Training for Personal Protective Equipment
The Occupational Safety and Health Administration (OSHA) requires all employers to provide workplaces that are “…free from recognized hazards that are… likely to cause death or serious physical harm….”[OSH Act Sec. 5-The General Duty Clause]
One of the methods employers may have to implement to protect employees from serious hazards is the use of personal protective equipment, or PPE. Under the general PPE requirements, the employer is required to assess the workplace to determine if hazards are present. When serious hazards are present that cannot be eliminated from the workplace or cannot be sufficiently mitigated by engineering or administrative controls, PPE becomes a worker’s primary defense against workplace hazards. [29 CFR 1910.132(d)]
There are many kinds of PPE; some of the most common include: safety glasses, face shields, hard hats, and work gloves and boots. More specialized PPE, such as dark lenses for welding or environmental suits for hazardous atmospheres, may be necessary to protect against the more unique hazards. For some types of PPE, OSHA’s General Industry Standards impose specific requirements for when and how the equipment must be used. PPE for which specific requirements exist include: eye and face protection (29 CFR 1910.133), respiratory protection (29 CFR 1910.134), head protection (29 CFR 1910.135), foot protection (29 CFR 1910.136), and hand protection (29 CFR 1910.138). For other types of PPE, such as non-construction-related fall protection equipment, the General Industry Standards do not list specific requirements, subjecting them instead to the general minimum requirements at 29 CFR 1910.132.
General PPE Training Requirement
Whether the selected PPE is subject to a specific OSHA standard or not, training is an obligation for all selected PPE. The general rules state that for each type of PPE the employee is required to wear, the employer must train the employee regarding the following:
- When PPE is necessary;
- What PPE is necessary;
- How to properly don, doff, adjust, and wear PPE;
- The limitations of the PPE; and
- The proper care, maintenance, useful life, and disposal of the PPE.
It is implicit in these requirements that the training also discusses “why” the PPE is necessary, i.e. from what hazard or hazards the PPE is protecting the employee.
Employee Qualifications and Retraining
Before an employer can allow an employee to use PPE, the employee must demonstrate:
- An understanding of the required elements of training, and
- An ability to use the PPE properly.
Retraining is not required at particular intervals, but is necessary whenever:
- Employees who have been trained demonstrate that they do not have an understanding of the required elements of training or show an inability to use PPE properly; or
- Changes in the workplace, or the type(s) of PPE in use, render previous training obsolete.
Special Rules for Respirators
The respirator standard includes its own detailed training standard at 29 CFR 1910.134(k). In addition to respirator-specific requirements for why, when, and how to wear respirators, the standard does specify annual retraining and also requires additional training whenever an employee changes respirator type or whenever the employer has any indication that the employee has not retained the necessary knowledge and skill in proper use and care.
Ensure your personnel are prepared to protect themselves from the hazards in your workplace. The 10-Hour OSHA General Industry Online Course is a convenient, effective way to get your team the training they need. Topics covered include PPE use and maintenance, hazard communication, electrical safety, materials handling, hearing protection, and more.
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