A comprehensive personal protective equipment (PPE) program not only can be one of the easiest safety and health programs your company can implement and maintain, but it also can be one of the most beneficial.
The level of PPE usage, however, has lacked in the past, partly because of style and comfort issues. PPE manufacturers understand the importance of developing and improving the design by making products more comfortable, fashionable and easier to use. The better it feels, looks and goes on, the more likely it is to be implemented.
The Occupational Safety and Health Administration (OSHA) has cited employers for not protecting their employees from jobsite hazards that may be reduced or eliminated through the use of PPE. OSHA covers PPE and life-saving equipment in the construction industry in 29 CFR 1926 Subpart E. OSHA's coverage of PPE, however, is broad and relies heavily on American National Standards Institute voluntary standards. Remember that OSHA standards are only minimum standards, and employers can implement more stringent requirements at their discretion.
Your company's safety and health program should include a PPE program with many, if not all, of the following:
- Eye and face protection, such as safety glasses, safety goggles, safety side shields, face shields and laser welding shields;
- Hand protection, such as gloves and barrier creams;
- Head protection, such as hard hats;
- Hearing protection, such as earplugs and ear muffs;
- Foot protection, such as boots with metatarsal guards and puncture-resistant soles;
- Body protection, such as high-visibility vests, coveralls, welding leathers, life jackets or buoyant work vests, chemical suits and skin protection (sun block);
- Respiratory protection, such as half-face, full-face and supplied-air respirators and two-strap irritant dust masks; and
- Fall protection, such as personal fall arrest systems, harnesses and lanyards.
Employees can provide their own PPE. The employer, however, must ensure the PPE is adequate for the job and is maintained properly, including proper sanitation. OSHA can cite an employer for an employee's personally purchased PPE if it does not meet standards.
Last Line of Defense
Personal protective equipment is an important aspect of every construction jobsite in protecting the worker. PPE, however, is the last line of defense when it comes to protecting the construction worker.
First, look at administrative and engineering controls to reduce and maintain worker exposure below unsafe levels. Administrative controls, for example, may be the use of a less toxic material that does not require workers to wear respiratory protection or the rotation of employees to reduce exposure levels. Then look to engineering controls, such as using ventilation systems, to eliminate the respiratory hazard.
Companies often overlook the hierarchy of controls when bidding a job or preparing to work. There are numerous opportunities on construction jobsites to reduce or eliminate a hazard or hazardous situation by proper preplanning.
Keys to Success
To ensure success in a construction PPE program, elements should include preplanning; selection, education and use of PPE; care, inspection and maintenance of PPE; management evaluation; and recordkeeping.
Preplanning. Preplanning, necessary in any successful construction operation, should include a prejob and an onsite survey of potential hazards.
A great source of information during the survey is material safety data sheets (MSDS) for chemicals and hazardous products used on the job.
The MSDS lists hazards associated with a chemical or a product being used, explains how to use it properly and recommends a type of PPE.
After determining potential hazards, the significance of that hazard -- including type of injury or illness, opportunity for occurrence and severity of injury or illness -- should be determined. Next, determine the viability of eliminating or reducing the hazard using administrative or engineering controls.
Selection, education and use. If administrative and engineering controls cannot work adequately for a specific operation, select appropriate PPE. Choosing the appropriate PPE for a specific task or operation is an important step in the selection process.
With the overwhelming assortment of PPE models and sizes available and the endless situations requiring PPE, it is important to involve several employees. These include the person responsible for purchasing the equipment, the safety professional, the supervisor or foreman overseeing the PPE and the worker who will wear the PPE.
After equipment selection, educate all workers required to wear PPE in the proper use of it, including:
- What, when and why it is necessary;
- How to wear, adjust, properly fit and remove it;
- Signs of end of service; and
- Proper care and maintenance.
Workers should demonstrate an understanding of PPE and how to properly use it before wearing it. Educating and re-educating workers on PPE may be one of easiest ways to increase usage on jobsites.
Care, inspection and maintenance. Clean and maintain PPE regularly and according to the manufacturer's recommendations. The proper storage of equipment is also critical to the service life of that equipment.
Proper storage often requires a dry and clean place that is not subject to temperature extremes. A hard hat hanging in the back window of a truck, for example, may suffer sun and heat damage that prematurely ages the shell, reducing worker protection.
Inspect PPE before each use. With most PPE, it only takes a few minutes to inspect the equipment for any breaks, tears and visible signs of stress or damage.
Immediately remove from service any damaged equipment until a competent person or a manufacturer's representative can certify the equipment for use. If not authorized by a manufacturer to repair PPE, do not attempt to fix it.
Management evaluation. As with all safety and health programs, a successful PPE program must be evaluated from time to time or as conditions or operations change to ensure the program is current and provides adequate protection for the workers.
Recordkeeping. A comprehensive PPE program must have a recordkeeping component, which includes signatures of those trained and lists PPE on which they were trained, those who conducted the training, date of training and topics covered.
Rules Are Rules
In a company's comprehensive safety and health program, there must be a clear policy covering discipline for any worker violating a safety and health policy or procedure. This policy must address the nature of the consequences and progressive discipline steps for any worker not wearing the required PPE.
Consistently enforce safety and health policies and procedures for all workers, including management. If policies and procedures cannot or are not being enforced, rewrite or eliminate them.
Why Does It All Matter?
Personal protective equipment is something all construction workers have to wear during their careers in the construction industry. It is as much a "tool of the trade" as a hammer to a carpenter. Worker attitudes toward PPE must be one of "I am wearing this for me." Requiring and wearing PPE may be one of the best business and personal decisions one can make.
Carl Heinlein, CSP, OHST, is director of construction services for FDR Safety, based in Nashville, Tenn. He previously was director of safety and health services for Associated General Contractors of America.