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1. Hazard assessment for personal protective equipment: An investigative process...................................... 1

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Hazard assessment for personal protective equipment: An investigative process

Author: Foster, Roger W Publication info: Professional Safety 41. 4 (Apr 1996): 30. ProQuest document link Abstract: OSHA has revised original portions of its general industry standards that address personal protective equipment. The revisions included in 29 CFR 1910 Subpart 1, have been in effect since October 1994. The agency initiated these changes so the standard would be consistent with current good industry practices. In the requirement employers must: conduct and document a walk-through hazard assessment and equipment selection program, review all hazard types, organize and analyze data, eliminate hazards where possible, select proper PPE and ensure usage, communicate selection decisions to affected employees, address PPE maintenance and restrain when necessary. By following a logical approach to hazard analysis and applying a good-faith effort to risk analysis, safety professionals can meet the performance-oriented intent of this part of the standard. Full text: Recognizing the need for industry emphasis on personal protective equipment (PPE), OSHA has revised original portions of its general industry standards that address PPE requirements. The revisions, included in 29 CFR 1910 Subpart I, have been in effect since October 1994. The agency initiated these changes so the standard would be consistent with current good industry practices. According to Assistant Secretary of Labor Joseph Dear, "The standard updates requirements to reflect current technology and improvements in PPE , adds provisions for assessing hazards and employee training, and fills gaps in protection." Specifically, employers must: * conduct and document a walk-through hazard assessment and equipment selection program; * review all hazard types; * organize and analyze data; * eliminate hazards where possible; * select proper PPE and ensure usage; * communicate selection decisions to affected employees; * address PPE maintenance; * retrain when necessary. OSHA estimates that the standard will save four lives and 700,000 lost workdays per year. It will also prevent 65,000 non-lost workday injury cases. In addition, employers can reportedly expect a $3 savings in workers' compensation costs for every $1 spent on PPE. HAZARD ASSESSMENT FOR PPE A significant requirement of the standard is contained in 29 CFR 1910.132. This section mandates that a workplace assessment be conducted to determine whether hazards requiring PPE are present or are likely to be present. This assessment must be verified via written certification which identifies the workplace evaluated, the person certifying that the evaluation was performed and date(s) it was performed. This document must be identified as certification of hazard assessment. Figure 1 shows a sample form that can facilitate compliance. PPE 101: THE BASICS PPE is required whenever hazards can cause injury or illness through absorption, inhalation, physical contact or ingestion. However, PPE should be considered the last line of defense against hazards--to be utilized only when more effective means of elimination or mitigation have been exhausted. These other means (in order of importance) are: 1) engineering controls, such as job redesign or machine guarding; 2) administrative controls, such as job rotation or employee training. PREPARING FOR THE ASSESSMENT The assessor should be knowledgeable about safety hazards in a particular work environment. Although a safety manager is the logical choice, alternatives include supervisors (who could assess hazards in their individual areas) or a team comprised of safety or inspection committee members. Insurance company loss control representatives, consultants and state consultation services a other potential candidates. Pre-assessment hazard training shows the assessor how to conduct an effective walk-through. All requirements of the OSHA standard should be thoroughly reviewed, and he assessor should receive formal hazard recognition training. This individual must be familiar with potential hazards. As a guide, common hazard types can be listed in the fit column of the evaluation worksheet (Figure 1). (Figure 1 omitted) THE "FRONT 16 April 2013 Page 1 of 4 ProQuest

