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Personal Protective Equipment

Originally created by the Minnesota Safety Council for publication in the Minnesota Counties Insurance Trust publication The Safeguard. Used with permission.

As an employer, you have an obligation to protect your workers from workplace hazards. The preferred way to do this is through engineering controls or work practice and administrative controls. When these controls are not feasible or do not provide sufficient protection, an alternative method is personal protective equipment (PPE).

PPE: A Step by Step Guide

The following are general guidelines to help you comply with the OSHA personal protective equipment standards.

Step 1: Assess your work areas and job sites to identify potential hazards. Use a number of strategies:
  • Conduct a walk-through.
  • Talk to employees.
  • Review your OSHA 300 log of injuries and illnesses.
  • Review PPE recommendations on material safety data sheets (MSDSs).
  • Review job safety analyses or standard operating procedures.
Step 2: Select the proper type of protective equipment based on the hazard.

Step 3: Document that you have completed a PPE hazard assessment. Include who conducted the assessment, the name of your county and the date on which the assessment was completed.

Step 4: Purchase and provide the appropriate PPE, including various sizes and styles.
Who pays for personal protective equipment? In Minnesota, when personal protective equipment is required for the job, the employer is responsible for it (Minnesota Occupational Safety and Health Act, section 182.655, subdivision 10a).

Step 5: Provide information and training
  • Inform your employees why PPE is necessary and when it must be worn.
  • Train your employees how to use and care for the selected PPE and how to recognize PPE deterioration and failure.
  • Require employees to wear the protective equipment.
In general, retraining must be conducted if there are changes in the workplace or PPE. The OSHA respirator and hearing conservation standards require annual training.

REMINDER: Do you have procedures for cleaning protective equipment, including equipment that is not individually assigned, such as face shield and goggles?

Step 6: Document the training. Records must contain the name of the employee, the training date and the training subjects, including each item of PPE covered.

PPE From Head to Toe

PPE encompasses a range of items for the entire body, including hard hats, goggles, face shields, ear plugs, steel-toed shoes and respirators, among others.

Eyes and face
Eye and face protection should be provided when employees are exposed to dust and other flying particles. It is also indicated when employees are working around:
  • molten metal
  • liquid chemicals that might splash
  • injurious light radiation
  • blood and other infectious body fluid
Side shields are required on safety glasses when there is a hazard from flying objects. Protective eyewear must meet the requirements of ANSI standard Z87.1-1989.

Face shields must be worn with appropriate eye protection—they are not a substitute for eye protection.

The head
Provide head protection when there is a potential injury from falling objects, when employees might bump their heads against fixed objects such as pipes, and when they are working near exposed electrical conductors.

The three classes of helmets:
A. General service, limited voltage protection
B. Utility service, high voltage protection
C. Lightweight; limited protection. Protection from bumps, not falling objects or electrical shock. Protective helmets must meet the requirements of ANSI standard Z89.1-1986.

You must provide respiratory protection when the measured concentration of airborne contaminants exceeds the OSHA permissible exposure limit (PEL). The revised respiratory protection standard allows for the use of filtering face piece respirators (often referred to as dust masks) on a voluntary basis if there is no overexposure. Individuals involved in these situations do not need to be included in your respirator program. However, you must train them on the information contained in Appendix D of the standard (1910.134).

Hearing
Hearing protection is required when an employee's noise exposure exceeds an 8-hour time weighted average of 85 dB(A). A noise reduction rating (NRR) indicates how much the hearing protection reduces the noise reaching the inner ear (when tested in a laboratory). The NRR is typically adjusted to account for actual use of the protectors in the field. Therefore, the amount of noise reduction provided by a particular brand/model of hearing protection during actual use is significantly less than the stated NRR.

Feet, legs and hands
Foot and leg PPE provides protection from exposure to falling or rolling objects, objects that might pierce the sole, electrical hazards, and molten metal (welding sparks). Foot protection must meet the requirements of ANSI standard Z41-1991.

Hand protection is indicated when employees are exposed to hazards such as:
  • skin absorption of chemicals
  • severe cuts, lacerations, abrasions
  • punctures
  • chemical/thermal burns
  • temperature extremes
Note: Barrier creams are not an alternative to wearing gloves but they do provide an extra layer of skin protection. A good product will also moisturize the skin.

When working with chemicals, employees must be instructed to wash up after removing their protective gloves.

When selecting gloves for protection against chemical hazards you must use the manufacturer's selection charts and have this information on hand to document your decision logic.

Full body protection
Body protection must be provided when:
  • working around mobile earth moving equipment or exposed to vehicle traffic. (Workers should wear high visibility warning vests or other visibility garments. For work in darkness or low light conditions the protection equipment must be made or marked with retro-reflective material.)
  • there is a potential for contact with liquid chemicals (splashes)
  • there is exposure to intense heat or to low temperatures
  • when working at elevations greater than 6 feet. (Fall protection is required for construction activities; for non-construction activities, assess the situation for hazards and possible controls.)
Other hazards requiring full body protection include sparks, corrosive materials, molten metal, toxic dusts, vapors and gases, X-rays, and gamma radiation.
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