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Personal Protective Equipment (PPE)

32nd Annual Iowa Governor’s Safety Conference “Back to the Basics”

Des Moines, IowaNovember 4, 2003

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Azita MashayekhiMHS in Industrial Hygiene and Safety

Staff Industrial HygienistSafety and Health Department

International Brotherhood of Teamsters

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What do we do?

Technical assistance and information

Training and education

Legislative and regulatory action

Workplace inspections and surveys: manufacturing, public employees, health care, construction, warehouse, freight, parcel, brewery, waste

Respond to questions on safety and health hazards in the workplace

Training and education: Teamsters Leadership Academy; Local union stewards’ trainingWe respond to calls and letters by writing a letter or a report if it entails an inspection or review of another environmental reportSee range of S&H fact sheets on www.teamster.org

Testify about DOT and OSHA, Federal Railroad Administration (FRA), Mine Safety and Health Administration (MSHA) proposals and lawsIBT developed language that was included in TEA-21 (Transportation Equity Act for the 21st

Century) about toll collector safety and health.Provide S&H information to IBT lobbyists in various states to promote or counter proposed legislation.Write comments to OSHA, DOT on proposed rules, etc.

IBT can perform comprehensive or focused inspections and environmental measurements.Review existing safety and health programs/policies; Injury/illness records (OSHA 300) (see fact sheet); Interview Workers; Talk with employer

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Overview

What are PPE?

OSHA and other Standards

Hierarchy of Safety and Health Controls

Limitations

Where do PPE fit in the” hierarchy of controls” that can be used to address safety and health problems in the workplace.

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What are PPE?

OSHA requires (29 CFR 1910.132-138) employers to use personal protective equipment (PPE) to reduce employee exposure to hazards when engineering and administrative controls are not feasible or effective. Employers are required to determine all exposures to hazards in their workplace and determine if PPE should be used to protect their workers.

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What are PPE?

Devices used to protect an employee from injury or illness resulting from contact (absorption, inhalation, injection) with chemical , radiological, physical, electrical, mechanical, or other workplace hazards (OSHA)

Summary slide

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Types of PPE

Head protectionEye and Face protectionHearing protectionRespiratory protectionArm and Hand protectionFoot and Leg protectionProtective clothing (coveralls, vests)Protective shields and barriersFall protection (OSHA Directive 1-1.13)

Examples of PPE:Protective helmets, hardhats Safety glasses/goggles; face shieldEar plugs or muffsAir-purifying respirator; atmosphere-supplying respirator; etc.Gloves; jacket cuff (worn over glove cuff)Boots (e.g., steel-toe)TYVEC suit; splash suitFull-body harness; body belt

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Back BeltsBack belts are not recognized by OSHA as effective engineering controls to prevent back injury. While they may be accepted by individual workers because they feel as if they provide additional support, the effectiveness of back belts in the prevention of low back injuries has not been proven in the work environment. Thus, OSHA does not forbid the use of back belts and similar devices, nor does it endorse their use.(See OSHA Standard Interpretations04/06/1998 - Prevention of back injuries and use of back belts)

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Back BeltsBack belts: The effectiveness of back belts in reducing the risk of back injury among healthy workers remains unproven. If workers falsely believe they are protected when wearing belts, they may attempt to lift more than they would without a belt. This poses a risk of injury to the worker Back injuries account for nearly 20% of all injuries and illnesses in the workplace and cost the nation an estimated 20 to 50 billion dollars per year. The National Institute for Occupational Safetyand Health (NIOSH) believes that the most effective way to prevent back injury is to implement an ergonomics program that focuses on redesigning the work environment and work tasks to reduce the hazards of lifting.(See Back Belts: Do They Prevent Injury? DHHS, NIOSH Publication No. 94-127).

