Planning Protection Strategies
OSHA Updates PPE Sections of General Industry Standards

To recognize more recent editions of the national consensus standards, OSHA has revised the personal protective equipment (PPE) sections of its general industry, shipyard employment, long shoring and marine terminals standards, concerning requirements for eye- and face-protective devices, and head and foot protection.OSHA is updating the references to reflect advances in technology, and requires that PPE be safely designed and constructed for the tasks performed.

“Workers exposed to occupational hazards requiring head, foot, or eye and face protection will now be provided protection based on a standard that reflects state-of-theart technology and materials,” according to acting Assistant Secretary of Labor for OSHA Jordan Barab. “This final rule is another step in OSHA’s efforts to update or remove references to outdated national consensus and industry standards.”

Amendments to the PPE standards include such requirement as filter lenses and plates in eye-protective equipment meeting a test for transmission of radiant energy such as light or becomes infrared.

The final rule becomes effective on October 9, with text revised to allow employers to meet the design requirements of its PPE standards by using PPE constructed in accordance with any of three national standards. Additionally, the final rules maintain the option employers currently have to use PPE that is not manufactured in accordance with one of the listed consensus standards if the employer can demonstrate that the PPE is as protective as PPE constructed in accordance with one of the incorporated standards.

PPE should be worn to minimize exposure to specific occupational hazards. Examples of PPE are respirators, gloves, aprons, fall protection, and full body suits, as well as head, eye and foot protection. Using PPE is only one element in a complete safety program that would use a variety of strategies to maintain a safe and healthy occupational environment. PPE does not reduce the hazard itself nor does it guarantee permanent or total protection.

Hazards exist in every workplace so strategies to protect workers are essential.

The priority should be the elimination and control of hazards at their source or along the path between the source and the worker. Many methods are available, and those most appropriate to the specific situation should be used.

Controlling a hazard at its source should be the first choice because this method will eliminate it from the workplace altogether or isolate it from the worker. This “safe place” approach may require substitution of a material with nonhazardous ones, isolation of hazards, addition of safety features to existing equipment, redesign of the work processes, or purchase of new equipment.

When the hazard cannot be removed or controlled adequately, Personal Protective Equipment (PPE) must be used if the work process is to continue.

 Planning a Protection Strategy?

Before any decision is made to begin or to expand a PPE program, it is important to understand the underlying principles of protection strategies. There are three elements that must be considered:

• Protection of workers;

• Compliance with applicable laws / regulations and internal company standards; and

• Technical feasibility. In practice, only a few strategies are available. These include:

• Engineering controls;

• Material substitution;

• Process change;

• Revised work practices;

• Equipment change; and

• Administrative controls.

Use of Personal Protective Equipment.

A good comprehensive strategy considers the hazards, evaluates all possible control methods, integrates various approaches, and reexamines them frequently to ensure a safe work operation. It does these things by requiring that conscious decision-making, evaluation, and reevaluation be done at various stages throughout the program.

When hazards are identified, it is useful to consider general principles of control, which can be thought of as two basic categories: “pre-contact” or “point-of-contact.”

Pre-contact control is the first and most important method because it prevents the hazard from reaching the worker. Pre-contact control methods include substituting materials or processes that are less hazardous, isolating hazardous processes, retrofitting existing equipment, or acquiring safer equipment.

Pre-contact control can also be achieved by providing protection to the worker with local exhaust ventilation, machine guarding, better housekeeping, and safe work practices. While many hazards can be anticipated and avoided through effective engineering at the pre-contact stage, others may not be recognized before an accident occurs. A genuine effort to identify hazards is essential so that they may be reduced or eliminated at the source.

Where pre-contact controls are not practical, feasible, or totally effective then pointof- contact controls must be used.

The point-of-contact control is important but secondary because it cannot eliminate the hazard. It only manages the hazard at the point of contact with the worker. This form of control is primarily accomplished through personal protective equipment, and is to be used when pre-contact controls are not totally effective.

When Should PPE be Used?

PPE is used to reduce or minimize the exposure or contact to injurious physical, chemical or biological agents. A hazard cannot be eliminated by PPE, but the risk of injury can be eliminated or greatly reduced.

For example, wearing hearing protection reduces the likelihood of hearing damage when the ear plugs or muffs are appropriate for the kind of noise exposure and they are used properly. However, hearing protection does not eliminate the noise.

PPE should only be used:
• As an interim (short term) measure before controls are implemented;
• Where pre-contact control technology is not available;
• Where pre-contact controls are inadequate;
• During activities such as maintenance, clean up, and repair where pre-contact controls are not feasible or effective; and
• During emergency situations.

How do I Design a PPE Program?

A PPE program must be comprehensive. It requires commitment and active participation at the planning, development, and implementation stages from all levels: senior management, supervisors, and workers. A good PPE program consists of these essential elements:

• Workplace survey;

• Selection of appropriate controls;

• Selection of appropriate PPE and proper fitting;

• Training;

• Management support; and

• Maintenance and auditing of the program.

The organization’s occupational health and safety policy should be a statement of principles and general rules which serve as guides to action. Senior management must be committed to ensuring that the policy and procedures are carried out. PPE programs must be, and must be seen to have equal importance with all other organizational policies, procedures, and programs.

In addition, worker compliance with the PPE program is likely to be poor if a PPE device is unattractive, uncomfortable, or is imposed on the worker with little choice in the selection. The protection provided will be dramatically reduced if workers remove the PPE for even short periods of time. The loss of protection during the periods when the PPE is not worn may easily outweigh the protection when it is used.

For example, in order to get full benefit, hearing protectors must be worn all the time during noisy work. If hearing protectors are removed only for a short duration, the protection is substantially reduced.

Once the need for PPE has been established, the next task is to select the proper type. Two criteria need to be determined:

• The degree of protection required, and the appropriateness of the equipment to the situation (including the practicality of its being used and kept in good repair).

• The degree of protection and the design of PPE must be integrated because both affect its overall efficiency, wearability, and acceptance. There are no shortcuts to PPE selection. Choose the right PPE to match the hazard. FSM