SPECIAL REPORT

Does Your PPE Program Meet OSHAs Requirements?

4 Critical Steps to Help You Comply and Protect Your Employees

10101260

SPECIAL REPORT

Does Your PPE Program Meet OSHAs Requirements?

4 Critical Steps to Help You Comply and Protect Your Employees

10101200

Executive Publisher: Robert L. Brady, J.D. Editor in Chief: Margaret A. Carter-Ward Managing Editor: Judy Ruddy Editor: Carolyn Leese Production Supervisor: Isabelle B. Smith Graphic Design: Catherine A. Downie Layout and Production: Susan Dumas This publication is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional services. If legal advice or other expert assistance is required, the services of a competent professional should be sought. (From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers.) 2008 BUSINESS & LEGAL REPORTS, INC. All rights reserved. This book may not be reproduced in part or in whole by any process without written permission from the publisher. Authorization to photocopy items for internal or personal use or the internal or personal use of specific clients is granted by Business & Legal Reports, Inc., provided that the base fee of U.S. $0.50 per copy, plus U.S. $0.50 per page, is paid directly to Copyright Clearance Center, 222 Rosewood Drive, Danvers, MA 01923, USA. For those organizations that have been granted a photocopy license by CCC, a separate system of payment has been arranged. The fee code for users of the Transactional Reporting Service is 1-55645-618-2/07/$.50+$.50. ISBN 1-55645-618-2 Printed in the United States of America Questions or comments about this publication? Contact: Business & Legal Reports, Inc. 141 Mill Rock Road East P .O. Box 6001 Old Saybrook, CT 06475-6001 860-510-0100 http://www.blr.com

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Table of Contents
Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1910.132General Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1. Hazard Assessment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2. Equipment Selection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 3. Employee Training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 4. Follow-UpReinforcement and Enforcement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 1910.133Eye and Face Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 1910.134Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 1910.135Head Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 1910.136Occupational Foot Protection . . . . . . . . . . . . . . . . . . . . . . . . . . 11 1910.137Electrical Protective Devices . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 1910.138Hand Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Protective General Work Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 Conclusion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Personal Protective Equipment Hazard Assessment Certification . . . . . . . . . . . . . . 18

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Introduction
As an employer you have two important safety goals to keep in mind: N Protecting your employees as they perform their duties, and N Complying with OSHA regulations that apply to your workplace. These two goals must be considered for all phases of your operations, but they clearly are paramount in the case of personal protective equipment (PPE). As the name states clearly, the purpose of this regulation is employee protection, and OSHA spells out exactly how this protection must be achieved. This report will first examine the four critical steps that OSHA requires in its general regulation on PPE (1910.132). Then we will take a look at how these general rules apply to the various categories of PPE: N 1910.133Eye and face protection N 1910.134Respiratory protection N 1910.135Head protection N 1910.136Occupational foot protection N 1910.137Electrical protective devices N 1910.138Hand protection Youve undoubtedly heard some horror stories about workers who were injured because they werent wearing PPE that could have kept them safe. Perhaps you have some stories of your own to tell.Year after year, work accident statistics show that an alarming number of injured workers were not wearing PPE that could have preventedor at least lessened the severity oftheir injuries. Making sure your employees use required PPE is a tough responsibility that you cant dodge since it comes straight from OSHAs PPE standard (Subpart I). However, its a duty made lighter by remembering four essential steps.

1910.132General Requirements
1. Hazard Assessment
Section 1910.132(d)(1) of the OSHA standard says that employers must assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment. In addition, the employer has to certify in writing that the assessment was performed [Section 1910.132(d)(2))]. Think head-to-toe protection and be sure to consider all the hazardsfalling objects, chemical exposures, flying objects, sharp objects, and rolling or pinching objectsas well as all the protectionshard hats, safety glasses and goggles,
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respirators, gloves, safety shoes, and other clothing and equipment. The better you identify and understand the impact of specific hazards, the better you will be able to take the next step and select the most appropriate PPE. Although this report will focus on PPE, it is obviously preferable if hazards can be eliminated so its use is unnecessary. In some cases, engineering controls like ventilation systems, machine guards, or physical separation of workers can eliminate or reduce a particular hazard. In other instances, administrative controls or work practices can reduce a hazard by minimizing the time of worker exposure. Remember that PPE is only a supplementary form of protection, necessary where all hazards have not been controlled through other means. Even if they have, PPE may still be advisable in some cases as a backup.

