OSHA Compliance Manual

Hazard Assessment and Employee Training §1910.132 (d), (e), (f)

2012-02-01T01:13:00.000-08:00

In April of 1994 OSHA issued a rule updating the PPE standard to reflect current technology and improvements in personal protective equipment and to add provisions requiring employers to assess their workplaces for hazards and train their employees in the use of the protective equipment. OSHA estimates that the new standard will provide improved protection in 1.1 million work establishments covering 11.7 million employees. Upgrades in eye, face, head, foot and new hand requirements became effective July 5, 1994 and hazard assessment and training requirements on October 5, 1994. Guidance in conducting a hazard assessment of the workplace and selecting personal protective equipment is also provided.

The workplace must be assessed to determine if hazards are present which necessitate the use of PPE. The employer must verify that the assessment has been completed through a written certification which identifies the workplace, the person certifying that the evaluation has been performed, the date of the assessment, and a statement which identifies the document as certification of hazard assessment. If it is determined that such hazards are present, the employer must select protective equipment for the employees and communicate the selection decisions to them.

Hazard Assessment

PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with guards, engineering controls, and sound manufacturing practices.

It is necessary to consider certain general guidelines for assessing the foot, head, eye and face, and hand hazard situations that exist in an occupational or educational operation or process, and to match the protective devices to the particular hazard. It should be the responsibility of the safety officer to exercise common sense and appropriate expertise to accomplish these tasks.

Assessment Guidelines

The employer must conduct a walk-through survey of the areas in question to identify sources of hazards to workers. These hazardous situations may include sources of motion; sources of high temperatures; types of chemical exposures; sources of harmful dust or light radiation; sources of falling objects or potential for dropping objects; sources of sharp objects which might pierce the feet or cut the hands and rolling or pinching objects which could crush the feet; the layout of workplace and location of co-workers; and any electrical hazards.

Following the walk-through survey, it is necessary to organize the data to prepare an analysis of the hazards to enable proper selection of protective equipment. The employer should analyze the data on the workplace and estimate the potential for injuries. Each of the basic hazards should be reviewed and a determination made as to the type, level of risk, and seriousness of potential injury from each of the hazards found in the area. The possibility of exposure to several hazards simultaneously should be considered.

Selection Guidelines

After completion of the hazard assessment, the general procedure for selection of protective equipment is to:

Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do;
Compare the hazards associated with the environment;
Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards;
Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that the users be made aware of all warning labels for and limitations of their PPE.

Careful consideration must be given to comfort and fit. PPE that fits poorly will not afford the necessary protection. Continued wearing of the device is more likely if it fits the wearer comfortably and protective devices are generally available in a variety of sizes.

Adjustments should be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. Particular care should be taken in fitting devices for eye protection against dust and chemical splashes. In addition, proper fitting of helmets is important to ensure that it will not fall off during work operations.

It is the responsibility of the employer or safety officer to reassess the workplace hazard situation as necessary, to identify and evaluate new equipment and processes, to review accident records, and reevaluate the suitability of previously selected PPE.

Employee Training

Employers must provide training for each employee who is required to use personal protective equipment. Training should include when PPE is necessary; what PPE is necessary; how to wear PPE; its limitations; the proper care, maintenance, useful life, and disposal of the PPE. Employees must demonstrate an understanding of the training and the ability to use the PPE properly before being allowed to perform work requiring the use of the equipment.

If an employer has reason to believe an employee does not have the understanding or skill required, the employer must retrain. Circumstances where retraining may be required include changes in the workplace or changes in the types of PPE to be used which would render previous training obsolete. Also, inadequacies in an affected employee's knowledge or use of the assigned PPE which indicates that the employee has not retained the necessary understanding or skills. Employers must certify in writing that the employee has received and understands the training.

Cleaning and Maintenance

It is important that all PPE be kept clean and properly maintained. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE should be inspected, cleaned, and maintained at regular intervals so that the PPE provides the requisite protection.

It is also important to ensure that contaminated PPE which cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards.

Exactly What is Personal Protective Equipment (PPE)?

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Personal protective equipment includes all clothing and accessories designed to create a barrier against workplace hazards. The basic element of any personal protective equipment management program should be an in-depth evaluation of the equipment needed to protect against the hazards at the workplace.

Much of the personal protective equipment (PPE) information in this chapter is framed in general terms and is intended to complement relevant regulations and manufacturers' requirements. For more specific information, refer to the OSHA standards cited earlier.