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Work-related Injuries and Illnesses Statistics 2001 (BLS)

1.5 million work-related injuries and illnesses involving days away from workin private sector

More than 1/7 will involve the head, eyes, hands, or feet

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Safety and Health Hazards

Chemical

Physical

Biological

Ergonomics: Fitting the job to the worker

Physical hazards include: noise, radiation, forklift, welding, etc.Biological hazards are infectious diseases from viruses, bacteria, parasites, fungi such as histoplasmosis from bird droppings; West Nile virus; Hepatitis and HIV from bloodborne pathogens.

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Chemical Hazards

Liquid, gas, or solid

Through inhalation, skin absorption, or ingestion

Chemicals come in three forms and can expose workers in three ways.

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Chemical Hazards

Hazard Communication Standard:Any generally applicable control measures which are known to the chemical manufacturer, importer or employer preparing the material safety data sheet, such as appropriate engineering controls, work practices, or personal protective equipment; 1910.1200(g)(2)(ix)

OSHA’s Hazard Communication standard requires the use of appropriate engineering controls, work practices, or personal protective equipment.

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Physical Hazards

Noise, radiation, temperature, vibration, impact, penetration, compression (rollover)

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Physical Hazards

Occupational Noise Exposure Standard:When employees are subjected to sound exceeding those listed in Table G-16, feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels within the levels of Table G-16, personal protective equipment shall be provided and used to reduce sound levels within the levels of the table.1910.95(b)(1)

OSHA’s noise standard requires the use of feasible administrative or engineering controls.

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Physical Hazards

Electrical Standards: Employees working in areas where there are potential electrical hazards shall be provided with, and shall use, electrical protective equipment that is appropriate for the specific parts of the body to be protected and for the work to be performed. 1910.335(a)(1)(i)

Insulating blankets, matting, covers, line hose, gloves, and sleeves made of rubber shall be maintained in a safe, reliable condition. 1910.137

These are examples of language in OSHA standards that address physical hazards.

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Biological Hazards

Bacteria, viruses, fungi, parasites

Through inhalation, cuts, ingestion

Needlestick injuries, for e.g., can cause exposure to bloodborne pathogens such as Hepatitis B, Hepatitis C, and HIV.The Needlestick Safety and Prevention Act, effective 2001, revises the BloodbornePathogens Standard, in effect under the OSHA Occupational Safety and Health Act of 1970, to include safer medical devices, such as sharps with engineered sharps injury protections and needleless systems, as examples of engineeringcontrols designed to eliminate or minimize occupational exposure to bloodbornepathogensthrough needlestick and other percutaneous injuries.

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Hierarchy of Controls

PPE should be used as a last resortThe use of PPE signifies that the hazard could not be controlled by other methods, such as:

Engineering controlsAdministrative controls Engineering and other types of controls (including PPE) are not mutually exclusive. Employers may need to use multiple types of controls to prevent employee overexposure.

The different ways to control hazards, from most effective to least effective, are called the hierarchy of controls: Hazards should be controlled in the following order:

Engineering controls include using equipment that makes work safer or substituting safer chemicals or other products to keep hazards from entering the workplace. Administrative controls include changing the way workers do their jobs to reduce their exposure to hazards. Personal Protective Equipment (PPE) is the least effective way to protect workers. If the PPE fails, the workers are exposed to the hazard. PPE includes respirators, hardhats, face and eye protection, hearing protection, gloves, and protective clothing and footwear.

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Engineering Controls

Engineering controls include changes to workstations, tools or equipment used on the job, or changing the way a job is done, such as substitution of less hazardous materials or processes . These controls are preferred over all others because they make permanent changes that eliminate hazards at the identified source.

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Engineering Controls

Design (remove hazard from process)Substitution (of less hazardous materials)Process modification (how and where)Isolate the process or the workerWet methods for dust reductionLocal exhaust ventilation (at source)Dilution ventilation (area)Good housekeeping

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Engineering Controls

“The Needlestick Prevention and Safety Act”“Engineering controls shall be examined and maintained or replaced on a regular schedule to ensure their effectiveness.” 1910.1030(d)(2)(ii)Some examples of engineering controls used to control the hazards of needlesticks include needleless intravenous (IV) systems, “self-sheathing,” and/or “self-blunting” surgical needles.

