>Argus Group Application Notes

PPE Hazard Assessments

Suggestions to Simplify Compliance with OSHA’s 1910.132 (d)

Employers of all types and sizes have found significant challenges in complying with the revised 1995 OSHA Subpart I - Personal Protective Equipment Rule (1910.132(d)). Previous to this revision, the methods for selecting, fitting, inspecting and implementing the use of PPE were largely left to the employer’s discretion. This article offers suggestions for employers attempting to select the PPE for their employees based on the required assessment of the hazards in the workplace, and those which employees are most likely to encounter.

OSHA has determined that workers involved in a wide range of occupations are exposed to a significant risk of death or injury from being struck by various objects in the workplace. Incident data indicate that a significant portion of all work related injuries and fatalities involve workers being struck in the eyes, head, face, hand, and/or feet by foreign objects. For example, it has been estimated that as many as 2,500 eye injuries occur in the workplace every working day. One study determined that there were 333,272 reported occupational eye injuries for 1985. Another study, pertaining to disabling injuries, estimated that there were 320,000 hand and finger injuries, 70,000 eye injuries, 70,000 head and face injuries, and 110,000 foot and toe injuries in 1987. These injuries constituted 31.7 percent of the estimated 1,800,000 total disabling work injuries for 1987. These examples illustrate the magnitude of the hazards to which employees are exposed.

Bureau of Labor Statistics (BLS) Work Injury Reports (WIR) on eye, face, foot, head and hand injuries examine cases where a worker has been injured. These reports have identified two major causative factors: Personal protective equipment was not being worn the vast majority of the time; and, when protective equipment was worn, it did not adequately protect the worker. One study indicated that 70% of the workers experiencing hand injuries were not wearing gloves. The remaining 30% of the workers with hand injuries were wearing gloves, however the injury was caused by the gloves being either inadequate, damaged, or the wrong type for the hazard encountered.

Figure 1 - 1994 Federal OSHA Enforcement Data

A hazard assessment is an important element of a PPE program because it produces much of the information needed to select the appropriate PPE for the hazards present or likely to be present at particular workplaces. Paragraph (d) of the revised PPE rule clearly indicates that the employer is accountable for both the quality of the hazard assessment and for the adequacy of the PPE selected. Paragraph (d) is a performance-oriented provision which simply requires employers to use their awareness of workplace hazards to enable them to select the appropriate PPE for the work being performed. The PPE requirement mirrors others established by OSHA which require assessments of employee exposures to assist in the selection of appropriate protective equipment (i.e.: respiratory and hearing protection).

Some form of written verification is needed to provide compliance officers and affected employees with appropriate assurance that the required hazard assessment has been performed. OSHA has addressed similar situations in other rulemakings by requiring employers to verify compliance through a written certification. For instance, OSHA has required certification of training in the Permit-Required Confined Space standard, 1910.146(g)(4); the Control of Hazardous Energy (lockout/tagout) standard, 1910.147(c)(7)(iv); and in the Telecommunications standard, 1910.268(c). The Agency believes that a written certification is a reasonable means by which to establish accountability for compliance. Therefore, employers can verify compliance with 1910.132(d) through a written certification which identifies the workplace evaluated; the name of the person making the certification; the date(s) of the hazard assessment; and identifies the document as a certification of hazard assessment.

In Michigan, MIOSHA requires that the PPE assessments address Head, Eye/Face, Hand, Foot and Body Protection requirements as well as Electrical Protective and Fall Protection Equipment (Safety Belts, Safety Harnesses, Lifelines & Lanyards). Comprehensive and properly conducted hazard assessments can aid not only in the proper selection of equipment, but in fitting and sizing equipment to personnel. Involving the affected employees in the hazard assessment and selection process may also improve worker acceptance through their involvement in the decision-making for selecting the equipment issued them. These assessments also produce useful information for establishing learning objectives for subsequent employee training sessions.

Information sources to consider when conducting a hazard assessments

Challenges to Proper Equipment Selection

Today, more workers are employed in jobs requiring PPE for new and more diverse hazardous work conditions. Increased employment levels in the service sector has often resulted in more employees working independently, without direct supervision. Efforts over the last forty years have resulted in the recognition of most of the prevalent long-duration exposure situations, while the contribution of short-duration exposures to employee injury incidence is becoming a significant issue, resulting in intermittent conditions which are more difficult to observe and overcome.

