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Health & Safety is a lifestyle.

Person Protective Equipment (PPE)

1/3/2016

2 Comments

 
Person Protective Equipment & Requirements
By Christina Keyes, Keyes To Safety LLC

OSHA requires the use of personal protective equipment (PPE) to reduce employee exposure to hazards when engineering and administrative controls cannot provide protection by reducing exposure(s) to permissible limits.  Employers must determine if PPE should be used to protect their workers by completing a Job Hazard Analysis.  PPE programs must be implemented addressing standard PPE requirements along with special situation requirements.

PPE that may be required:
Head Protection
  • Workers must wear hard hats when overhead, falling, or flying hazards exist or when danger of electrical shock is present.
  • Inspect hard hats routinely for expiration date, dents, cracks, or deterioration.
  • If a hard hat has taken a heavy blow or electrical shock, you must replace it even when you detect no visible damage.
  • Maintain hard hats in good condition; do not drill; clean with strong detergents or solvents; paint; or store them in extreme temperatures. More than 3 stickers is an offensive to stability and is a violation by OSHA.
  • Do not wear your hard hat backwards unless specifically approved by the hard hat manufacturer and your employer, must have ANSI stamp designating it to be reverse fitting (typically used by welders)
Eye and Face Protection
  • Workers must wear only ANSI approved safety glasses, face shields or goggles for welding, cutting, nailing (including pneumatic), or when working with concrete and/or harmful chemicals and to protect against flying particles. Look for Z87 stamped on the frames.
  • Eye and face protectors are designed for particular hazards. Be sure to select the proper type to match the hazard that is present.
  • Always replace poorly fitting or damaged safety glasses as soon as possible.
  • Workers needing corrective lenses must either wear ANSI approved safety glasses with prescription lenses and frames or wear ANSI approved goggles designed to be worn over their regular prescription glasses.
Foot Protection
  • Employers may designate for workers to wear shoes or boots with slip-resistant and puncture-resistant soles to prevent slipping and puncture wounds.
  • Safety-toed shoes are recommended to prevent crushed toes when working with heavy rolling equipment or falling objects.
  • Chemical resistant shoes or NFPA rated boots may also be mandated.
 
Hand Protection
  • High-quality gloves can prevent injury. Make sure that gloves should fit snugly.
  • Always inspect gloves for cuts, tears and discoloration that might indicate excessive wear.
  • Hands must be clean before putting gloves on and always thoroughly clean glove exteriors before removing them.
  • Glove gauntlets should be taped for working with fiberglass materials.
  • Workers should always wear the right gloves for the jobs (for example, heavy-duty rubber for concrete work, welding gloves for welding). Check the Safety Data Sheet (SDS, formerly called MSDS) for detailed information.
  • Never use petroleum-based products (Vaseline) under gloves. They can trap chemicals against your skin if they get into your gloves
Fall Protection
  • Use a safety harness system for fall protection.
  • Where fall prevention cannot be installed, use a “personal fall arrest system” (PFAS). A PFAS includes an anchorage, full body harness, and connector such as a lanyard or lifeline.
  • A PFAS must be rigged to limit falls to 6 feet or less without contacting any lower level and limit the arresting forces on the worker to 1,800 pounds or less.
  • PFAS components, including safety harnesses, should be inspected before each use for wear, damage and other deterioration.
  • PFAS should be designed, installed, and used, under the supervision of a qualified person.
Body Protection:
  • Clothing to protect the body should consist at a minimum of long work pants and a sleeved shirt. When hazardous liquids, gases, vapors, fire/spark, or debris are present, the level of protection needed increases. This may include garments of Tyvek, Nomex, or PVC.
  • For jobs that leave clothes very contaminated, bring a set of clean clothes to change into at the end of the day. Wash contaminated clothing separately.
Hearing Protection:
  • Wherever it is not feasible to reduce the noise levels or duration of exposures, ear protective devices shall be provided and used. Ear protective devices inserted in the ear shall be fitted or determined individually by competent persons.
Respiratory Protection
  • Select the correct respirator based on the hazard.
  • Inspect the respirator for missing or worn respirator parts.
  • Depending on the type of respirator, the employee must be medically cleared, trained and respirator fit tested prior to respirator use.
  • Do not share respirators and only use the respirator that you have been fitted for.
 
To maintain quality of PPE:
  • Maintain PPE in a clean sanitary, serviceable condition.
  • All items have expiration periods, please check dates of expiration/manufacturing against the Manufacturer’s recommendations.
  • Replace PPE if showing signs of wearing, cracking, chipping, fading, instability, or any form of misuse.
  • Make sure to have PPE meet applicable recognized performance standards, such as ANSI, National Institute for Occupational Safety and Health, Mine Safety and Health Administration, etc.
 
Do Not:
  • Do not use PPE in lieu of sound engineering and manufacturing practices.
  • Do not use PPE without proper training in its use and limitations.
  • Do not use damaged or inferior equipment.
2 Comments
Patricia
2/10/2016 01:15:03 am

I noticed in your article you've mentioned that "...More than 3 stickers is an offensive to stability and is a violation by OSHA.". I've been scouring the OSHA website and I can't find it being referenced in there. Would you point me to the source of that information? Appreciate it a lot. Cheers.

Reply
Christina @ Keyes To Safety LLC
2/10/2016 08:06:41 am

The 29 CFR 1910.132 and 1910.135 do not contain provisions that explicitly prohibit adhesive stickers on hard hats; however, the employer’s ability to comply with the existing requirements of these standards may be adversely affected by not regulating the use of stickers.

In a letter of interpretation from Federal OSHA to Ms. Johanna Cohan in October 27, 2009, OSHA makes the following statements:
The letter goes on to reference 29 CFR 1910.132(a) which requires that PPE be “maintained in a sanitary and reliable condition”.

In the letter it states to ensure a "helmet" is, and remains, in a “reliable” condition, the helmet must be inspected prior to use for signs of dents, cracks, penetration, and any damage due to impact, rough treatment, or wear that might reduce the degree of protection originally provided, and used and maintained in accordance with the manufacturer’s instructions. Application of stickers can eliminate electrical resistance and – depending on the location and quantity – conceal defects, cracks, penetration, and any damage that would be otherwise readily identifiable during the employee’s inspection to ensure reliability.

OSHA then goes on to state “For these reasons, painting or applying stickers must be performed in accordance with the manufacturer’s instructions, unless the employer can demonstrate that the altered protective helmet is equally as effective and protective as those meeting the requirements of Z89.1”.

OSHA falls just short of saying “no” and basically puts it back on the manufacturer as to whether paint and/or stickers are acceptable. The ANSI standard does mention the above points in whether or not stickers should be applied and says that if for identification purposes "adhesive stickers and paint" should not be placed within one inch of the brim.

Most manufacturers will agree that the adhesive used on stickers and the oils used in paints weakens the shell making the PPE unreliable. I have personally been involved with OSHA Inspectors and they interpret unnecessary, ill-placed, and over use of stickers and paint a violation of safety and the use of PPE. It has been commonly stated on-site's that more than "3 stickers" is a willful violation. Remember that the OSHA Regulations are interpreted differently by different people and most definitely topics such as this will need to be tested and proved if in question, and documentation from the manufacturer is also recommended to have handy. I say that it is better to be cautious and aware of the interpretations, throwing caution to the wind and allowing safety to be compromised over stickers is ill-advised.

Good luck in your safety endeavors!

Christina

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