PPE Assessment Form.

More Samples of the 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 (USA Standard for Occupational and Educational Eye and Face Protection).
  • Head Protection: ANSI Z89.1-1986.
  • Foot Protection: ANSI Z41.1-1991.
For hand protection, there is no ANSI standard for gloves but OSHA recommends that selection be based upon the tasks to be performed and the performance and construction characteristics of the glove material. For protection against chemicals, glove selection must be based on the chemicals encountered, the chemical resistance and the physical properties of the glove material.

Controlling Hazards

To control hazards, a hierarchy of controls has been used as a means of determining how to implement feasible and effective controls. ANSI Z10-2005, Occupational Health and Safety Management Systems, encourages employer employ the following hierarchy of hazard control strategies:
  1. Elimination
  2. Substitution
  3. Engineering controls
  4. Administrative controls
  5. Personal protective equipment
The idea behind this hierarchy is that the control methods at the top of the list are potentially more effective and protective than those at the bottom. Following the hierarchy normally leads to the implementation of inherently safer systems, ones where the risk of illness or injury has been substantially reduced. Let's take a closer look at the hierarchy of control strategies.

Elimination and Substitution

Elimination and substitution, while most effective at reducing hazards, also tend to be the most difficult to implement in an existing process. If the process is still at the design or development stage, elimination and substitution of hazards may be inexpensive and simple to implement. For an existing process, major changes in equipment and procedures may be required to eliminate or substitute for a hazard.

These strategies are considered first because they have the potential of completely eliminate the hazard, thus greatly reducing the probability of an accident. Redesigning or replacing equipment or machinery may be expensive, but remember that, according to the National Safety Council, the average direct and indirect cost of a lost work time injury is $34,000 and $1,115,000 to close a fatality claim.

Some examples of these two strategies include:

  • Removing the source of excessive temperatures, noise, or pressure
  • Substituting a toxic chemical with a less toxic or non-toxic chemical

PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with engineering controls and other administrative controls.

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.

Administrative Controls

Administrative 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 administrative 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, administrative controls rely on human behavior (which introduces many variables in the long run) that must be continually managed.



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