The recognition of bloodborne pathogens causes many healthcare providers, EMT’s and Fire/Police personnel to begin using PPE for universal precautions; thus, expanding the pool of employees to include professionals not previously considered to require protection. Shifts in compliance efforts from general industry towards construction has resulted in an increased emphasis on the need for enhanced protection of construction trades persons from Fall and PPE related hazards.

Businesses are increasingly becoming more oriented towards global competition. This has resulted in significant organizational changes which often have eliminated many experienced managers familiar with the applications for PPE. This shift has also resulted in fewer safety and occupational health professionals involved in decision-making, and thus in less experience being available for the selection process.

Continued advances in materials and manufacturing methods have resulted in a wider variety of designs and choices for protective equipment and apparel. These factors further complicate the process of proper PPE selection at a time when continuing expansion in the equipment manufacturing base increases the variety of designs, number of suppliers, and variety of services the employer will need to choose from.

Conducting the Walk-through Assessment

While conducting the walk-through phase of a hazard assessment there are several recommendations which may prove helpful in ensuring that all potentially hazardous work tasks are being considered. Attention should be placed on work tasks where employees are involved in exposures which may prove hazardous, and to those tasks which are not easily observable. Examples of these intermittent tasks would include work cell or die set-up and preventative maintenance or repair activities. In the first case the observer is weighting the focus of his attention toward the frequency of a task or on the distribution among the potentially exposed work force. In the later case the observer is weighing the effect of unforeseen consequences which could occur due to the intermittent nature of these repair situations. Often the responsive nature of these work situations prohibits the effective planning required to ensure the tasks are conducted safely and with the appropriate PPE.

The observers involved in this phase of the hazard assessment should attempt to identify potential hazards which might be present due to the observable sources of motion (lifting, rolling, bending, compressing, etc.). Processes which either consume or release energy should be observed (inductive heating, resistance welding, gas cutting, heat treating or quenching, cryogenic cooling, etc.). Where contaminants must be eliminated prior to final manufacturing stages, observers should consider the hazards produced by parts cleaning operations (vapor degreasing, alkaline dip, water spray, etc. )

The next issue to consider during the walk-through assessment is the variations which occur as a result of process changes with respect to changing raw materials or with ergonomic concerns caused by different employees doing the same task (i.e. - Will the type or number of hazards produced by this process vary under the dynamic conditions of production?, Do second shift personnel perform this task in the same manner as first shift employees?).

One of the most critical variables for the observer to record is the size, gender, and variability of the employee population which may be required to utilize PPE. As fit is the most critical issue in addressing worker acceptance, these considerations will be important in selecting the appropriate type of PPE. Also important is information on what, if any, PPE was observed being used by employees. Questions should be asked regarding how often PPE is being replaced or disposed of, and where replacement items may be obtained.

Suggestions for Identifying Protective Equipment Needs

1. Define the population of workers to be protected - Describe what objectives the protective equipment should achieve when selected properly.
2. Describe the range of personnel attributes covered by the equipment need (Sex/Age/Education/Anthropometrics).
3. Determine the duration for expected or required equipment use.
4. Establish equipment reuse limitations and consider recycling alternatives.
5. Select all possible protective equipment choices which may achieve these objectives.
6. Use several catalogs for developing an understanding of equipment variety and sizing criteria.
7. Review guides such as Best’s Safety Directory (A.M. Best Company, Inc., Oldwick, N.J., 201-439-2200) for lists of equipment manufacturers. These guides maybe available at a college library or through local safety organizations such as regional chapters of the National Safety Council.
8. Eliminate those equipment designs which haven’t the intended protective characteristics or design features to satisfy the objectives.
9. Consider various local and national sources for equipment procurement.
10. If available visit a local equipment showroom or contact a distributors - these companies often provide useful assistance in the evaluation of protective products, their selection and actual user training.
11. Try to secure samples before you buy. Evaluate the range of sizes required for the affected employees.
12. Conditional or Trial Purchases are often available from suppliers. Negotiate with your suppliers for best price/service.
13. Record how PPE was distributed during evaluations. Collect as many formal responses from equipment users to determine worker acceptance and establish whether the objective of the protective equipment needs to be redefined.
14. Customized equipment and clothing designs for special applications are often available and may offer the best compromise between performance and cost effectiveness. Just because there may not be an out-of-the-box solution for your problem doesn’t mean that creative solutions can’t be found. Ask, ask, ask again .... does this meet the objective I set out to achieve?

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