Course 600 - Introduction to Occupational Safety and Health

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Personal Protective Equipment

What is Required?

Personal Protective Equipment for Chemical Work
PPE, such as the gloves and eye protection seen here, must be provided to the employee at no cost.

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.

What is proper use?

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:

  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
  4. the employer does not properly train employees on the use of PPE

What subjects must be trained?

According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:

Lineman climbing a pole with PPE
Photo courtesy of Honeywell Safety Products, Manufacturer of Miller fall protection products.
  1. when PPE is necessary
  2. what PPE is necessary
  3. how to properly don, doff, adjust, and wear PPE
  4. the limitations of the PPE
  5. the proper care, maintenance, useful life, and disposal of the PPE

So far, we meet minimum OSHA requirements... but one very important element is missing:

  1. the PPE standard does not specifically require education on "why" PPE is necessary

Why is this element 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.

Educate the "why" as well as train the "how"!

The first five elements in the list describe the what, when, and how about PPE use. The goal is to increase both knowledge and skill so that the employee is better able to properly use PPE. The methods used to train the employee are primarily discussion and demonstration. To measure knowledge and skill, the instructor usually tests the employee by asking them to do something.

The final "why" element addresses the importance of using PPE and what the consequences of behavior (compliance and failure to comply) will be. The natural consequences include some form of resulting injury or health to the employee. The system consequences describe the nature of the discipline or recognition that will result from performance. The goal of this last element is to increase employee motivation to use PPE so that the employee is more likely to use PPE properly.

Demonstration is the key

Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:

  • demonstrate an understanding of the training elements listed above
  • demonstrate the ability to use PPE properly
Woodworker being trained and wearing PPE
Properly demonstrating tasks and ensuring PPE is correctly used is an important responsibility of the employer..
(Click to Enlarge)

Demonstration is really 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.

  1. What PPE is required for your particular job?
  2. When is the PPE required to be used in your job?
  3. What are the possible defects your PPE might have?
  4. How do you properly care for and maintain/store your PPE?
  5. What is the useful life of your PPE?
  6. From what hazards does the PPE protect you?

The form of the "test" may be either written or oral. If you are training a number of employees, you should give them a written test to best measure individual knowledge. It's also the intent of most OSHA law that knowledge be measured by written exams.

Online Training

According to a 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." In addition to the online training (including this course), PPE training must also include a hands-on portion so that the employee can practice using the PPE.

When is retraining required?

When the employer has reason to believe that 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:

  • changes in the workplace render previous training obsolete;
  • changes in the types of PPE to be used render previous training obsolete; or
  • deficiencies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill

Who should conduct the training?

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." To meet minimum rule requirements, the employer must verify each affected employee has received and understood the required training. This must be done using a written certification that contains:

  1. the name of each employee trained
  2. the date(s) of training
  3. the subject of the certification

However, when it comes to documentation of PPE training, it's a good idea to go beyond the minimum requirements stated in the standard to make sure the employer can demonstrate (prove) they have met or exceeded their legal obligations with respect to safety training.

Solid PPE training documentation will contain the elements below:

  • A statement by the employee that they have received training by the employer on the six subjects listed previously, and that the trainer has demonstrated proper use of the PPE and answered all employee questions about the PPE satisfactorily.
  • A statement by the trainer that, through an oral or written test, the employee has satisfactorily demonstrated an understanding of the subjects covered during training, and has, through practice, demonstrated the ability to properly don, use, doff, care for, and maintain the PPE.

Remember, PPE training is absolutely critical to an effective program. Effective training will likely prevent serious injury or even a fatality which makes it all worthwhile.

Personal Protective Equipment (PPE)

Hard Hat Demonstration Using Watermelon

Proper Disposable Glove Removal

Instructions

Before beginning this quiz, we highly recommend you review the module material. This quiz is designed to allow you to self-check your comprehension of the module content, but only focuses on key concepts and ideas.

Read each question carefully. Select the best answer, even if more than one answer seems possible. When done, click on the "Get Quiz Answers" button. If you do not answer all the questions, you will receive an error message.

Good luck!

24. Personal protective equipment (PPE) may be required for the:

25. Employers must also make sure employees use and maintain PPE in a sanitary and reliable condition.

26. Which of the following root causes may result in general non-compliance in the use of PPE?

27. OSHA does not require training on the limitations of the PPE.

28. Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:

29. When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by the PPE standard, the employer should retrain the employee.


Have a great day!

Important! You will receive an "error" message unless all questions are answered.