All of the activity above, below and on the ground at a construction worksite can create hazards for your employees and for contractor employees. One way to protect your employees is by providing appropriate personal protective equipment (PPE).
The General Duty Clause of the OSH Act indicates that the 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.” PPE is the last line of defense, used when administrative controls (like scheduling work so that trades people are not in the same area at the same time) and engineering controls (such as designing the jobsite so that hazards are far enough away from employees so there is no exposure) have been exhausted and hazards remain.
The basic element of any PPE management program should be an in-depth evaluation of the equipment needed to protect against the hazards at the jobsite. What hazards are your employees exposed to or potentially could be exposed to? A hazard analysis is required to provide you with the knowledge of those hazards.
OSHA requires that the employer is responsible for providing and requiring the wearing of appropriate PPE in all operations where employees are exposed to hazardous conditions. In addition, if a hazard-specific regulation requires that you provide PPE, then you must do so.
There are certain exceptions where the employee pays for the PPE, such as steel-toed boots or non-specialty prescription safety eyewear, provided the employer allows such items to be worn off the jobsite.
It’s important that you train employees in the proper use of the PPE. OSHA requires at 29 CFR 1926.21(b)(2) that, “The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury.”
The use of PPE sometimes can create or contribute to hazards for the worker, such as heat stress; physical and psychological stress; and impaired vision, mobility and communication. These issues must be addressed as part of the training.
In general, the greater the level of PPE protection, the greater the associated risks. For any given situation, equipment and clothing should be selected to provide an adequate level of protection, but should not over protect the worker. Over-protection, just like under-protection, often can be hazardous and should be avoided.
Types of PPE
What PPE you provide depends on the hazards the employees are, or could be, exposed to. You also have to enforce the use of the PPE. Simply providing it is not enough.
Eye protection – Eye protection is needed when machines or operations present potential eye or face injury from physical, chemical or radiation agents.
Eye protection is one of the easiest and least expensive forms of protection. Yet each year, thousands of workers injure their eyes or lose their sight. In some cases, injury occurred not because they didn’t have the proper eye protection, but because they chose not to wear it.
Foot protection – Heavy work boots are common on construction jobsites for the protection of workers’ toes, ankles and feet. Manufacturers now offer a wide variety of protective devices and continually update materials and engineering of their products to ensure protection from new hazards.
Hand protection – Gloves are one of the most commonly used types of PPE. Gloves provide protection to fingers, hands and sometimes wrists and forearms. Ideally, gloves should be designed to protect against specific hazards of a job being performed while allowing for dexterity. Types range from common canvas work gloves to highly specialized gloves that provide cut protection for the fingers, offer protection to the back of the hand and prevent against chemical exposure.
High-visibility clothing – As mentioned earlier, jobsites can be busy and congested places. When employees are moving around on the ground, it can be hard for equipment operators to know who is working where. Plus, in less than ideal situations such as rain, fog, night work and other low-light conditions, both workers and construction equipment can be difficult to spot.
One of the most common ways to help your employees stand out on the jobsite is to have them wear high-visibility apparel. This type of clothing can include safety vests, jackets, pants and hardhats. Much of this high-visibility clothing will meet ANSI/ISEA specifications for Performance Class 2 or 3 apparel. There are different colors that can be worn, including fluorescent orange-red or yellow-green.
If you have employees performing flagging work, a Class 2 or 3 vest or jacket is required, and the workers have to be clearly visible (and identifiable as a person) at a distance of at least 1,000 feet.
Respiratory protection – Respirators are devices that prevent the entry of harmful substances into the lungs. The two basic types of respirators are:
(1) Air purifying; These remove hazardous substances from the breathing air, and
(2) Atmosphere supplying; These deliver safe breathing air from an outside source.
Respirator selection must be based on the respiratory hazard, and also must consider applicable workplace and user factors that may affect performance and reliability. Respirators must be NIOSH-certified.
Your workplace evaluation needs to include a reasonable estimate of employee exposures, and an identification of the contaminant’s chemical state and physical form. Where you cannot identify or reasonably estimate the employee exposure, the atmosphere must be considered as immediately dangerous to life or health (IDLH). Respirator selection also must consider the respirator’s assigned protection factor and the maximum use concentration for the application.
Working over or near water – OSHA regulates construction work over or near water. The purpose of the rule is to prevent drowning. Employers must:
- Provide employees working over or near water, where the danger of drowning exists, with a U.S. Coast Guard-approved life jacket or buoyant work vests.
- Inspect vests or life preservers for defects.
- Provide ring buoys with at least 90 feet of line and ensure that they are readily available for emergency rescue operations.
- Space ring buoys no more than 200 feet apart.
- Provide at least one life-saving skiff immediately available at locations where employees are working over or adjacent to water.
PPE that fits the season – By its very nature, a good deal of construction work takes place outdoors or in buildings that are not properly heated or cooled. With that in mind, you have to prepare for the changing temperatures.
Throughout the summer months, you have been providing PPE that fits the climate and temperatures in which your employees work. As mentioned earlier, heat stress can be a serious hazard related to using PPE in the summer months.
In certain parts of the country temperatures may start to cool off soon; in other areas, that will not happen for several months. Either way, you will want to plan for anticipated changes in the kinds of PPE you issue.
The danger on construction jobsites is real. The proper PPE and training can provide a measure of protection for your employees so they can go home safe and sound at the end of their work day.
Mark H. Stromme is a workplace safety editor with J. J. Keller & Associates Inc., Neenah, Wisc., where he works with the OSHA construction and general industry regulations and is an authorized OSHA construction trainer. Stromme can be reached at 920-722-2848 or via email at [email protected]