Is PPE Your Last Resort for Workplace Safety?

Posted on 8/2/2016 by Lee Ann Coniglione

Today, American workplaces are safer than ever, but US employers still face challenges when it comes to controlling workplace hazards.

All kinds of everyday materials, processes, and operations can pose a workplace hazard to your employees—chemicals, machinery, trip-and-fall hazards, and more found in indoor and outdoor work environments. Because these hazards are so varied in nature and can pose serious risk to workers, OSHA has established several Personal Protective Equipment (PPE)–related standards to cover hazards of different types and severity. OSHA's General Requirements Standard addresses the overall elements of an employer-sponsored PPE program. In addition, the Agency enacted similar standards having to do with protecting specific body parts from occupational hazards.

The majority of the PPE standards are found in 29 CFR 1910, Subpart I. We'll start by taking a look at how OSHA organizes this collective grouping of standards:
  • 1910.132 - General Requirements
  • 1910.133 - Eye and Face Protection
  • 1910.134 - Respiratory Protection
  • 1910.135 - Head Protection
  • 1910.136 - Foot Protection
  • 1910.137 - Electrical Protective Devices
  • 1910.138 - Hand Protection
Although not found in Subpart I, another standard that fits into this grouping is the Occupational Noise Exposure Standard, found in 29 CFR 1910.95, Subpart G. It sets the requirements for managing noise hazards in the workplace, including several PPE program elements related to hearing protection.

Many other OSHA standards include provisions for PPE as well. For example, the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard has a relatively large PPE component to it. For now, though, we will focus on the general requirements for implementing a PPE program.

OSHA's Hierarchy of Controls

We know that PPE is used to protect employees from hazards that can cause injury or illness through any one of several routes of exposure (e.g., contact, absorption, inhalation, injection). Before we move on with our discussion, let's look at where PPE ranks in terms of hierarchy of controls. Although certainly widespread throughout many workplaces, PPE is actually the least preferred method for controlling hazards. In fact, it occupies the last spot on the list of controls:
  1. Substitution/elimination
  2. Engineering controls
  3. Administrative and work practice controls
  4. Personal Protective Equipment
This means OSHA considers PPE to be the last resort for workplace safety. If the hazard cannot be removed from the workplace or engineered out through mechanisms, and employee exposure to the hazard cannot be mitigated by work practices, then, and only then, should the employer consider PPE for employees.

Elements Related to PPE Program Administration

Hazard Assessments

If in fact PPE has been determined to be the most feasible course of action to protect employees from job hazards, then a comprehensive hazard assessment must be performed by the employer. The hazard assessment should be focused on identifying hazards that are present or likely to be present in the workplace.

Going through the hazard assessment process is crucial. The information gathered during this phase will enable employers to make informed decisions about when there is a legitimate need for PPE.

Selecting PPE for (and With!) Employees

Two of the most basic goals of any PPE program likely have to do with providing employees with an adequate level of protection as well as supplying them with equipment they will actually wear. While the latter may sound a bit like a no brainer, it can be a challenge to achieve full PPE compliance, particularly when employees are not involved in the selection process. Employees may decide not to wear their PPE for many reasons—maybe it doesn't fit properly; it's too hot or otherwise uncomfortable; it interferes with items already worn on the face, such as eyeglasses or safety glasses; or it slows them down. Again, all of these reasons (and more) reinforce why employees should be included and have a voice in the selection process.

The Written PPE Certification

As stated in OSHA's PPE Standard, part of the hazard assessment and equipment selection process requires that employers provide written certification that the required workplace hazard assessment has been performed. In terms of guidance, OSHA provides a template document in the form of Appendix B to Subpart I. In it, employers will find the steps of the hazard assessment process outlined, in addition to some PPE recommendations when considering protection for various parts of the body.

Training Employees on PPE Selection, Fit, Wear, and Care

Aside from the hazard assessment and equipment selection processes, another significant component of the general requirements is training. Employers are expected to train their employees to an adequate level at which they are able to recognize when PPE is necessary, what PPE is necessary, how to properly put on and remove their PPE, and how to wear and make adjustments to it. Employees must also be trained to know about the limitations of PPE, as well as how to properly care for and dispose of it.

While a few specific standards do mandate annual training on PPE use (e.g., Respiratory Protection at 29 CFR 1910.134 and Hearing Conservation at 29 CFR 1910.95), general use PPE does not require repeat training on a regular basis. However, following initial training, employees may need retraining in the event that there are changes in the workplace, such as the introduction of new hazards or new types of PPE.

Follow-up PPE training would also be necessary in the event employees were to behave in a manner indicating they do not know how to properly wear the assigned PPE or otherwise failing to comply with the employer's PPE policy.

Who Pays for PPE?

Once an employer determines that PPE is necessary to protect employees from hazards in the workplace, the next question is: Who pays for it?

OSHA does allow employees to provide and use their own protective equipment, though this is more likely to be the exception than the rule. In general, employers are responsible for purchasing, providing, and maintaining PPE, as well as any associated costs that are incurred as part of a medical surveillance program.

As mentioned earlier, payment for protective equipment is also addressed in the General Requirements Standard, and with limited exception, PPE "shall be provided by the employer at no cost to employees." [29 CFR 1910.132(h)(1)]

When Is the Employer NOT Required to Pay for PPE?

The following list addresses those limited exception scenarios in which the employer is NOT required to pay the cost of PPE:
  • Non-specialty safety-toe protective footwear (including steel-toe shoes or steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job site
  • When the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection, the employer is not required to reimburse the employee for the shoes or boots
  • Logging boots required by 29 CFR 1910.266(d)(1)(v)
  • Everyday clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots
  • 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
  • Replacement PPE when the employee has lost or intentionally damaged the PPE
  • Where an employee provides adequate protective equipment he or she owns, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment
So, in summary, the employer cannot require an employee to provide or pay for his or her own PPE, unless the PPE falls into one of the aforementioned bulleted scenarios. To learn more about OSHA's General Requirements Standard for PPE, and other related standards, click here.

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