OFFICE" ASSESSMENT Existing written programs and established PPE practices are the most logical starting point. This "front office" (or initial paperwork) phase of the assessment is where the sleuthing process begins. Worksheets shod be completed to the greatest degree possible before beginning the walk-through; this allows the assessor to focus on verifying the effectiveness of PPE usage and identifying new hazards. In other words, the assessor does not want to miss previously unidentified hazards by trying to complete all forms while on the plant floor. To facilitate the assessment, worksheets should be organized in manageable segments, such as by department or work cell. Paperwork review should include the OSHA 200 Log, first-aid records, accident investigation reports and related data. The assessor should identify what types of accidents and illnesses could have been prevented by use of PPE. That person should also record areas where PPE is currently required and review employee suggestions for possible PPE needs. The next step: to review current PPE usage, as delineated in written safety programs and related documentation (i.e., plant safety rules). Each employee's PPE requirements need not be recorded; rather, similar job categories or general tasks that require PPE can be grouped and summarized. Material safety data sheets are a valuable resource for identifying specific requirements, as are job hazard analyses (JHAs) and standard operating procedures. Once all possible PPE requirements have been documented from the "front office," the walk-through can begin. THE INVESTIGATIVE WALK-THROUGH Now it is time to don a detective (hard) hat and begin the active investigative phase of the hazard assessment. The assessor should bring necessary assessment tools such as noise level meters or air sampling equipment. (If industrial hygiene sampling data is current, this may not be necessary.) All areas and shifts, as well as infrequent or seasonal jobs, should be assessed. As each section of the facility is evaluated, the primary goals are to: 1) verify the accuracy and adequacy of pre-identified PPE requirements; and 2) evaluate work areas for additional requirements. Beyond verifying the effectiveness of predetermined PPE, the assessor should observe plant activities with "fresh eyes." Following are potential hazards to consider throughout the investigative process. (A similar list can be used in conjunction with the worksheet to "jog" the assessor's memory.) * motion (i.e., machinery); * temperature extremes; * chemical exposures; * light radiation (i.e., welding); * falling objects; * sharp objects; * rolling or pinching foot hazards; * workplace layout, employee location; electrical hazards. Again, however, the assessor should keep in mind that PPE is the last defense against a hazard. JHAs should be conducted to determine whether PPE is the most feasible, effective means of protection. The assessor should also remember that the worksheet is just that; if unsure about risk analysis or appropriate PPE in an area, the assessor should flag that section to indicate that further analysis is required. Each worksheet should be signed and dated; this certifies that the hazard analysis has been conducted. HAZARDS ANALYSIS AND PROGRAM DEVELOPMENT Once the initial hazard assessment is complete, data must be organized and analyzed. In Appendix B to Subpart I (non-mandatory guidelines), OSHA states, "It should be the responsibility of the safety officers to exercise common sense and appropriate expertise to accomplish these tasks." The assessor should review all data in order to make a good-faith determination of the level of risk and the seriousness of potential injuries or illnesses. If questions remain, industry peers and professional organizations can provide information on how others have handled similar situations. Even if no serious injury has occurred in a particular area, the potential for such injury may exist if the right hazardous conditions arise. OSHA regulations, publications; and PPE-related information can also be consulted, as can OSHA letters of interpretation, which may clarify specific requirements. (Much of this information is available on CD-ROM from OSHA's information office.) Other resources include National Institute for Occupational Safety and Health (NIOSH), American National Standards Institute (ANSI) and American Conference of Governmental Industrial Hygienists (ACGIH). Information obtained should be used to develop a written PPE policy and program, which can then be incorporated into the company's safety manual. CONCLUSION Although a potential pitfall, the PPE standard need not be cited often by OSHA. By following a logical approach to hazard analysis and applying a good-faith effort to risk analysis, safety professionals can meet the performanceoriented intent of this part of the standard. In addition, hazard assessment for PPE brings with it many 16 April 2013 Page 2 of 4 ProQuest

concomitant benefits: Hazards are eliminated, written programs reviewed, the JHA process enhanced, adverse trends documented, unsafe acts mitigated and previously hidden hazards identified. National Safety Council. "Personal Protective Equipment." In Accident Prevention Manual for Business &Industry -- Engineering &Technology. 10th ed. Chicago: National Safety Council, 1992. Personal Protective Equipment For General Industry. Abstract and Summary of OSHA's Final Rule &Amendments to Part 1910 Subpart 1. Washington, DC: Dept. of Labor, OSHA. Roger W. Foster CSP, M.S., is a safety and injury management consultant for Marsh &McLennan Protection Consultants in Boston. He provides specialized services to international clients in various industries. Foster is a professional member and current Secretary of ASSE's Boston Chapter. Subject: Safety management; Risk assessment; Personal protective equipment; Occupational safety; Hazardous substances; Federal regulation; Compliance Location: US Classification: 9190: US; 5340: Safety management; 4310: Regulation Publication title: Professional Safety Volume: 41 Issue: 4 Pages: 30 Number of pages: 3 Publication year: 1996 Publication date: Apr 1996 Year: 1996 Publisher: American Society of Safety Engineers Place of publication: Des Plaines Country of publication: United States Publication subject: Public Health And Safety, Occupational Health And Safety ISSN: 00990027 CODEN: PRSAD5 Source type: Scholarly Journals Language of publication: English Document type: PERIODICAL Accession number: 01203107 ProQuest document ID: 200419764 Document URL: http://search.proquest.com/docview/200419764?accountid=49672 Copyright: Copyright American Society of Safety Engineers Apr 1996 Last updated: 2010-06-06 Database: ABI/INFORM Complete

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