Personal Protective Equipment Program

If PPE is to be used to reduce the hazards, a PPE program will be developed. The program will contain:

• Identification and evaluation of workplace hazards
• PPE selection, maintenance, and training procedures
• PPE evaluation and effectiveness procedures

PPE should not substitute engineering, work practice, and/or administrative controls. PPE should be used with these controls to provide employee safety and health at work. PPE includes all clothing and other accessories designed to create a barrier against workplace hazards.

Using PPE requires the user to be trained and aware of hazards. Employees must know that equipment does not eliminate the hazard. If the equipment fails, exposure will occur. To reduce failure, equipment must be fitted and maintained in a serviceable condition.

Selecting the proper PPE for a job is important. Everyone must understand the equipment’s purpose and limitations. The equipment must not be altered or removed if an employee finds it uncomfortable.

Hazard Assessment

Assess the workplace to determine potential hazards that require the use of PPE. If hazards are found, employers must select and have affected employees use properly fitted PPE suitable for protection from these hazards.

Note: Respirators, hearing protection, and rubber insulating equipment are considered PPE. However, because OSHA has specific requirements for them, they are not discussed here.

During the hazard assessment survey, identify hazards that require using head, eye, hearing, face, hand, and/or foot protection. Potential hazards to look for are:

• Impact – chipping, grinding, machining, masonry work, woodwork, sawing, drilling, chiseling, powered fastening, riveting
• Penetration – sharp objects that can penetrate the skin: nails, knives, saws
• Compression – construction, plumbing, smithing, building maintenance, trenching, utility work, moving equipment operations (powered industrial trucks, lawn equipment, etc.)
• Hazardous chemical exposures – pouring, mixing, painting, cleaning, siphoning, dip tank operations, dental and health care services
• Heat – welding, pouring molten metal, smithing, baking, cooking, drying
• Light radiation – welding: electric arc, gas, cutting, torch brazing, soldering, glare
• Electrical hazards – building and tool maintenance, utility work, construction, wiring, computer and arc or resistance welding
• Harmful dusts – sawing, drilling, sanding, abrasive blasting, grinding

Employers must certify that a workplace hazard assessment has been performed and recorded.

Choosing PPE

Select equipment that provides protection greater than the minimum required to protect employees from the hazards. Remember to consider comfort and fit. PPE must fit properly to be effective. If the protective gear does not fit, it may not adequately protect the worker. Employees are more likely to continually wear PPE if it fits comfortably. PPE is generally available in many sizes. Take care to choose the correct size. Defective or damaged PPE shall not be used.

Training

Before doing work requiring PPE, employees must know:

• When PPE is necessary and what type is needed based on the job
• How PPE should be worn – don, adjust, doff, wear
• The limitations, proper care, maintenance, useful life, and proper disposal of PPE

Employees must demonstrate an understanding of the required training and the ability to use PPE properly before performing work requiring PPE. Employers must certify training has been carried out and that employees understand and demonstrate the proper PPE use. Retrain if the employee does not have the required skill and understanding. All certification shall contain the name of each employee trained, training dates, and the subject certified.

PPE EQUIPMENT HAZARD ANALYSIS

To meet OSHA requirements (29 CFR 1910.132) and maintain a safe working environment, you must analyze the potential job hazards.

Instructions

1. Identify the job titles for all people within your department.
2. Make copies of the PPE hazard analysis form so each job is represented on a separate form.
3. Enter the name of your department.
4. Enter the job title to be analyzed.
5. Enter the location or area of the facility that the person performs the activities or tasks. 
6. Enter your name after “Analysis done by."
7. Enter the date of the analysis.
8. List the activities or tasks that the person is required to perform. 
9. Use the hazard key to identify all potential hazards associated with each task. Enter the hazard numbers in the area corresponding to the task. Use a separate line for each hazard.
10. Use the body part key to identify the body part that would be exposed to each hazard. If more than one body part has hazard exposure, list all parts. Enter the body part letters in the area corresponding to the hazard.
11. Use the PPE required key to identify the PPE required for each hazard listed.

Employee-Owned PPE

Where employees own their own PPE, the employer is responsible to ensure its adequacy, including proper maintenance, and sanitation of such equipment. Where an employee provides adequate protective equipment they own, the employer may allow the employee to use it and is not required to reimburse the employee for that equipment.

Payment for Protective Equipment

Protective equipment, including PPE, used to comply with this part, shall be provided by the employer at no cost to the employee. The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE.

Exceptions

1. The employer is not required to pay for non-specialty safety-toe protective footwear (including steel-toe shoes and steel-toe boots) and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site.
2. 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.
3. Logging boots,
4. Everyday clothing (long-sleeved shirts, long pants, street shoes, and normal work boots).
5. 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.

Employee-Owned PPE

General Requirements

1. The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquid, chemical gases or vapors, or potentially injurious light radiation.

2. The employer shall ensure that each affected employee uses eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors meeting the pertinent requirements of this section are acceptable.

3. The employer shall ensure that each affected employee who wear prescription lenses while engaged in operations that involve eye hazards wears eye protection that incorporates the prescription in its design, or wears eye protection that can be worn over the prescription lenses without disturbing the proper position of the prescription lenses or the protective lenses.

