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:
According to the standard, to meet the minimum training requirements, each employee receiving PPE training must be trained to know at least the following:
So far, we meet minimum OSHA requirements... but one very important element is missing:
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.
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.
Before an employee is allowed to do work requiring PPE, the employer must require each affected employee to:
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.
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.
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 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:
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:
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:
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.
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