The following is an excerpt from the GAWDA Safety Organizer, a monthly bulletin sent to GAWDA members. For more information on the GAWDA Safety Organizer, or to read past issues, visit the GAWDA.org Members-Only Section
Hazards exist everywhere: Viruses, noise, chemicals, falling objects, slippery surfaces/uneven surfaces and sharp objects. Employers are required by regulation to protect employees from known and potential hazards in the workplace. The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health (OSH) Act of 1970, 29 USC 654(a)(1), requires employers to furnish to each worker “employment and a place of employment, which are free from recognized hazards that are causing or are likely to cause death or serious physical harm.”
Employers can be cited for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard. The General Duty Clause is used only where there is no standard that applies to the particular hazard. The following elements are necessary to prove a violation of the General Duty Clause:
The employer failed to keep the workplace free of a hazard to which employees of that employer were exposed;
- The hazard was recognized;
- The hazard was causing or was likely to cause death or serious physical harm; and
- There was a feasible and useful method to correct the hazard.
- There is a Hierarchy of Controls to “Correct the hazard.”
1st – Eliminate the Hazard: a cylinder cart has a flat tire. Eliminate the hazard, change the tire.
2nd – Substitute the Hazard: change a cleaning agent from a caustic solution that requires dilution to a pre-diluted non-caustic cleaning solution
3rd – Administrative Control: SOPs, training employees or hanging instructive posters
4th – PPE: protection for the employee’s body: leather palmed work gloves to decrease the severity of a hand hit between two cylinders colliding.
This guide will help both employers and employees do the following:
- Understand the types of PPE.
- Know the basics of conducting a “hazard assessment” of the workplace.
- Select appropriate PPE for a variety of circumstances.
- Understand what kind of training is needed in the proper use and care of PPE.
Establishing a written PPE Program detailing what PPE employees use, in which work areas, makes it easier to ensure that employees use PPE properly in the workplace.
The Requirement for PPE
To ensure the greatest possible protection for employees in the workplace, the cooperative efforts of both employers and employees will help in establishing and maintaining a safe and healthy work environment.
In general, employers are responsible for:
- Performing a “hazard assessment” of the workplace to identify and control physical and health hazards.
- Identifying and providing appropriate PPE for employees.
- Training employees in the use and care of the PPE.
- Maintaining PPE, including replacing worn or damaged PPE.
- Periodically reviewing, updating and evaluating the effectiveness of the PPE program.
In general, employees should:
- Properly wear PPE,
- Attend training sessions on PPE,
- Care for, clean and maintain PPE,
- Inform a supervisor of the need to repair or replace PPE.
Types of PPE
All PPE must meet ANSI (American National Standards Institute) standards in effect at the time of its manufacture or provide protection equivalent to PPE manufactured to the ANSI criteria. Employers should inform employees who provide their own PPE of the employer’s selection decisions and ensure that any employee-owned PPE used in the workplace conforms to the employer’s criteria, based on the hazard assessment, OSHA requirements and ANSI standards.
NOTE: If an employee uses a respirator, the employer must then maintain a Respirator Program.
- OSHA requires PPE to meet the following ANSI standards:
- Eye and Face Protection: ANSI Z87.1-1989
- Head Protection: ANSI Z89.1-1986.
- Foot Protection: ANSI Z41.1-1991.
- For hand protection, there is no ANSI standard for gloves, but OSHA recommends that selection be based upon the tasks to be performed and the performance and construction characteristics of the glove material. In our industry, leather palmed cotton backed gloves are the industry standard.
All PPE clothing and equipment should be of safe design and construction, and should be maintained in a clean and reliable fashion. Employers should take the fit and comfort of PPE into consideration when selecting appropriate items for their workplace. PPE that fits well and is comfortable to wear will encourage employee use of PPE. Most protective devices are available in multiple sizes and care should be taken to select the proper size for each employee. If several different types of PPE are worn together, make sure they are compatible. If PPE does not fit properly, it can make the difference between being safely covered or dangerously exposed. It may not provide the level of protection desired and may discourage employee use.
In order to assess the need for PPE, a hazard assessment should be performed for each activity in the facility. Engagement of an employee(s) who performs the job will greatly increase the accuracy of the assessment.
The basic steps of a Hazard Assessment are:
- Identify the jobs where exposures exist or are possible, then rank their exposure (likelihood and severity). Review of the injury and first aid logs will help identify those jobs.
2. Walk through the SOPs (Standard Operating Procedures), beginning with the job that has the greatest likelihood of hazard exposure and severity.
Consider the hazard categories that may be present:
- Motion or impact
- Extreme temperatures
- Chemical or biological
- Harmful dust
- Light (optical) radiation
- Employee falls and falling/dropped objects
- Sharp objects
- Compressing, rolling, or pinching objects
- Electrical, including static electricity discharge
3. Observe and record if any of the following hazards are present and if/what PPE are used:
- Sources of motion or impact (e.g., machinery or processes where any movement of tools, machine elements, or particles could exist, or movement of personnel that could result in collision with stationary objects).
- Sources of extreme temperatures that could result in burns, eye injury, ignition of protective equipment, frostbite, etc.
- Types of chemical and biological exposures.
- Sources of harmful dust.
- Sources of light (optical) radiation, e.g., welding, brazing, cutting, furnaces, heat treating, high-intensity lights, etc.
- Sources of employee fall hazards or the potential for falling or dropping objects.
- Sources of sharp objects that might pierce the feet or cut the hands.
- Sources of compressing, rolling, or pinching objects that could crush the feet.
- Sources of electrical hazards, such as electric shock or burns (from electric arcs, blasts, or heat), as well as static electricity discharge.
- Layout of workplace and location of co-workers.
4. Following the walk through, organize and categorize the information to analyze the hazards and choose the proper PPE. The Safety Manager should sign and date the form. Periodic review of the Hazard Assessment, injury and first aid logs will ensure the approved PPE is still appropriate. Job Hazard Analysis form on last page.
Employers are required to train each employee who must use PPE. Employees must be trained to know at least the following:
- When PPE is necessary.
- What PPE is necessary.
- How to properly put on, take off, adjust and wear the PPE.
- The limitations of the PPE.
- Proper care, maintenance, useful life and disposal of PPE.
Employers should make sure that each employee demonstrates an understanding of the PPE training as well as the ability to properly wear and use PPE before they are allowed to perform work requiring the use of the PPE. If an employer believes that a previously trained employee is not demonstrating the proper understanding and skill level in the use of PPE, that employee should receive retraining. Other situations that require additional or retraining of employees include the following circumstances; changes in the workplace or in the type of required PPE that make prior training obsolete.
The employer must document the training of each employee required to wear or use PPE by preparing a certification containing the name of each employee trained, the date of training and a clear identification of the subject of the certification.
OSHA has a very good booklet on Personal Protective Equipment and CGA P-44, Selection of Personal Protective Equipment is also a very good resource, it too is free if you are enrolled in the CGA & GAWDA Publication Subscription Program & Distributor Safety Award.
If there are questions or items that I can help you with, please contact me.