4. Eye and face PPE shall be distinctly marked to facilitate identification of the manufacturer. 

5. The employer shall ensure that each affected employee who uses equipment with filter lenses that have a shade number appropriate for the work being performed for protection from injurious light radiation. 

6. Prior to each use, protective eye and face equipment shall be checked for cracks, scratches, and other deformities that may compromise the protective value of the glasses.

Criteria for Protective Eye and Face Protection

Protective eye and face protection devices must comply with any of the following consensus standards. Protective eye and face protection devices that the employer demonstrates are at least as effective as protective eye and face protection devices that are constructed in accordance with one of the above consensus standards will be deemed to be in compliance with the requirements below.

1. ANSI/ISEA Z87.1 – 2010, Occupational and Educational Personal Eye and Face Protection Devices
2. ANSI Z87.1 –  2003, Occupational and Educational Personal Eye and Face Protection Devices
3. ANSI Z87.1 – 1989, Practice for Occupational and Educational Eye and Face Protection

Head Protection

General Requirements

1. The employer shall ensure that each affected employee wears a protective helmet when working in areas where there is a potential for injury to the head from falling objects, bumps to heads against fixed objects, or if there is a possibility of accidental head contact with electrical hazards.

2. The employer shall ensure that a protective helmet designed to reduce electrical shock hazard is worn by each affected employee when near exposed electrical conductors which could contact the head.

3. Protective helmets or hard hats should do the following: resist penetration by objects, absorb the shock of a blow, be water-resistant and slow burning, and have clear instructions explaining proper adjustment and replacement of the suspension and headband.

4. Hard-hats must have a hard outer shell and a shock-absorbing lining that incorporates a headband and straps that suspend the shell from 1 to 1¼ inches away from the head.

5. Protective head gear accessories (earmuffs, safety glasses, face shields, mounted lights, etc.) must not compromise the safety elements of the equipment.

6. A daily inspection of the hard hat shell, suspension system and other accessories for holes, cracks, tears, or other damage that may compromise the protective value of the hat is essential.

7. Paint, paint thinners and some cleaning agents can weaken the shell of hard hats and may eliminate electrical resistance.

8. Never drill holes, paint or apply labels to protective headgear as this may reduce the integrity of the protection.

9. Do not store protective headgear in direct sunlight

10. Always replace a hard hat if it sustains an impact, even if damage is not noticeable

11. Suspension systems are offered as replacement parts and should be replaced when damaged or when excessive wear is noticed. It is not necessary to replace the entire hard hart when deterioration or tears of the suspension system are noticed.

Types of Hard Hats

1. Class A hard hats provide impact and penetration resistance along with limited voltage protection (up to 2,200 volts).

2. Class B hard hats provide the highest level of protection against electrical hazards, with high-voltage shock and burn protection (up to 20,000 volts). They also provide protection from impact and penetration hazards by flying/falling objects.

3. Class C hard hats provide lightweight comfort and impact protection but offer no protection from electrical hazards.

4. A bump hat is designed for use in areas with low head clearance, but are not designed to protect from falling or flying objects.

Head Protection Criteria

Head protection must comply with any of the standards below. Head protection devices that the employer demonstrates are at least as effective as head protection devices that are constructed in accordance with one of the standards will be deemed to be in compliance with the requirements of this section.

1. ANSI Z89.1 – 2009, American National Standards for Industrial Head Protection

2. ANSI Z89.1 – 2003, American National Standards for Industrial Head Protection

3. ANSI Z89.1 – 1997, American National Standards for Personnel Protective Headwear for industrial Workers.

Foot Protection

General Requirements

1. The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures.

2. Employees working in explosive and hazardous locations must wear conductive shoes to reduce the risk of static electricity buildup on the body that could produce a spark and cause an explosion or fire.

3. Electrical hazard safety toe shoes are non-conductive and will prevent the wearers feet from completing an electrical circuit to the ground.

4. Safety footwear should be inspected prior to use. This includes looking for  cracks or holes, separation of materials, broken buckles or laces, and ensure sole is in good shape and does not contain pieces of metal or other items that could present electrical or trip hazards.

Criteria for Protective Footwear

Protective footwear must comply with the following consensus standards. Protective footwear that the employer demonstrates is at least as effective as protective footwear that is constructed in accordance with the standards will be deemed to be in compliance with the minimum requirements.

1. ASTM F-2412-2005, “Standard Test Methods for Foot Protection,” and ASTM F—2413-2005, “Standard Specification for Performance Requirements for Protective Footwear.

2. ANSI Z41 – 1999, “American National Standard for Personal Protection – Protective Footwear.

3. ANSI Z41 – 1991, “American National Standard for Personal Protection – Protective Footwear.

Hand Protection

General Requirements

1. Employers shall select and require employees to use appropriate hand protection when employee’s hands are exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns, and harmful temperature extremes.

2. The selection of appropriate hand protection shall be based on an evaluation of the performance characteristics of the hand protection relative to the task to be performed, conditions present, duration of use, and the hazards and potential hazards identified.

3. Protective gloves should be inspected prior to each use to ensure that they are not torn, punctured, or made ineffective in any way. Gloves that are discolored or stiff may also indicate deficiencies caused by excessive use or degradation from chemical exposure.

Hazard Analysis Worksheet - SAMPLE