2. Equipment Selection
Section 1910.132(d)(1) also states that if such hazards are presentor are likely to beyou must: N Select, and have affected employees use, the types of PPE that will protect them from the hazards you have identified. N Communicate selection decisions to employees. N Select PPE that fits each affected employee properly. There has been a lack of clarity in the past about who should pay for PPE. OSHA has tried to correct that situation with a final rule, effective on February 13, 2008, with employer implementation no later than May 15, 2008. Section 1910.132(h) states that PPE, with only a few exceptions, shall be provided by the employer at no cost to the employee. The exceptions are as follows: N Nonspecialty safety-toe protective footwear (including steel-toe shoes or steeltoe boots), provided that the employer permits such items to be worn off the jobsite. N Nonspecialty prescription safety eyewear, provided that the employer permits such items to be worn off the jobsite. N Shoes or boots with built-in metatarsal protection that the employee chooses instead of metatarsal guards provided by the employer. N Logging boots required by 29 CFR 1910.266(d)(1)(v). The rule also makes clear that certain items are not considered PPE and do not require payment by the employer. They include: N Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; or N 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 rule also states that employers must pay to replace PPE on a regular basis. This duty is considered part of the employers obligation to be sure that the PPE is in good condition. The only exception to the rule about paying for replacement is when the employee has lost or intentionally damaged the PPE.

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Try to involve employees in the selection process whenever possible. Have a variety of sizes and styles available to accommodate the needs of all your workers. Let them join you in picking the PPE that they find most comfortableas long as it can do its job. Many employers have found that for some items, like safety glasses or shoes, many employees like to be able to select from different colors or styles according to their tastes. When choices are possible, worker cooperation increases if they actually like the look of their PPE. N In such instances, some employers may give a set allowance toward the workers selection, as long as the PPE is considered adequate to protect the worker. N If the employee makes a more expensive choice, he or she is responsible for the extra cost. While we are discussing the regulations about employer payment, the rule establishes the following rules about employee ownership of PPE. N Where an employee owns adequate PPE and is allowed to use it, the employer is not required to reimburse the employee for that equipment. N Often, newly hired workers report to the workplace with PPE they own. N This practice occurs in many industries but seems to be found more frequently in workplaces that use short-term labor. N OSHA makes it clear, however, that employers cannot avoid their obligations by requiring employee ownership of PPE as a condition of employment. Hazard assessment and equipment selectionthe first two stepsare actually the easy part. The hard part is encouraging employees to actually use the PPE. The next two stepstraining and follow-up present the challenge of reaching employees and communicating your important message.

3. Employee Training
Section 1910.132(f)(1) requires you to train employees concerning each type of PPE before allowing them to perform any work requiring its use. At a minimum, your PPE training program must include the following information: N When PPE is necessary, N What PPE is necessary, N How to properly don, doff, adjust, and wear the PPE, N Limitations of the PPE, and N Proper care, maintenance, useful life, and disposal of the PPE. The regulations [1910.132(f)(3)] also require you to retrain whenever: N Changes in the workplace render previous training obsolete. N Changes in the types of PPE to be used render previous training obsolete. N Inadequacies in an employees knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill. The employer must certify in writing that each affected employee has received and understood the training [1910.132(f)(4)].

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Here are some training tips to encourage employees cooperation. N Explain the need for each type of PPE. Identify each hazard that employees face on the job and explain specifically how a particular type of PPE protects them against this hazard. N Point out that OSHA requires it. Make sure your employees understand that the requirement is mandated by law. The company could be cited and fined if employees dont use PPE required by OSHA regulations. N Dramatize the consequences of failing to use required PPE. Tell your horror stories or miracle stories. Or borrow someone elses. Show them a piece of damaged PPE that saved a worker from an injury if you can. Or show them a video that dramatizes the importance of wearing PPE. N Help employees recognize that PPE gives them more control. People like to feel that they are in control of their own destiny. Wearing appropriate PPE will do just that. N Lead by example. Always use required PPE yourself in the work area, and require visitors to use it, too. The example you set for your employees is a very powerful motivator.

4. Follow-UpReinforcement and Enforcement

You have to accept the fact that no matter what you do, a few employees will still forget to use their PPE, ignore the rules, think that PPE is for wimps, or believe that accidents happen to someone else. Daily monitoring is essential to see that employees are actually wearing their PPE. Try these suggestions to motivate your employees and keep your PPE program from going down the drain: N Use a behavioral approach. As you walk around the department every day, give employees positive feedback for using PPE. When you catch employees not wearing required PPE, rather than scold them, tell them you are concerned about their safety. Tell them to stop what they are doing and go and get their PPE. The next time you see them wearing it, be sure to praise them. N Recognize and reward employees for using PPE. At safety meetings, praise employees for using PPE. Have a Safe Employee of the Month contest every month and include wearing PPE as one of the main criteria for winning the award. N Make it easy to get and exchange PPE. If its a hassle for employees to get PPE or exchange damaged or worn articles for new ones, they probably wont bother and will opt for just not using it. So make sure PPE is readily available and easily accessible at all times. N Recognize proper use of PPE in performance appraisals. Make sure employees understand that one of the factors you will use to assess their performance is regular use of required PPE. N Enforce PPE policies. Use discipline if necessary as a last resort to show employees you are serious about their wearing assigned PPE. If youre not 100 percent sure that all of your employees are using required PPE right this minute, maybe this is a good time to go and check. The next step in the process is to relate each of these four elements to the types of PPE your workplace requires.