In some instances the standards refer to specifications by:

American National Standards Institute (ANSI)
11 West 42 Street, 13th Floor
New York, NY 10036

and

American Society for Testing and Materials (ASTM)
1916 Race Street
Philadelphia, PA 19103

Many methods of reinforcing the use of personal protective equipment have been employed. Regardless of the method, the employee should understand at the outset that his or her life may well depend upon the use of the equipment.

Using personal protective equipment requires hazard awareness and training on the part of the user. Employees must be aware that the equipment does not eliminate the hazard. If the equipment fails, exposure will occur. To reduce the possibility of failure, equipment must be properly fitted and maintained in a clean and serviceable condition.

Selection of the proper piece of personal protective equipment for the job is important. Employers and employees must understand the equipment's purpose and its limitations. The equipment must not be altered or removed even though an employee may find it uncomfortable. (Sometimes equipment may be uncomfortable simply because it does not fit properly.) Work procedures should be instituted making it a violation (resulting in termination) to modify or refuse to wear the equipment.

Develop a Personal Protective Equipment (PPE) Program

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Management dedicated to the safety and health of employees should use that evaluation to set a standard operating procedure for personnel, then train those employees to use, maintain, and clean the equipment to protect themselves against those hazards.

A written PPE program should be established for the workplace. The two basic objectives of any PPE program should be to protect the wearer from safety and health hazards, and to prevent injury to the wearer from incorrect use and/or malfunction of the PPE.

To accomplish these goals, a comprehensive PPE program should include:

Hazard assessment of the workplace,
Medical monitoring,
Environmental surveillance,
Selection, use, maintenance, and decontamination of PPE, and
Employee training.

Program Review and Evaluation

Your PPE program should be reviewed at least annually. Elements which should be considered in the review include:

The number of person-hours that workers wear various protective ensembles,
Accidents and illness experience,
Levels of exposure,
Adequacy of equipment selection,
Adequacy of the operational guidelines,
Adequacy and effectiveness of training and fitting elements,
Coordination with overall safety and health program,
The adequacy of program records,
Program costs, and
Recommendation for program improvement and modification.

The results of the program evaluation should be made available to employees and presented to top management so that program adaptations may be implemented.

Hazards of Personal Protective Equipment (PPE)

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While personal protective equipment is part of the job in some industries—face shields for welding—as a rule, it is considered a last-resort, temporary type of protection. For normal operations, first choice will always be given to eliminating the hazard in the environment rather than using PPE. This is called implementing engineering controls.

No single combination of protective equipment and clothing is capable of protecting against all hazards. Thus, PPE should be used in conjunction with other protective methods. The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication.

In general, the greater the level of PPE protection, the greater are the associated risks. For any given situation, equipment and clothing should be selected that provide an adequate level of protection. Overprotection as well as under-protection can be hazardous and should be avoided.

Using PPE improperly or in a manner unsuited to its design and purpose is worse than using no protection at all. Without any protection, the worker knows he is vulnerable and perhaps, takes precautions. With some protection, the worker may rashly blunder into severe difficulty, thinking he is safe.

Personal Protective Equipment

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1910.132 General Requirements

(a) Application. Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.

Under OSHA, you are required to provide a hazard-free environment for your employees. Anyone encountering hazardous conditions must be protected against the potential hazards. The purpose of personal protective clothing and equipment (PPE) is to shield or isolate individuals from the chemical, physical, and biological hazards that may be present in the workplace.

In general, it is just good common sense to have PPE available for whatever emergency situation could arise in your operation. The use of PPE is specifically required by OSHA in 29 CFR 1910, in at least the following places:

1910.94(a)(5) - Abrasive Blasting
1910.95(b)(1) - Noise Exposure
1910.120 - Hazardous Waste Operations and Emergency Response
1910.137 - Electrical Protective Equipment
1910.156(f) - Fire Brigades
1910.252(b)(2) and (3) - Welding, Cutting, and Brazing
1910.261(b)(2) - Pulp, Paper, and Paperboard Mills
1910.262(qq) - Textiles
1910.266(d)(1) - Logging Operations
1910.1000(d) - Asbestos Exposure
1910.1200(h)(2)(iii) - Hazard Communication Standard

Methods to Lower Workplace PELs

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According to OSHA policy, engineering controls and work practices are preferred over personal protective equipment to control employee exposures to airborne contaminants.

Engineering controls involve the use of a local exhaust ventilation, general ventilation, isolation of the worker and enclosure of the source of emissions, process modifications, equipment modifications, and substitution of nonhazardous or less hazardous chemicals. These methods may be used alone or in combination, depending upon the industrial processes involved. These controls are widely used and will effectively control exposures either by themselves, or coupled with changes in work practices.

