OSHA updates PPE standards.

Personal protective equipment revisions require more training and responsibility for employees and more active roles for employers.

As the first national safety and health law, the Occupational Safety and Health Act of 1970 established standards requiring employers to provide their workers with workplaces free from recognized hazards that could cause serious injury or death. The Act covers more than one million employers and more than 90 million employees throughout the U.S.

Personal protective equipment (PPE), a major part of the Act, is designed to protect workers from health and safety hazards that cannot practically be removed from the work environment. In general, PPE comprises clothing and accessories that create a barrier between workers and hazards.

Using PPE requires hazard awareness and training on the part of the user. Employees must be aware that PPE does not eliminate hazards and should not be used as a substitute for engineering, work practice and/or administrative controls. PPE should be used along with these controls to provide safety in the workplace.

Recently, there have been some important revisions to the general OSHA requirements governing the use of PPE. OSHA's Personal Protective Equipment Standard 29 CFR 1910.132-.140 went into effect October 5, 1994. These revisions require employers to select appropriate PPE based on hazard assessments, ensure. that PPE is not defective or damaged and train employees in the proper use of PPE.

According to OSHA estimates, employers will initially spend $52.4 million to comply with the role - this cost includes employee training and hazard assessments - but employers will save $150 million per year by reducing worker injuries and fatalities. Additionally, an estimated 712,000 lost workdays could be prevented.

The PPE Standard for general industry was developed by OSHA using a "performance oriented" approach. This allows employers to determine the best protection in a given situation and gives them more freedom in selecting PPE.

Protection from workplace hazards requires not only the selection of appropriate PPE, but also a successful management program to monitor its use and effectiveness. OSHA notes in a number of standards and regulations that there is a strong correlation between the application of sound management practices and a lowered incidence of workplace-related injuries and illnesses. Without the visible involvement and commitment of management, it is difficult to convince others to comply.

Hazard Assessments

The first revision mentioned requires employers to assess the workplace to determine if hazards that require PPE are present or are likely to be present.

The first step in the assessment process should include a walk-through survey of the work areas.

During the walk-through survey, the safety officer should observe possible sources of motion, ignition and light radiation; source locations where objects could potentially fall or roll; or possible electrical hazards. The data should be organized and evaluated, and the appropriate PPE should be selected for each job.

Employers must certify in writing that a workplace hazard assessment has been performed.

Training

Once the PPE has been selected, employers must train employees to know when PPE is necessary, how it is to be worn and what its limitations are, as well as know its proper care, maintenance, useful life and disposal. Classroom training may be conducted, with an instructor available to answer employees' questions. A videotape is not considered sufficient training. Employers are required to certify in writing that training has been carried out, and employees should be able to demonstrate an understanding of the training and an ability to properly use PPE, before being allowed to work using it.

Workers should be retrained if employers believe they do not understand the training points or have not retained the understanding or skill; if changes in types of PPE to be used render previous training obsolete; or if there are changes in the workplace.

According to Jack Schuldt, Safety Specialties, Inc., training should begin with management and move on to employees. "The same rules should apply to everyone who steps foot in the foundry, employees, management and even suppliers."

Defective and Damaged PPE

In April of 1994, a new paragraph regarding defective and damaged equipment stated that defective or damaged PPE may not be used. Not only does this include defects that are visually observed, but other methods, such as performance tests to assure integrity, should also be used to determine whether or not PPE is performing its intended function.

Specific Types of PPE

According to a report by Coastal Video Communications Corp., nearly two million people are expected to receive disabling work-related injuries this year. More than one fourth of these injuries will involve the head, eyes, hands or feet.

Head Protection - A survey of workplace-related accidents and injuries by the Bureau of Labor Statistics (BLS) noted that most impact injuries to the head were caused by not wearing head protection. The majority of workers were injured while performing their normal jobs at their regular work sites.

Head injuries are caused by falling or flying objects, or by bumping into a fixed object. Head protection, in the form of protective hats, must do two things - resist penetration and absorb the shock of a blow.

OSHA states that employees must also wear protective helmets designed to reduce electrical shock when near exposed electrical conductors that could contact the head. Protective helmets purchased after July 5, 1994 must meet the requirements of ANSI Standard Z89.1-1986.

Eye and Face Protection - Both the original and revised standards require eye and face protection when the potential for hazards to the eye and face exist. OSHA studies show that when eye protection is used, most injuries occur because flying objects go around the protective device. Particularly important to foundry employees, Section 1910.133 (a)(1) requires that front and side protective devices be worn if employees face a hazard from flying particles, molten metal, liquid chemicals, acids, or caustic liquids, chemical gases or vapors or potentially injurious light radiation.

Source operations involving heat hazards include furnace, casting and welding operations. Workers can be protected from hot sparks by using goggles and spectacles with side protection. Severe exposures require the use of a face shield, along with spectacles or goggles. A face shield worn over goggles will protect workers from possible molten metal splashing.

Additionally, if an employee is required to wear prescriptive lenses, eye protection should either incorporate the prescription in its design or fit over the prescription.

Employees must also use eye protection against injurious light radiation. OSHA requires that affected employees use equipment with filter lenses that have a shade number appropriate for the work being performed. A table is provided in 29 CFR 1910.133.

Arm and Hand Protection - Fingers, hands and arms are injured more often than any other part of the body. The new standard defines when hand protection is necessary and the criteria for selecting the appropriate kind.

Gloves are the most common protectants for the hands. Employers need to determine what hand protection their employees need and select gloves according to their performance characteristics relative to the specific hazard anticipated. These hazards include both physical hazards, such as abrasions and punctures, and hazards from chemical exposures. For example, foundry workers wear gloves that provide thermal protection against molten metal splashes, while meat cutters wear gloves that protect against cuts.

Foot Protection - Foot injuries are most likely to occur when a heavy or sharp object falls on the foot, when something rolls over the foot or when an object pierces the sole of the shoe.

The new standard requires that safety footwear provides both impact and compression protection and protection from electrical hazards.

Ear/Hearing Protection - Exposure to high noise levels can cause hearing loss or impairment and can create physical and psychological stress. Hearing loss is a common workplace injury, but it is usually ignored because it happens gradually.

OSHA's Noise Standard 29 CFR 1910.95 requires that protection against the effects of noise exposure must be provided when sound exceeds designated levels.

Employers must administer a continuing, effective hearing conservation program whenever noise exposures equal or exceed an eight-hour time-weighted average (TWA) sound level of 85 decibels.

Employers are required to conduct workplace remonitoring when there are significant changes in machinery or production processes that could result in increased noise levels and an annual employee training program should be instituted for all those who are exposed to excessive noise levels. The program should be facility specific but must cover the effects of noise on hearing; the purpose of using hearing protectors; instructions on selection, fitting, use and care of hearing protectors; and the purpose of testing.

Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and their related costs. PPE can be effective only if the equipment is selected based on its intended use, employees are trained in its use and the equipment is properly tested, maintained and worn. It is the employer's responsibility to inform workers about PPE, but it is the employees' responsibility to wear it.