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

1910.133Eye and Face Protection

Hazard Assessment
If any of these hazards are discovered, eye and face protection will be necessary: N Flying particles N Molten metal N Liquid chemicals N Acids or caustic liquids N Chemical gases or vapors N Potentially injurious light radiation

Selection of Eye and Face Protection

If there are rarely any flying objects (e.g., metal or wood chips), safety glasses with side protection may be adequate. If the job frequently involves exposure to flying objects, the worker should wear a face shield over the safety glasses. Normal safety glasses will not protect against fine airborne particles such as dust, however, because the particles will float behind the glasses and into the workers eyes. In this case, the worker must instead wear goggles that are designed to protect against dust. For those who are exposed to molten metals, a face shield designed to protect against the extremely hot metal must be worn. Workers who are exposed to liquid chemicals, acids or caustic liquids, or chemical gases or vapors cannot wear normal safety glasses or dustproof goggles because the chemical could splash onto their face and eyes. In this case, they must wear chemical-resistant goggles. Face shields may also be required if splashing is likely to occur. Potentially harmful light radiation refers to the light from welding operations or laser equipment. Workers exposed to this hazard will need to wear eye and face protection with filter lenses that have a shade number appropriate for the hazard. Workers who require prescription eyewear must wear either protective devices fitted with prescription lenses or protective devices designed to be worn over regular prescription eyewear. Normal prescription glasses are not strong enough to protect against flying objects and are not adequate for other hazards such as chemicals, molten metal, or light radiation.

Payment for Nonspecialty Prescription Safety Eyewear

Provided the employer permits such items to be worn off the jobsite, such eyewear is specifically listed as one of the few types of PPE that an employer is not required to pay for. Because it is more convenient and comfortable than having prescription eyewear covered by a second protection device, however, some employers will contribute at least a portion of the cost. They feel it is a relatively small price to pay to ensure that their workers are protected at all times when there is a workplace hazard.

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Wearers of contact lenses must also wear appropriate eye and face protection devices in a hazardous environment. It should be recognized that dusty and/or chemical environments may represent an additional hazard to contact lens wearers. Dust may get behind the contact lens and scratch the eye. Chemicals could melt the contact lens or get behind the lens and cause a serious eye injury. Eye and face protection must be designed according to the American National Standards Institute (ANSI) Z87.1-1989 to be considered safe to use in the workplace. Equipment will be marked with Z87 if it meets these standards.

Worker Training
Putting on, removing, and wearing eyewear is basic common sense and probably requires little instruction. Employees should be reminded, however, to put on eye or face protection before entering a hazardous area, and not to remove it until they leave the area. Injury to the eye or face from a flying object takes only a brief second. For the same reason, anyone, including visitors, who enters the area should wear protection.

One tip:
If workers are exposed to dust or liquid chemicals while wearing goggles, they should be sure to clean the top rim of the goggles before removing them so dust or liquid chemicals that have accumulated on top of the glasses does not fall into their eyes.
Eye and face protection should fit comfortably and should not distort or block vision. Eyewear should not pinch the nose or put pressure on the head, but it must fit snugly if the air contains dust or other fine particles. Employees should be instructed to clean eye and face protection on a regular basis with soap and water or with special cleaning solutions (some contain antifog ingredients). They should be reminded to dispose of eye and face protection when it becomes scratched and distorts vision or becomes otherwise damaged and no longer provides adequate protection.

Follow-Up
N Keep reminding everyone of the importance of eye and face protection. N Make sure anyone who enters the area follows the ruleskeep a supply of safety glasses available for visitors. N Also, be sure there is a backup supply of protection in case a workers PPE is lost or damaged.

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

1910.134Respiratory Protection
Hazard Assessment
OSHAs respiratory protection standard has many requirements that are beyond the scope of this report. One provision requires the employer to assess the workplace to ensure that employees are protected when potentially exposed to workplace hazards such as: N Inhalation of airborne dusts or particulates N Inhalation of chemical vapors or fumes N Lack of adequate oxygen Once the assessment has identified the potential for exposure to dusts, chemical vapors, or a lack of oxygen, the assessment must go deeper and include: N Identification of the hazardous substance(s) that may be the source of the respiratory hazard. N Review of work processes to determine where hazardous exposures occur as well as the magnitude of the exposure(s). This review will be conducted by surveying the workplace, reviewing process records, obtaining objective data, and talking with employees and supervisors. N When necessary, exposure monitoring will be required to measure potential hazardous exposures.