OSHA’s bloodborne pathogens standard has provisions for engineering controls.

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Administrative Controls

Administrative controls (or work practice controls) are changes in work procedures such as written safety policies, rules, supervision, and training with the goal of reducing the duration, frequency, and severity of exposure to hazardous chemicals or situations.

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Administrative Controls

Performing maintenance operations that involve toxic substances at night when the usual production staff is not present. Rotating workers through various job assignments so that they donot develop repetitive motion injuries. Prohibiting workers from working with ionizing radiation once they have reached a predetermined level of exposure. Requiring workers in hot environments to take breaks in cool rest areas and providing fluids for rehydration. Prohibiting worker access to areas involving hazards such as lasers, energized electrical equipment, or excessive noise. Proper housekeeping. Reducing clutter reduces the chances for anaccident and minimizes the effects if an accident does occur.

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PPE Limitations

The use of PPE signals that the hazard still exists in the workplacePPE design may interfere with activities PPE may contribute to physical burden (weight, breathability, ergonomic characteristics)PPE may not fit or may fail and expose workers without their knowledgeFailure of PPE means that the worker will be exposed

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OSHA PPE StandardsTitle 29 Code of Federal Regulations

(CFR)General Industry: 1910 Subpart I and others

Construction: 1926 Subpart E –Personal Protective and Life Saving Equipment

Maritime:Shipyard Employment, 1915 Subpart IMarine Terminal, 1917 Subpart ELongshoring, 1918 Subpart J

OSHA has separate S&H standards for several industries.

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Other PPE Standards

Some “consensus” standards referenced in OSHA’s standards:

American National Standards Institute (ANSI) http://www.ansi.orgRevised consensus standard does not automatically replace the old standard within an OSHA regulation

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Biological Hazards

Bloodborne Pathogens Standard:Engineering and work practice controls shall be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protectiveequipment shall also be used. 1910.1030(d)(2)(i)When there is occupational exposure, the employer shall provide,at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratorycoats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. Personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectiousmaterials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. 1910.1030(d)(3)(i)

OSHA’s bloodborne pathogens standard has provisions for various controls, including engineering controls.

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OSHA 1910 Subpart I29 CFR 1910.132-139

1910.132 - General requirements.1910.133 - Eye and face protection.1910.134 - Respiratory Protection.1910.134 App A - Fit Testing Procedures (Mandatory).1910.134 App B-1 - User Seal Check Procedures (Mandatory).1910.134 App B-2 - Respirator Cleaning Procedures (Mandatory).1910.134 App C - OSHA Respirator Medical Evaluation Questionnaire (Mandatory).1910.134 App D - (Mandatory) Information for Employees Using Respirators When not Required Under Standard.1910.135 - Head protection.1910.136 - Occupational foot protection.1910.137 - Electrical protective devices.1910.138 - Hand Protection.1910.139 - Respiratory protection for M. tuberculosis.1910 Subpart I App A - References for further information (Non-mandatory)1910 Subpart I App B - Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection.

OSHA has a range of standards for personal protective equipment in general industry (29 CFR 1910.132-139).

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General PPE Requirements-OSHA

29 CFR.1910.132 requires:Hazard assessments before worker assignmentSelect appropriate and fitting equipmentCommunicate selection decision to employeesTrain and (retrain) in use and limitations of PPEHave employees demonstrate understanding of PPEEnsure adequacy, including proper maintenance and

sanitation, of supplied or employee-owned PPEEnsure use of PPE

OSHA’s 1910.132 contains general requirements for PPE.