Ventilation

Perhaps the most widely used technique for controlling chemical exposure is the use of ventilation. General ventilation uses the movement of air within the general work space to displace or dilute the contaminant with fresh outside air. General ventilation may not be the preferred control method, however, due to the large volumes of air movement required. Local exhaust ventilation uses a much smaller volume of air and controls emissions at the point or source from which contaminants are generated.

Isolation

Isolation involves placing a physical barrier between the hazardous operation and the worker. Many modern, automated manufacturing processes are now fully enclosed in ventilated cabinets. The effectiveness of such a control technique depends on the frequency with which the workers have to enter the enclosure during normal operations.

In other situations, the worker, rather than the process or machine, can be placed in an enclosure having a controlled atmosphere. Many processes which involve potential chemical exposures are operated remotely by operators from air conditioned booths isolated from the hazardous materials.

Substitution

Substitution refers to the replacement of a toxic chemical in a particular process or work area with another, less toxic or non-toxic product. Properly applied, substitution can be a very effective control technique. However, care must be taken to ensure that the proposed substitute performs in a similar manner to the product being replaced. In addition, it is essential that the substitute be carefully evaluated to ensure that in controlling one hazard, another different hazard is not inadvertently introduced. The substitute must also be compatible with existing manufacturing equipment and processes.

The success of these engineering control techniques will depend on the physical properties of the chemicals and emissions encountered (boiling point, vapor pressure, etc.) and the process operating conditions. In some cases, particularly with cleaning solvents, substitution may provide the quickest and most effective means of reducing exposure. In other situations, a major effort may be required to alter processes or install or expand local or general dilution ventilation.

OSHA has found that engineering controls and improved work practices are available to reduce exposure levels to the new levels in almost all circumstances. However, in some circumstances, respiratory protection may be necessary to complement engineering controls. Respiratory protection may be necessary to achieve compliance in some specific operations in some industries.

Engineering Controls vs. Protective Equipment

So in other words, the most desirable way to deal with an air contaminant is to alter the process so that the contaminant is no longer produced. If the process cannot be changed or materials substituted, a well designed ventilation system may be the best solution to the problem. If ventilation would require too large a volume of air to reduce the concentration of the contaminant, then respiratory protection may be a necessary short-term solution.

Pitfalls of Exposure Limits

Even though you have checked the PELs and the TLVs for your chemicals, brought the exposure numbers into the acceptable range, your workers may still be endangered. How could this be?

There are over 600,000 chemicals in use today. Information available for selecting an exposure limit is very scant. Only a small percentage of chemicals is even evaluated. Therefore, supporting data can be weak. Exposure limits are changed when new information becomes available. What is considered “safe” today, may be viewed in a different light tomorrow.

Individual sensitivity is a factor. Even at an acceptable exposure level, a given chemical may have a negative effect on certain people. So even if the exposure limit protects most people, it can not be relied upon to protect everyone.

Synergistic effects should be considered. Single substances are assigned individual ratings. Seldom in the real world is only one chemical in use at a time. What happens when several chemicals combine to produce effects far more harmful than those of any one substance?

Court Decision Affecting PELs

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Since the 1970s, much new information has become available which indicates that, in most cases, these early limits are outdated and insufficiently protective of worker health. To correct this situation, OSHA published a proposal in 1988 updating the air contaminant limits in general industry. When that proposal became a final rule in 1989, it lowered the existing PELs for 212 toxic air contaminants and established PELs for 164 previously unregulated air contaminants.

In July 1992, the Eleventh Circuit Court of Appeals vacated the 1989 final rule on the grounds that OSHA:

Failed to establish that existing exposure limits in the workplace presented significant risk of material health impairment or that new standards eliminated or substantially lessened the risk; and
Did not meet its burden of establishing that its new permissible exposure limits (PELs) were either economically or technologically feasible.

The Court’s decision to vacate the rule forced OSHA to revert back to the original protective limits. The Court granted several successive stays following the July 1992 decision, allowing the Agency time to consider further legal steps. A decision was made on March 1993 not to appeal to the Supreme Court, and the Eleventh Circuit Court’s decision stands today.

Should you comply with the 1989 PELs, even though they are no longer legally required?

OSHA believes the 1989 PELs are more protective, and encourages employers to continue compliance efforts to meet these levels, particularly where engineering and work practice controls have already been implemented. OSHA always encourages employers to go beyond the minimum protections afforded by the standards.