Selection of Respiratory Protection

The respiratory protection standard discusses in detail the selection of proper protection from the hazards discovered by the hazard assessment. The following is a basic summary; however, the regulations should be consulted to ensure proper respiratory protection is selected. If employees are exposed to only low levels of dust, often referred to as nuisance dust, they may voluntarily choose to use a dust mask or filtering facepiece. In this case, OSHA requires employers to supply certain basic information for employees using respirators voluntarily. If employees are exposed to high levels of dust and the exposure levels have been monitored to show that the dust levels are over permissible exposure limits (PEL), employees must be required to wear a filtering facepiece. Employees who are exposed to chemical vapors or fumes may also be required to wear a respirator. The employer will need to determine which chemical(s) employees are being exposed to. After determining the chemical, the employer will need to have the air monitored to determine the level of employee exposure. The monitoring results will determine if respiratory protection is required. OSHA regulations provide: N The employer shall select and provide an appropriate respirator based on the respiratory hazard(s) to which the worker is exposed and workplace and user factors that affect respirator performance and reliability.

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N The employer shall select a NIOSH-certified respirator. The respirator shall be used in compliance with the conditions of its certification. N Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be Immediately Dangerous to Life and Health (IDLH). N The employer shall select respirators from a sufficient number of respirator models and sizes so that the respirator is acceptable to, and correctly fits, the user. OSHA has incorporated new Assigned Protection Factors (APFs) into Agency rules. APFs are numbers that indicate the level of protection a respirator or class of respirators is expected to provide employees when used as part of an effective program. Employers must select respirators by comparing the exposure level and the maximum concentration of the contaminant in which a particular type of respirator can be used. Known as the Maximum Use Concentration (MUC), this is generally determined by multiplying the respirators APF by the contaminants exposure limit. In cases of very high exposure levels, such as during a chemical spill, employees may be exposed to levels that are considered IDLH. In this case, employees must wear Self-Contained Breathing Apparatus (SCBA) or air-supplied respirators with escape bottles. Employees who work in areas where a chemical spill is likely to create IDLH conditions should be provided with emergency escape respirators. Air-purifying respirators have different cartridge types to choose from, depending on the potential chemical contaminant. Check with the respirator manufacturer to determine which cartridge will filter out the chemical your employees are exposed to. The manufacturer may also be able to help you determine how long it may take for a chemical to break through the cartridge and therefore determine how often the employees need to change their cartridges. Employees who are exposed to work environments that lack adequate oxygen (e.g., working in a confined space) will need to wear an air-supplied respirator. An air-purifying respirator will not work because there is not enough oxygen in the atmosphere to begin with. Refer to your confined spaces program for the details on how to work safely in spaces that lack adequate oxygen. Any time employees wear air-purifying or air-supplied respirators, they must be included in your companys Respiratory Protection Program. These employees must be medically evaluated to ensure it is safe for them to wear a respirator. All respirators used in accordance with this Respiratory Protection Program must be certified by the National Institute for Occupational Safety and Health (NIOSH) and shall be used in accordance with the terms of that certification. All filters, cartridges, and canisters must be labeled with the appropriate NIOSH approval label. The label must not be removed or defaced while it is in use.

Worker Training
Once the employee is medically approved to wear a respirator and the proper type has been selected, the employee must be trained and fit tested. Fit testing involves judging whether a worker can detect various odors, tastes, or smoke while wearing the selected respirator.

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Before each use, the employee must also be taught to inspect the respirator and the seal, head straps, valves, and cartridges for signs of cracking, wear, or other damage. Any damaged parts should be discarded and replaced. When employees first put on a cartridge respirator they must check the respirators seal to their face by conducting either a positive or negative seal check. Respirators must be cleaned and stored properly. They should be wiped clean at least daily and thoroughly cleaned on a regular basis. The thorough cleaning should include taking the respirator apart and cleaning it in soap and water and allowing it to air dry. Respirators should be stored in plastic bags that can be sealed so they are protected from dust or other contaminants. The cartridges should be stored separately from the respirator.

Follow-Up
If the respiratory hazards in your workplace involve poisonous chemicals, workers are going to recognize the importance of their respirators and are probably going to be quite cooperative about following proper safety procedures. If, however, the hazards are not quite so obviousdust or fibers in the air, for exampleworkers may not fully understand that these are real dangers. Even if they do not present an acute hazard and will not kill you in 15 minutes, they can cause serious long-term health problems. The many medical problems that have developed among emergency workers following the 9/11 disaster attest to the serious consequences of workers not using proper respiratory protection. Managers should make sure that this message is repeated as often as is necessary. They should also speak to any worker who is not using required protection and insist on compliance.