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General PPE Requirements-OSHAHazard Assessment

The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). 1910.132(d)(1)

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General PPE Requirements-OSHAHazard Assessment

Impact: falling/flying objectsPenetration: sharp objects that pierce hands/feetCompression: rolling/pinching objectsChemical exposure: eye/skin contactHeat: burns, eye injury, ignition of PPELight: welding, high-intensity lightElectrical: high voltage exposureHarmful dust: paint, asbestosHarmful noise: steady or impact

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General PPE Requirements-OSHAEye and Face Protection, 1910.133

“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 liquids, chemical gases or vapors, or potentially injurious light radiation.”

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General PPE Requirements-OSHARespiratory Protection, 1910.134

“Respirators shall be provided by the employer when such equipment is necessary to protect the health of the employee. The employer shall provide the respirators which are applicable and suitable for the purpose intended. The employer shall be responsible for the establishment and maintenance of a respiratory protection program.”

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General PPE Requirements-OSHAHead Protection, 1910.135

“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.”

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General PPE Requirements-OSHAOccupational Foot Protection, 1910.136

“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, and where such employee's feet are exposed to electrical hazards.”

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General PPE Requirements-OSHAElectrical Protective Devices, 1910.137“Insulating blankets, matting, covers, line hose, gloves,

and sleeves made of rubber shall meet the following requirements…”

“Insulating equipment shall be stored in such a location and in such a manner as to protect it from light, temperature extremes, excessive humidity, ozone, and other injurious substances and conditions.”

“Insulating equipment shall be inspected for damage before each day’s use and immediately following any incident that can reasonably be suspected of having caused damage. Insulating gloves shall be given an air test, along with the inspection.”

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General PPE Requirements-OSHAHand Protection, 1910.138

“Employers shall select and require employees to use appropriate hand protection when employees' 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.”

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General PPE Requirements-OSHAFall Protection, 1910.23, .66, .269

29 CFR 1910.269 Fall Protection:• (g)(2)(iii) - Body belts, safety straps, lanyards, lifelines,

and body harnesses shall be inspected before use each day to determine that the equipment is in safe working condition. Defective equipment may not be used.

• (g)(2)(v) - Fall arrest equipment… shall be used by employees working on elevated locations more than 4 feet above the ground on poles, towers, or similar structures if other fall protection has not been provided.

In several general industry standards, OSHA has requirements for the use of PPE in fall protection.

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Who Pays?Pay versus Provide (OSHA)

At no cost: 1910.95; 1910.134; 1910.146; 1910.156; 1910.266; 1910.1001; 1910.1018 1910.1027; 1910.1028

Employers shall make hearing protectors available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater at no cost to the employees. Hearing protectors shall be replaced as necessary.1910.95(i)(1)

In several standards, OSHA explicitly states that PPE should be provided at no cost to workers by the employer.The noise standard, for example, contains such language.

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Who Pays?Pay versus Provide (OSHA)

Just provide: 1910.28; 1910.67; 1910.66, 1910.94, 1910.119; 1910.132; 1910.133; 1910.135; 1910.137; 1910.139; 1910.136; 1910.138

Overhead protection shall be provided on the scaffold, not more than 9 feet above the platform, consisting of 2-inch planking or material of equivalent strength laid tight, when men are at work on the scaffold and an overhead hazard exists. 1910.28(f)(16)

In several standards, OSHA only states that PPE should be provided to workers by the employer.In these instances, the issue of payment for PPE should be negotiated with the employer by the local union.OSHA’s standard, Safety requirements for Scaffolding, for example, contains such language.

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Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection - 1910 Subpart I App B

3. Assessment guidelines. In order to assess the need for PPE the following steps should be taken:a. Survey. Conduct a walk-through survey of the areas in question. The purpose of the survey is to identify sources of hazards to workers and co-workers. Consideration should be given to the basic hazard categories:(a) Impact(b) Penetration(c) Compression (roll-over)(d) Chemical(e) Heat(f) Harmful dust(g) Light (optical) radiation

OSHA has a non-mandatory appendix for PPE which is intended to provide compliance assistance for employers and employees in implementing requirements for a hazard assessment and the selection of personal protective equipment.

