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Safety & Health: Personal Protective Equipment

Over the past couple weeks, I have received several telephone inquiries on the topic of personal protective equipment (PPE). Specifically, the following questions arise most frequently:

1. Who decides what PPE is needed, and when and where is it to be used?
2. How do I determine what is the right choice of PPE to provide?

The whole PPE decision process begins with an assessment of the workplace and work processes by the employer to determine if there are hazards which truly require the use of PPE. Though it is the employer’s responsibility to ensure the assessment is conducted, it is strongly recommended that employers include workers in this process. The assessment is a basic requirement of OSHA’s Personal Protective Equipment standard, Subpart I, of the General Industry Safety and Health Standards (29 CFR 1910.132). Simply identifying the existence of real or potential hazards is not enough. Hazards must be evaluated through observation or scientific sampling to determine the likelihood and severity of worker exposure. USF SafetyFlorida can help with this!

It must also be determined if the hazard(s) can be eliminated, or worker exposure minimized to a safe level by installing engineering controls such as guards, barriers, mechanical control devices, ventilation systems, or sound dampening systems.

If engineering controls are not feasible, or able to reduce the hazard to a safe level, then Administrative Controls must next be considered for employee protection. Administrative Controls might include the development of specific procedures, and training employees on those procedures, or perhaps rotating personnel in and out of, for example, a noisy environment where the noise cannot be attenuated to an acceptable level.

If neither the implementation of Engineering Controls and/or Administrative Controls is adequate to abate the hazard, then the employer may need to consider the selection and use of appropriate PPE as a last resort.

Once the need for PPE has been established, the employer should review the specific OSHA standard for the type of PPE needed:

§1910.133 — Eye and face protection
§1910.134 — Respiratory protection
§1910.135 — Head protection
§1910.136 — Foot protection
§1910.137 — Electrical protective equipment
§1910.138 — Hand protection

These standards are available on OSHA’s website (https://www.osha.gov/law-regs.html), and provide valuable information on what to look for when it comes to procuring the needed equipment. The standards also articulate employers’ responsibilities in providing the equipment to employees and training personnel on the proper use, maintenance, and storage of the equipment.

Another important consideration on the topic of PPE is not only the requirement that it be provided, but that the employer ensures its proper use. While we all too often hear of the employer’s responsibility to provide safe work and a safe place of work, employees also have the responsibility to comply with all reasonable workplace rules and policies established to ensure their safety, including the proper use of PPE. That responsibility is only effective if there is accountability. OSHA holds employers, not employees, accountable. It is therefore incumbent that after the need for PPE has been recognized, equipment provided, and its intended use effectively communicated, employers must hold employees accountable for its proper and consistent use, for their own safety and well-being.