1910.135Head Protection
Hazard Assessment
The employer must assess the workplace to ensure that employees are protected when potentially exposed to workplace hazards such as: N Falling objects N Exposed electrical conductors N Low-hanging obstructions

Selection of Head Protection

If there is a potential for head injury from falling objects, employees must wear protective helmets.When assessing the workplace, look for areas where employees are working beneath other employees.Type I helmets are designed to provide only top impact protection while Type II helmets provide protection against both top and side impacts.

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If employees work near exposed electrical conductors that could contact their head, the employee must wear a protective helmet designed to reduce electrical shock. Do not assume that hard hats will protect against electrical hazards just because they appear to be made of nonconducting material. The proper hard hats are specifically designed to reduce electrical shockthey are called Class E and are tested to 20,000 Volts. Workers are often required to go into areas that may present a bump hazard from low-hanging objects such as pipes, steel structures, or machinery parts. When employees complain about hitting their heads on obstructions in an area, they need bump caps. A helmet may not be necessary because employees are not exposed to falling objects or exposed electrical conductors. However, wearing bump caps, which are made of lightweight hard plastic, is an effective way to ensure that employees do not suffer bruises or cuts on their heads from walking into solid objects. Most hard hats are made of high-density polyethylene so they are lightweight, yet strong enough to meet the protection requirements for impact, penetration, and electrical insulation. However, some industries may require hard hats made of a different material because the polyethylene could be damaged in certain work environments, such as in the steel industry, where the helmet might be melted by the high temperatures. Helmets used in the workplace must be designed according to ANSI Z89.1-1997, which is the standard that all protective headwear intended for industrial use must meet to be used in the workplace. Protective helmets will be marked with Z89 if they meet these standards.

Worker Training
Head protection should fit comfortably. There are many different types of suspension systems for hard hats. Be sure employees are trained on how to properly adjust the suspension in the hard hat to ensure proper fit. Hard hats should be inspected before every use. Check the hard hat itself and look for cracks or any other signs of damage that could reduce the integrity of the hard hat. Inspect the suspension system for cracks, worn straps, or any other damage. Make sure the suspension system is installed properly in the hard hat and not put on backward. Hard hats should be cleaned on a regular basis with soap and water. They should be stored in a safe cool place, not in the back deck of a truckthe hot sun will cause deterioration. The hard hat should be replaced if it receives a hard blow, even if there is no visual sign of damage.

Follow-Up
Head protection is another type of protection that is often ignored by visitors or others who are just passing through the workplace. Wearing a hard hat should be required for everyone in the danger area. Be aware that remodeling of facilities or repair work may necessitate new areas to be designated as hard hat areas. Be alert to such temporary hazard areas.

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Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

1910.136Occupational Foot Protection

Hazard Assessment
The employer must assess the workplace to ensure that employees are protected when potentially exposed to workplace foot hazards such as: N Falling objects N Rolling objects N Objects piercing the sole N Exposure of employees feet to electrical hazards N Slippery walking surfaces N Wet or muddy conditions N Hazardous chemicals N Heat N Cold weather conditions

Selection of Foot Protection

If employees work in areas where heavy objects would fall and crush or otherwise damage their feet, the workers should be required to wear boots or shoes with protective steel toes. Some boots will also have protection for the upper part of the foot (the metatarsal) and are recommended when there is potential injury from falling objects. Strap-on foot guards made of aluminum or high-density plastic can also be purchased. Employees exposed to rolling objects will require toe and possibly metatarsal protection. Some footwear contains steel in the heel and along the ankle to help protect the ankle from being twisted or otherwise damaged. Employees who work where sharp objects can pierce the sole should wear boots with steel shanks that prevent sharp objects from penetrating the foot. Workers exposed to electrical hazards should wear nonconducting shoes that have a high resistance to electricity. Workers exposed to higher voltages will require special boots as well as other precautions to help prevent them from becoming part of an electrical current. When slippery work surfaces cannot be engineered out of a workspace, employees should be required to wear shoes that have slip-resistant soles. Many workers think normal athletic shoes, such as tennis or basketball shoes, will provide slip-resistance. However, these shoes actually slip very easily on wet surfaces. Also, consider the material that is causing the slippery surface. Water will require a different type of sole than a surface that is covered with an oily product. Workers in wet or muddy conditions should have foot protection designed to keep their feet dry. Basic rain boots made of PVC or rubber are needed for these conditions.
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Workers exposed to liquid chemicals, acids, or caustic liquids require chemicalresistant boots. The proper boot must be made of material that will protect against the chemical to which the employee will be exposed. Boots can be made of different materials, such as rubber, PVC, neoprene, or vinyl. Check with the boot manufacturer to see if they have performed chemical-resistance tests on their boots. Boots for firefighters may also require special testing. Workers exposed to cold weather conditions can purchase footwear with special liners that will protect their feet from the cold conditions. Special footwear should be considered for workers in freezing outdoor conditions and for those that work inside refrigerated environments. As discussed previously in this report, nonspecialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) does not have to be paid for by the employer, provided that the employer permits such items to be worn off the jobsite. The same is true of logging boots required by 29 CFR 1910.266(d)(1)(v). Similarly, if an employee chooses shoes or boots with built-in metatarsal protection instead of metatarsal guards provided by the employer, the extra cost is the employees responsibility. Just because the employer may not have to pay for foot protection doesnt eliminate the responsibility to require employees to wear adequate foot protection in good condition. Note that many work shoes on the market today can protect against a number of these hazards. It is possible to purchase chemical-protective boots that have steel toes and steel shanks with slip-resistant soles. So if employees are exposed to multiple hazards, make sure they have the footwear that will protect against all of them. Foot protection shall be designed according to ANSI Z41-1991, the standard for all protective footwear used in the workplace.

