OSHA requires the use of personal protective equipment (PPE) to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective in reducing these exposures to acceptable levels.
Employers are required to determine if PPE should be used to protect their workers and have an obligation to provide PPE, including personal protective equipment for eyes, face, head, and extremities, and protective clothing and barriers. Employers must also make sure employees use and maintain PPE in a sanitary and reliable condition.
Personal Protective Equipment must be worn and used in a manner that will make full use of its protective qualities. Personal protective equipment used incorrectly potentially exposes an employee to hazards, defeating the idea behind using PPE.
Low rates of compliance in wearing PPE usually indicate the safety management system is failing in some way.
When employees don't wear or use PPE correctly, it is usually because the employer:
According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following topics:
So far, we meet minimum OSHA requirements, but one very important topic is missing:
Why is this topic so important? Because study after study tells us the most common reason employees don't follow rules in the workplace is because they don't know why the rules are important.
As we mentioned previously, the first five topic elements in the list required by OSHA describe the "what, when, and how" of PPE use. The goal is to increase both knowledge and skill so the employee is better able to properly use PPE.
The methods used to train the employee are primarily discussion and hands-on demonstration. To measure knowledge and skill, the instructor usually tests the employee by asking them to demonstrate using the PPE (harness, respirators, etc.).
The final "why" training topic addresses the importance of using PPE and what the consequences of behavior (compliance and failure to comply) will be. There are two primary types of consequences:
The goal of this last element is to increase employee motivation to use PPE. When employees understand the consequences, they are more likely to use PPE properly and consistently.
Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to demonstrate:
Demonstration is the most common and probably the most efficient method to determine employee knowledge and skills. How does the employee demonstrate an understanding of the six PPE training subjects listed previously? Simple, their level of knowledge is measured by asking the employee questions similar to those listed below.
Employees may be required to individually complete written tests or answer questions orally. The standard is that tests must measure individual knowledge. Asking groups of employees questions is not appropriate. OSHA does prefer written exams.
This is a very important question. Whoever the person training PPE is, he or she needs to be an expert who not only understands how to use PPE correctly, but has a thorough understanding of the importance of doing so. It's critical that the employee understands the importance of wearing PPE, not only for their safety, but their "continuing employment."
PPE training must be completed using a written certification document containing:
When documenting safety training, and specifically PPE training, it's also important to formally certify employees have demonstrated (proved) to the trainer, adequate knowledge and skills with respect to safety training.
PPE training documentation will be strengthened when it contains the elements below:
When the employer has reason to believe any affected employee who has already been trained does not have the understanding and skill required by the PPE standard, the employer must retrain the employee.
Circumstances where retraining is required include, but are not limited to, situations where:
According to an OSHA letter of interpretation (February 4th, 2009) about online training, OSHA states that an employer may not rely solely on the use of an online or video training program when training the use of PPE.
According to OSHA, the trainee must be able to "don, doff, touch, feel and otherwise manipulate a particular piece of personal protective equipment that an employer may require or provide to protect their employees to prevent injury or illness." To be considered adequate, online PPE training must also include a hands-on practice component so that the employee can practice using the employer's specific PPE.
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