Personal Protective Equipment (PPE) Requirements and Usage

This document outlines the requirements for personal protective equipment (PPE) and its proper usage to ensure worker safety and regulatory compliance. It addresses hazard assessment, PPE selection, training, maintenance, and related legal obligations.

Hazard Assessment and Equipment Selection

Employers are required to assess the workplace to identify hazards that necessitate the use of PPE. This assessment should identify potential hazards like chemical exposures, radiological hazards, or mechanical irritants that could cause injury through absorption, inhalation, or physical contact. Based on this assessment, employers must select and ensure that employees use appropriate PPE that protects them from the identified hazards. [4] [5]

The selection of PPE should consider all potential routes of hazard to employees, including inhalation, skin absorption, ingestion, and eye or skin contact. The performance of PPE materials in providing a barrier to these hazards is also critical, as the amount of protection provided is material-hazard specific. [3]

Types of Personal Protective Equipment

A variety of PPE is available to protect workers from different hazards:

• Eye and Face Protection: Safety glasses, goggles, face shields protect against flying particles, chemical splashes, and radiant energy.
• Head Protection: Hard hats protect against impact, penetration, and electrical shock.
• Hand Protection: Gloves protect against cuts, abrasions, burns, and chemical exposure.
• Foot Protection: Safety shoes and boots protect against impact, compression, and punctures; may also provide protection against electrical hazards or chemical exposure.
• Body Protection: Vests, aprons, coveralls, and full body suits protect against cuts, abrasions, chemical splashes, and extreme temperatures.
• Hearing Protection: Earplugs and earmuffs protect against noise exposure.

Specific examples of PPE and their use include:

• Workers handling rough, sharp-edged, or abrasive materials should wear suitable hand protection to prevent lacerations, punctures, burns, and bruises.
• When exposed to hazards such as radiation, alkalies, acids, abrasives, and temperature extremes, appropriate head, body, and hand protection must be worn.
• Employees working over or near water where a drowning hazard exists must wear a U.S. Coast Guard-approved life jacket or buoyant work vest.

Proper Use and Maintenance of PPE

To ensure PPE is effective, it must be used and maintained correctly:

• Defective or damaged PPE must not be used.
• PPE must be of safe design and construction for the work being performed.
• PPE must be properly fitted to each employee.
• A regular system of inspection and maintenance of PPE must be maintained.

Employees must be trained on how to properly don, doff, adjust, and wear PPE, as well as its limitations, proper care, maintenance, useful life, and disposal. Retraining is necessary when changes in the workplace or types of PPE render previous training obsolete, or when an employee's knowledge or use of PPE is inadequate. [2]

Employer Responsibilities

Employers have several key responsibilities regarding PPE:

• Ensuring workers use appropriate PPE.
• Providing instruction on what PPE is needed and how to maintain and clean it.
• Educating and training workers on the proper use of PPE.
• Providing approved PPE at no cost to the worker (with some exceptions).
• Ensuring PPE is available at the work site before work begins.
• Storing PPE in a clean, secure, and readily accessible location.

Employers must also verify that a workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying the evaluation, and the date(s) of the assessment. [2]

Payment for PPE

Generally, employers are required to provide and pay for PPE necessary to protect employees from workplace hazards. However, there are exceptions:

• Employers are not required to pay for non-specialty safety-toe protective footwear and non-specialty prescription safety eyewear, provided that these items can be worn off the job site.
• Employers are not required to pay for everyday clothing, ordinary weather gear, or upgraded/personalized PPE that exceeds requirements, provided adequate PPE is offered at no cost.

The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE. [7]

Hierarchy of Controls and PPE

PPE is considered a lower-level control method in the hierarchy of controls. It should be used as an interim measure before more effective controls are implemented, where other controls are not available or adequate, during activities like maintenance and repair, or during emergency situations. [1]

A comprehensive strategy involves identifying all hazards, conducting risk assessments, considering all possible control methods from the hierarchy of controls, integrating various approaches, and evaluating the controls frequently. [1]

Levels of Protection (A, B, C, D)

Personal protective equipment is divided into four categories (A, B, C, and D) based on the degree of protection afforded. Level A provides the greatest level of skin, respiratory, and eye protection and includes a positive pressure, full face-piece self-contained breathing apparatus (SCBA), or positive pressure supplied air respirator with escape SCBA, a totally-encapsulating chemical-protective suit, and chemical-resistant gloves and boots. [6] [6]

Compliance and Regulations

Compliance with applicable laws, regulations, standards, and guidelines is essential. Employers must stay informed about specific PPE requirements in their jurisdiction, as regulations can vary. [1]

Training Requirements

Training is a critical component of PPE compliance. Employers must provide training to each employee required to use PPE, ensuring they understand:

• When PPE is necessary.
• What PPE is necessary.
• How to properly don, doff, adjust, and wear PPE.
• The limitations of the PPE.
• The proper care, maintenance, useful life, and disposal of the PPE.

Employees must demonstrate an understanding of the training and the ability to use PPE properly before being allowed to perform work requiring its use. Retraining is required when changes in the workplace or PPE types occur, or when an employee's knowledge or skill is inadequate. [2]

Conclusion

Ensuring safety and compliance with regulations requires a comprehensive approach to PPE, including hazard assessment, proper selection, use, and maintenance of equipment, and thorough employee training. Employers must stay informed of their responsibilities and provide the necessary resources to protect their employees from workplace hazards.

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