Worker training
Work footwear must be comfortable since it will be worn for 8 to 12 hours a day. It should be inspected before each use. Chemical-resistant footwear should not have cracks or holes. Slip-resistant soles should not show excessive wear. Normal work boots that develop holes or splits must be replaced and should not be repaired with duct tape. Keep footwear clean. Chemical-resistant shoes should be decontaminated after every use. Other work shoes should be cleaned or sprayed with water regularly.

Follow-Up
Like face and head protection, protective footwear seems like such a common everyday item, workers are apt to forget that wearing it is an important safety rule.They need to be reminded frequently that foot protection is not optionalit is required.

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Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

1910.137Electrical Protective Devices

Hazard Assessment
When assessing a workplace for electrical hazards, employers should consider possible hazards to both nonqualified workers and qualified workers. An unqualified worker has only very basic knowledge of electrical safety and no familiarization with or training in the construction or repair of electrical equipment and the hazards involved. Such a person should never be working close to energized equipment. Therefore, protection for such workers would involve engineering to enable them to do their jobs without ever being in a hazardous area close to energized equipment. A qualified worker, on the other hand, is a person familiar with the construction, repair, and operation of the electrical equipment and the hazards involved. Such a person is expected to have the training and knowledge necessary so that he or she can safely perform duties involving energized equipment.This involves PPE in the broadest senseprotective clothing, insulated tools, and insulated covering materials. The hazard assessment of your facility should include the maximum voltage exposure in any danger area. Based on that, the tables in the OSHA standard will show what class of equipment is required to provide adequate protection from the electrical hazard.

Selection of Electrical Protection Devices

This report has already mentioned special insulated gloves, safety helmets, and safety shoes for use where there is possible exposure to electrical hazards. OSHA regulations spell out in detail the requirements for electrical protection devices, which must meet American Society for Testing and Materials (ASTM) consensus standards. OSHA references ASTM specifications for rubber insulating gloves, blankets, covers, line hose, and sleeves. OSHA also has tables with A-C and D-C proof-test requirements for such equipment. The standard has very specific regulations, including proper marking of equipment, and should be studied in detail to be sure that protective equipment provided to workers is adequate for the hazards noted in the assessment.

Worker Training
Obviously, if electrical protection devices are going to do their job properly, they must be in good condition. OSHA regulations require insulating equipment to be inspected for damage before each days use and immediately following any incident that can reasonably be suspected of having caused damage. In addition, the standard requires that insulating gloves be given an air test along with the inspection. The OSHA regulations also cite ASTM specifications for in-service care of insulating equipment. They spell out requirements for removal from service of defective equipment, proper storage, and proper repair.

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Workers must understand that, indeed, their lives depend on the correct equipment for the hazards they face and that this equipment must be in good condition at all times.

Follow-Up
The consequences of not following safety rules regarding electricity can be tragic. Perhaps, because of that fact, workers may take these rules more seriously. However, sometimes people just get careless or try to take shortcuts. Management should be vigilant to see that electrical safety rules are followed every time. Newly trained workers should be monitored closely to be sure they know where the hazards are and have learned the rules thoroughly. Disciplinary action should be taken if any violations are observed.

1910.138Hand Protection
Hazard Assessment
Some of the potential types of hazards that would require hand protection are: N Skin absorption of harmful substances N Chemical burns N Severe cuts or lacerations N Punctures N Severe abrasions N Thermal burns N Cold weather conditions N Electrical hazards

Selection of Hand Protection

OSHA requires that glove selection be governed by evaluating the level of protection relative to the task to be performed, conditions present, duration of use, and hazards identified. If employees work with hazardous chemicals that could damage their skin, such as acids, caustics, or solvents, hand protection is required. The first concern when selecting a glove for chemical protection is to make sure the correct material is chosen for the type of chemical exposure. Those who work with many chemicals will most likely require a number of different glove types. Chemical-resistant gloves are made from a variety of materials including rubber, latex,Viton, butyl, nitrile, neoprene, and PVC. Glove manufacturers will perform tests on their gloves to determine chemical resistance and grade their gloves on degradation, breakthrough time, and permeation rate for a number of chemicals. Employers should contact the glove manufacturer for a chemical-resistance chart or guide.

