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Five common Personal Protective Equipment (PPE) mistakes

Each year, more than 700,000 lost workdays and tens of thousands of no lost time injuries could be prevented with the proper use of PPE, according to the Occupational Safety and Health Administration (OSHA). Employers know that OSHA's PPE standards are "performance-based" standards, not "specification" standards. OSHA does not prescribe specific PPE for particular circumstances, but requires employers to identify hazards that necessitate PPE, select the appropriate PPE, and train employees when and how to use it properly. The standards defer to employers' reasonable judgment about what PPE is necessary, for which employees, and in which circumstances.

Even though the value of PPE is not news for employers, managers and employees, non-compliance is widespread. Here are five reasons why:

  1. Inadequate assessment.

    OSHA specifies that employers "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)." While OSHA does not specify the format, identifying hazards should be a formal process, with written documentation. Depending upon the nature of the workplace, there may be several assessments focusing on different areas and employees. Some of the factors to consider are:

    • Chemical exposures
    • Tool and equipment hazards
    • Electrical hazards
    • Pinch points
    • Sharp objects
    • Rough surfaces
    • Falling, rolling, flying or dropped objects
    • Bump hazards to heads and toes
    • Respiratory hazards
    • Heat or cold
    • Light radiation, such as welding, cutting, UV curing or lasers
    • Excessive noise
    • Workplace layout, location of coworkers and pedestrian traffic
    • Unique hazards

    When conducting inspections, OSHA considers the reasonableness of an employer's hazard assessment and looks at factors such as the existence of past injuries (past OSHA 300 Logs), employee input and the presence of other controls that protect against injuries such as administrative procedures and training, or engineering and equipment controls. While OSHA does not have specific standards, fines for non-compliance are common. As an example, OSHA recently fined Las Vegas-based NV Energy $43,000 for failing to provide properly fitting personal protective equipment for each worker. They found conductive booties that were too small and modified by cutting off the top portion and securing it to the work boots with tape, gloves and conductive suits with holes and tears, and fall arrest equipment that did not meet required safety rules.

  2. Insufficient training

    Many employers practice a generic approach to training that misses the finer points. Training should be specific and include:

    • When employees have to use PPE
    • Limitations of PPE protection
    • How to inspect PPE
    • How to put on and adjust PPE
    • How to remove PPE safely
    • How to care for and store PPE
    • Useful life of PPE
    • How to replace worn or damaged PPE
    • Where to dispose of PPE that might be contaminated by hazardous substances

  3. Failure to involve employees in PPE selection

    A Kimberly-Clark professional survey taken at the 2007 National Safety Council Congress and Expo found that discomfort was the most common reason for not using PPE. A good solution is to involve employees in the selection. Have a select group that is representative of employees using the gear try different samples and test it. It may be that more than one style is needed to accommodate the comfort of the workforce.

    Another reason employees do not use PPE consistently is that it is unattractive or does not fit properly. If employees are content with their appearance, they will be more likely to use PPE. Increasingly, manufacturers are looking to improve style; offering some options in color and style can increase use.

  4. Failure to enforce usage

    A survey commissioned by the International Safety Equipment Association (ISEA) of safety influencers in the heavy construction industry revealed that the main reason workers chose not to wear PPE when needed was employers don't require or enforce usage. Employees quickly develop an attitude that PPE is not necessary for the task. Supervisors should adopt a culture that work is not allowed to start until PPE is on. Constant reinforcement is key, with the goal to make the PPE a natural program that becomes part of the worker's habits. Employees may have performed the same task for many years and never been injured. Showing employees videos of what can happen or having someone who sustained an injury speak to the group is the most effective way to combat this excuse.

    If it is taking excessive time to don the gear, employers need to drill down and determine why. Employers should also be aware that the U.S. Supreme Court has agreed to consider Sandifer v. United States Steel Corporation, the case concerning pay for doffing and donning PPE. The case will be taken up during the October 2013 Supreme Court term.

  5. Failure to revisit PPE policies frequently

    Practices change, new equipment is purchased, work methods are revised, and better PPE is developed. Are the policies still appropriate? What kinds of injuries are occurring? The process is continuous, constantly find ways to improve the program, afford better protection, provide additional training, and make the employees more comfortable.