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Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection - 1910 Subpart I App B

3. Assessment guidelines. In order to assess the need for PPE the following steps should be taken:b. Sources. During the walk-through survey the safety officer should observe:

(a) sources of motion; i.e., 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;(b) sources of high temperatures that could result in burns, eye injury or ignition of protective equipment, etc.;(c) types of chemical exposures;(d) sources of harmful dust;(e) sources of light radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.;(f) sources of falling objects or potential for dropping objects;(g) sources of sharp objects which might pierce the feet or cut the hands;(h) sources of rolling or pinching objects which could crush the feet;(i) layout of workplace and location of co-workers; and (j) any electrical hazards. In addition, injury/accident data should be reviewed to help identify problem areas.

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General Duty ClauseOSHAct Section 5(a)(1)

“Each employer shall furnish to each of his employees 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 to his employees.”

Where there is no standard that applies to the particular hazard involved, the general duty provisions shall be used.Very important language – probably the most important language.Puts S&H responsibility on EMPLOYER.

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ANSIANSI Z87.1-2003

Occupational and Educational Personal Eye and Face Protection Devices: (referenced in 1910.133):

Sets forth criteria related to the description, general requirements, testing, marking, selection, care, and use of protectors to minimize or prevent injuries, from such hazards asimpact, non-ionizing radiation and chemical type injuries

ASSE/ANSI Z359.1-1992 (R1999) – Safety requirements for Personal Fall Arrest Systems, Subsystems and Components):

A full-body harness or personal fall systems should be used at working heights above six (6) feet.

Aside from OSHA standards, there are voluntary consensus standards (not enforceable, unless adopted by OSHA) that address PPE.The American National Standards Institute (ANSI) is a private, non-profit organization which has several standards addressing various PPE.

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Case Study: Sewage Repair Work and PPE

Biological: bacterial, viral and parasitic infections, e,g., HIV, Hepatitis B, Hepatitis A, Tetanus, E. coli

Chemical: Sewage water, droplets, aerosols

Physical: Needles; Slips/trips; Impact

A job hazard analysis will determine the existing or anticipated workplace hazards.

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Case Study: Sewage Repair Work and PPE

Inhalation: RespiratorAbsorption: Chemical splash goggles; Face shields; Rubber pants and jackets; Elbow-length rubber glovesIngestion: Face shields; Rubber pants and jacketsCuts/punctures: used syringes; Elbow-length rubber gloves; Steel-toed footwear Slips/trips, falls: Rubber boots; HarnessesImpact: Safety glasses

Establishing the routes of entry for the workplace hazards is necessary in order to select appropriate PPE.

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Case Study: Sewage Repair Work and PPE

Safety glassesChemical splash goggles Face shields Rubber pants and jacketsElbow-length rubber glovesDisposable mask Hard hatSteel-toed footwear Rubber boots Harnesses

Types of PPE recommended for sewage repair work.

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Resources

Inspection Guidelines for 29 CFR 1910. Subpart I, the Revised Personal Protective Equipment Standards for General Industryhttp://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1790American National Standards Institute (ANSI) www.ansi.org212-642-4900NSSN: “Internet’s most comprehensive data network on developing and approved national, foreign, regional and international standards and regulatory documents http://www.nssn.org/search.html

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Resources

NIOSH Guide to Industrial Respiratory Protection, 1987,“Blue Book” http://www.cdc.gov/niosh/87-116.htmlNIOSH Pocket Guide to Chemical Hazards, “Green book,”No. 97-140, 2003Quick Selection Guide to Chemical Protective Clothing, 3rd

ed., 1997, Krister Forsberg and Zack MansdorfThe American Industrial Hygiene Association (AIHA)http://www.aiha.orgThe American Conference of Governmental Industrial Hygienists (ACGIH) http://www.acgih.org/home.htm