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Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

When evaluating gloves for use with chemicals, it is important to consider features such as resistance to abrasions, cuts, or punctures; flexibility; heat resistance; or even tensile strength. A buyer should also consider glove length. If workers are dipping their hands into chemicals they will need to have longer gloves than if they are just handling objects contaminated with chemicals. Employees who work with saws, knives, or glass should wear gloves that will protect their hands from punctures, cuts, and lacerations. If they work with sharp blades, steel mesh gloves are the most effective. Some gloves have steel wires, staples, or small plates woven into the material. Other glove materials, such as Kevlar, provide good cut resistance.When evaluating cut-resistant gloves, a slip-resistant grip should also be considered if the worker is handling tools or knives. Cut-resistant sleeves are also available to protect a workers arms and even shoulders if necessary. Many workers are exposed to the potential for severe abrasions, cuts, or scrapes from metal burrs or slivers from handling wood. These workers should be equipped with leather, canvas, or cotton work gloves. These gloves can be lined for cold weather or even coated for improved grip or mild chemical resistance. Employees who are exposed to the potential for thermal burns from welding operations or from working with ovens or other hot equipment will require gloves made from heavy quilted cotton, leather, pigskin, or Kevlar. Welders should consider fit and flexibility as well as heat resistance. The type of welding performed may dictate the type of glove required. In addition to gloves, sleeves and other arm protection can be purchased. When purchasing thermal mittens for hot work, consider the maximum temperature for which the manufacturer has designed the glove. For resistance to flame or extreme temperatures (e.g., in foundries, steel mills), provide employees with aluminized gloves and clothing. Remember that gloves and other clothing used solely for protection from weather are not considered PPE and do not require payment by the employer. However, workers exposed to cold conditions, whether working outside or in refrigerated environments, may face hazards because of their job duties. Be sure to consider other concerns such as grip or cut-resistance when selecting gloves and liners that are to be required as PPE. Electricians working with live electrical wires will wear rubber lineman gloves that are designed for use with different levels of voltage. Higher voltage gloves are black rubber with a red interior so any cuts or damage to the outside of the glove can be seen more easily. Electricians may wear leather gloves over the rubber lineman gloves to protect the rubber from damage. Liners will also be worn under the gloves to absorb perspiration in the summer and keep the hands warm in the winter.

Worker Training
Hand and arm protection should fit comfortably. Gloves should not be so tight that they limit hand movement or so loose that they present a hazard of being snagged, caught, or grabbed by moving equipment. Inspect your hand protection before each use. Be sure chemical-resistant gloves do not have any cracks, holes, cuts, or other signs of damage that could decrease the protection of the glove. Gloves for cut resistance should be inspected for cuts or wear and to make sure any chain links have not been damaged. Normal work gloves should be inspected for unusual wear or other damage. Electricians gloves

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should be inspected for cuts or scrapes, and the liners should be replaced on a regular basis. Aluminized heat-resistant gloves should be checked for abrasions to the outside surface and damage to inner liners. Damaged gloves should be discarded and replaced. Keep your gloves clean and dry. Some gloves are machine washable. Chemicalresistant gloves should be decontaminated after every use or discarded properly if they are disposable gloves. Remove them carefully to avoid skin contamination.

Protective General Work Clothing

Hazard Assessment
The employer must assess the workplace to ensure that employees are protected when potentially exposed to workplace hazards such as: N Hot or cold materials or objects N Chemicals N Welding hazards N Electrical shock N Heavy, sharp, or rough materials Once again, the distinction must be made between ordinary clothing used solely for protection from weather, and clothing designed for protection from job hazards. The first is not considered PPE (and an employer is not required to pay for it) but the latter, most definitely is considered required PPE.

Selection of General Work Clothing

Long sleeve shirts and long pants may be required to protect the arms and legs from exposure to some of the hazards listed above. Workers exposed to hot or cold materials, objects, or environments must wear appropriate clothing. Flame-retardant clothing, aprons, and even arm covers are available. Aluminized clothing, aprons, hoods, boots, and gloves are also available for those working with flame and extreme temperatures. Employees, whose duties expose them to extremely cold temperatures, should be provided with subzero jackets, overalls, hoods, etc. For proper protection, clothing must also be selected to protect against the specific chemicals to which the employees will be exposed. Clothing can be made from such materials as waterproofed fabrics, PVC, polyurethane, nylon, rubber, polyethylene, and polypropylene. Some types of chemical-resistant clothing are better suited for working with dry chemicals while others are designed specifically for working with specific hazardous liquid chemicals. Consult the clothing manufacturer for more information. Workers exposed to welding hazards will typically wear protective leather clothing including jackets, pants, aprons, and even caps.

