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Workplace Safety Should Be More Than Just PPE

Posted on 4/3/2012 by James Griffin

The Occupational Safety and Health Administration (OSHA) requires all employers to assess the workplace for hazards and to provide proper personal protective equipment (PPE) to their employees whenever hazards are present, or are likely to be present. [29 CFR 1910.132(d)]
 
A “hazard” is any process, environment, chemical, radiation, or mechanical irritant that can injure or impair any part of the body through physical contact, absorption, or inhalation. “Personal protective equipment” means safety glasses, helmets, boots, gloves, respirators, and any other similar equipment. [29 CFR 1910.132(a)]
 
OSHA always recommends that, before an employer considers using PPE to mitigate workplace hazards, the employer attempt to remove the hazard from the workplace or reduce the risk to employees. Employers can mitigate hazards through engineering controls, safe work practices, and/or administrative controls. Some OSHA standards, like the Bloodborne Pathogens Standard, specifically require employers to use other means before considering PPE. [29 CFR 1910.1030(d)(2)].
 
Engineering Out Workplace Hazards
“Engineering controls” means that the employer attempts to remove the hazard from the workplace. For example, any time you replace a hazardous chemical with a non-toxic, less caustic, or otherwise inherently safer alternative, you are engineering out the hazard of the chemical by removing it from the workplace.
 For hazardous processes and environments, engineering controls also include the use of barriers, enclosures, and other means to limit or prevent employee exposure to the hazard. Paint booths or other well ventilated enclosures in which employees handle volatile chemicals are a good example of this kind of control.
 
Safe Work Practices
If after an employer has used engineering controls there are still hazards in the workplace, the next step is to implement safe work practices. A safe work practice is any rule of conduct intended to protect employees from hazards. A good example of a safe work practice is “nobody goes within 5 feet of the 8,000-degree kiln without authorization.”
For many operations, it may be necessary to combine work practices with engineering controls. A proximity rule to limit access to a hazard can be combined with a barrier or even a colored string or painted line marking the 5-foot limit, to prevent physical contact with the hazard.
 
Administrative Controls
Lastly, before considering PPE, come administrative controls. While safe work practices are a type of administrative control, the term also includes any other measure that reduces employee exposure to hazards. For instance, maybe you have noise-producing machinery. You may decide that in addition to relocating the noise-producing machine away from the employees (engineering controls) and instructing employees not to approach the noise hazard unless required (safe practices), to also rearrange work schedules to reduce the time each worker spends in the noisy area and/or to implement a maintenance schedule (proper maintainence reduces the noise levels). These last two are examples of non-work practice administrative controls.
 
Personal Protective Equipment: The Last Line of Defense
Once employer’s have done their best to address the hazards of the workplace with engineering and administrative controls, if any hazards still exist, then they can consider PPE. This of course leads to additional rules for selecting, providing, maintaining, inspecting, properly fitting, and properly using the equipment.
 
The most effective way to ensure workplace safety procedures is to provide comprehensive safety training. Lion Technology’s 10 Hour OSHA General Industry Online Course uses expert instruction, exercises, and tutorials to prepare students to identify, avoid, control, and prevent workplace hazards at any general industry site—and how to select and use the proper Personal Protective Equipment.
 

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