How to prepare a PPE Assessment in accordance with OSHA Requirements
Meola has conducted and written numerous PPE assessments, reviews, Safety Manuals and instructional tutorials associated with this topic.
He is a specialist in PPE applications and advises numerous private clients in Safety Program management and operations, particularly in the heavy industrial and construction sectors
Personal Protective Equipment (PPE) is one of the mainstay elements in most safety programs. The problem is that it typically receives minimal attention from persons responsible for safety management. Buying your PPE out of a catalog or from the lowest cost provider are indications of deficiency in the process. OSHA recognizes that PPE is important, and has a small but significant requirement the employers must ASSESS their workplace for hazards, and must address these hazards according to a ‘Hierarchy’ or order of progression.
Ideally, if a hazard is present in a workplace, OSHA will expect that the hazard should be ‘engineered’ out of existence, such as by enclosing, isolating, machine guarding or other means to completely remove the hazard. If this is not possible, then Administrative measures such as training, job rotation, instructional signage, etc. should be used to reduce or eliminate the hazard.
Lastly in the line of progression, PPE must be issued and used to protect employees against a specific form of hazard. Examples are flying particles of debris from a grinding operation, harmful UV radiation from welding or torch cutting, sharp edges on materials being handled, etc. Once identified, these hazards are subject to controls according to the hierarchy. PPE is the least desirable control, but regrettably, the first one most organizations reach for.
While this is understandable, a more defensible approach is to have a documented PPE Assessment in your files, that explains why you cannot engineer or otherwise eliminate this hazard. The assessment shows that your aware of the hazard, have evaluated its nature and scope and tried to reduce or eliminate it. At the end of this evaluation, you have determined that PPE is a viable option in the hazard reduction process.
For each piece of PPE in your inventory, the assessment will reference the hazard. It will describe the selection, use, maintenance and other details surrounding your decision. Employee involvement in this process is highly desirable. This is a good example of Safety Committee input to your program.
- How to recognize and identify a hazard in your workplace – specific things to look for
- Examples of common workplace hazards and how to eliminate them
- Trade-specific tips and reference for PPE selection & use
- Do’s and Don’ts for conducting a proper Risk Assessment
- References, sources of information, standards and general metrics applicable to the process
- Employee training requirements under the PPE Standard
- Who pays for PPE? (The employer, usually, but there are some exceptions)
- The importance of SME’s and vendor support
- Why having a Safety Committee is integral to the assessment process
- Sample language to help you get started on writing an assessment
- Keywords and terminology, the vocabulary of PPE; definitions and distinctions
- How to ‘leverage’ PPE use to increase organization safety awareness
- What constitutes PPE and who pays for what under OSHA
Course Level - Basic to Intermediate
Who Should Attend
- Safety Managers, Directors; safety technicians; safety committees; managers, supervisors, executives; superintendents; mechanics, helpers, foremen, leadmen; machine & equipment operators; sign installers, outdoor advertising; drillers; QA/QC personnel,
- Purchasing agents & buyers
- OSHA and State Plan officials
- Insurance Loss Control representatives
- Personal injury attorneys; paralegals
- Woodworkers; painting & coatings
- Foundry; metals casting; job shops
Why Should You Attend
Many safety professionals and small to medium business operations completely overlook the point of doing an assessment. Traditionally accepted practice is to buy a box of safety glasses, or glove, or hard hats, etc. and hand them out, and put up a sign saying “Safety Glasses (or whatever) Must Be Worn In This Area”.
For work activity where PPE forms critical protection, such as fall protection, hot work, etc. the assessment can become an important element in helping prevent injuries. In the event of an OSHA accident investigation, you could be asked to produce your safety records and documentation. Failure to have a PPE assessment on file is a key area of vulnerability.
The assessment needs to be a documented and coordinated activity, and should rightly engage all levels of an organization, namely employee involvement (Safety Committee) supervisory and managerial input, and possibly even vendor support. In addition to keeping your safety library up-to-date, the assessment will serve as evidence of your organizations' sincerity in managing employee safety & health.
This may not sound like much of an incentive, but it will be worth its weight in platinum during an Informal Conference following an OSHA inspection or investigation. Incidentally, OSHA has recently announced another round of penalty increases. The credit OSHA will offer you for having done a PPE assessment could well translate into a penalty reduction. If your organizations are reliant on PPE to any extent, you need to have a well-defined assessment on file. It’s not all that hard, and this webinar will walk thru the process.
The OSHA General Industry Standard 1910.132 requires that an employer assess their workplace to determine if hazards are present, or reasonably anticipated to occur, which may necessitate the use of PPE by employees. This same process can be used to address Construction site hazards, although OSHA recognizes the nature of construction and related trade activity creates a different set of measurement parameters.
The result is, if you sincerely want to create a strong and effective safety culture in your organization, PPE is considered an extremely important element in the process. The Assessment is a fairly straightforward process but it does require a dedicated effort. And it only needs to be done ONCE, unless something changes, and then a revision is warranted.