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Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Employees who handle heavy, sharp, or rough materials should wear clothing made of strong, durable materials to protect their skin. This might include blue jeans and thick cotton or wool shirts.

Worker Training
Work clothing should fit comfortably, allowing for free movement while not being too baggy or loose. If workers have a chance to select from different styles or types of appropriate protective clothing, they are more likely to use it willingly every time. Workers should be instructed to inspect specialty clothing, such as chemical- and heat-resistant clothing, for holes or other damage before every use. If damaged, the clothing should be discarded in an appropriate manner. Specialized training is necessary for workers wearing clothing to protect them from harmful chemicals. They should be taught precautions to protect themselves and others from chemical contamination. They should: N Remove contaminated clothing only in the designated changing area. N Never touch any part of the contaminated clothing without gloves. N Remove clothing from the top down so contaminants from the jacket or apron dont touch their unprotected legs. N Always wear gloves to unfasten zippers, snaps, or other fasteners. N Place contaminated clothing in proper containers for cleaning or disposal. N Never wear contaminated clothing home or launder it with other laundry.

Follow-Up
It has been said before, but people get to be very nonchalant about hazards that they encounter on a regular basis. Safety posters (if they are changed frequently) can be helpful in reminding workers of the importance of PPE. Stories (and gory pictures) of accidents and injuries that have occurred when workers neglected to follow safety rules can also reinforce the message.

Conclusion
As with any other workplace program, your PPE program should be reviewed periodically to make sure it still meets your companys needs and OSHA requirements. If your operations have changed, your program may have to change as well to reflect new hazards. Make sure that all new employees receive thorough training before they are assigned duties that require PPE. Following the four essential steps, however, should guide you in making any necessary modifications. Following them should also give you assurance that you are complying with OSHA regulations and doing all that is possible to keep your employees safe.

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Personal Protective Equipment Hazard Assessment Certification

Date of Assessment:_________________________

Job Title Assessed: ____________________________________________________ Department:___________________________________________________________

Assessment Team: ________________________ ________________________ ________________________ ________________________

Certification: Name & Title: ______________________________________________ Signature:__________________________________________________

Eye & Face Protection Assessment

Yes/No Describe the Hazard Eye or Face Protection Required or Recommended

Is there potential for eye or face injury from:

Flying particles

Molten metals

Liquid chemicals

Acids or caustic liquids

Chemical gases or vapors

Potentially injurious light radiation

Other hazards

Respiratory Protection Assessment

Yes/No Describe the Hazard Respiratory Protection Required or Recommended

Is there potential for respiratory injury from:

Inhalation of airborne dusts or particulates

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Inhalation of chemical vapors or fumes

Lack of adequate oxygen

Other hazards

Personal Protective Equipment Hazard Assessment Certification (continued) Head Protection Assessment
Yes/No Describe the Hazard Head Protection Required or Recommended

Is there potential for head injury from:

Falling objects

E posed electrical conductors

Low-hanging obstructions

Other ha!ards

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Foot Protection Assessment

Yes/No Describe the Hazard Foot Protection Required or Recommended

Is there potential for foot injury from:

Falling objects

Rolling objects

Objects piercing the sole

Exposure to electrical hazards

Slippery walking surfaces

Wet or muddy conditions

Hot surfaces or fire

Hazardous chemicals

Cold weather conditions

Other hazards

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Personal Protective Equipment Hazard Assessment Certification (continued) Electrical Protective Device Assessment
Describe the Types of Protection Required or Recommended

Describe the Source of the Electrical Hazard:

Hand Protection Assessment

Yes/No Describe the Hazard Hand Protection Required or Recommended

Is there potential for hand injury from:

Skin absorption of harmful substances

Chemical burns

Severe cuts or lacerations

Punctures

Severe abrasions

Does Your PPE Program Meet OSHAs Requirements? 4 Critical Steps to Help You Comply and Protect Your Employees

Thermal burns

Cold weather conditions

Electrical ha!ards

Other ha!ards

Personal Protective Equipment Hazard Assessment Certification (continued)

Work Clothing Protection Assessment

Yes/No Describe the Hazard Work Clothing Protection Required or Recommended

Is there potential for bodily injury from:

Hot or cold materials or objects

Chemicals

Welding hazards

Electrical shock

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Handling heavy, sharp, or rough materials

Other hazards

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