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

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:

1. Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do;
2. Compare the hazards associated with the environment;
3. Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards;
4. 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.

Exposure Assessment | Asbestos

Q.	What is included in the new "exposure assessment" requirements in the Construction and Shipyard standards?
A.	The "exposure assessment" predicts exposure and evaluates potential controls. In most cases, the exposure assessment will include both past and current monitoring. Monitoring results must be considered, but do not necessarily constitute an adequate "assessment" if they would not represent all representative employee exposures during the entire job. The assessment must review relevant controls, conditions and factors that influence the degree of exposure. These include, but are not limited to, quality of supervision and of employee training, techniques used for wetting the ACM, placing and repositioning the ventilation equipment and impacts due to weather conditions. The assessment must be based on a review of all aspects of the employer's performance doing similar jobs.
Q.	Do all employers need to conduct an "initial exposure assessment" under the Construction standard?
A.	In general, all employers who have a workplace covered by this standard are to conduct an "initial exposure assessment" at the beginning of each asbestos job [paragraph (f)(2)]. Exceptions to this requirement exist only for most Class IV work. Even employers who are planning to install full negative pressure enclosures with air flushing technology must conduct initial exposure assessments. Employers may base assessments of similar jobs on prior assessments of repetitive, routine jobs.
Q.	Is it more difficult than before to base an initial exposure on "historic data"?
A.	Yes, the standard establishes specific evaluation criteria for data. This criteria included the experience and training of the crews and the historic data must be updated annually. It is important to note that historic data is usually that data generated by an individual employer, whereas objective data is related to a product, material, or activity and may be derived from other employers' (such as the manufacturer of the product) data.
Q.	Explain "objective data."
A.	The use of objective data grants a monitoring exemption and may be used as a basis for a "negative exposure assessment." The employer using "objective data" must demonstrate that the product or material containing asbestos minerals or the activity involving such product or material cannot release airborne fibers in concentrations in excess of the PEL under those work conditions having the greatest potential for releasing asbestos. The employer may use data derived from other employers' jobs. The data should reflect worst case conditions in a variety of occupational settings.
Q.	When can "objective data" be relied on for a negative exposure assessment?
A.	For any specific asbestos job (combination of activity and product) performed by employees who have been trained in compliance with the standard the employer must demonstrate that, under worst case conditions, statistically there is a high degree of confidence that an exposure above the permissible exposure limit will not occur.
Q.	How would an employer who performs repetitive work complete exposure assessment?
A.	An employer may evaluate repetitive operations with highly similar characteristics, as one job, such as cable pulling in the same building, so long as the data used also reflect repetitive operations of the same duration and frequency.
Q.	Did OSHA adopt a clearance level?
A.	OSHA has not included a provision for a specific "clearance level" in the revised standards.