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Personal Protective Equipment Standards

Quick Tips #240

Background

The original personal protective equipment (PPE) standards for general industry went into effect on August 27, 1971. The Occupational Safety and Health Administration (OSHA) determined that these standards needed to be revised because they reflected the knowledge and practices of the 60s and 70s, and limited the use of new technology. OSHA also found that injuries were occurring to employees whether they wore PPE or not.

The revised personal protective equipment standards (29 CFR Part 1910) went into effect July 5, 1994. These include:

The revised personal protective equipment standards address five main areas:

  1. Current American National Standards Institute (ANSI) guidelines
  2. Hazard assessment for each employee work area
  3. Use of defective PPE
  4. Employee training
  5. Properly fitting PPE

A Look at the Updated Standards

29 CFR 1910.133: Eye and Face Protection

Per OSHA, the Eye and Face Protection Standard states: “The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.” The protection must comply with any of the ANSI (American National Standards Institute) Z87.1-2003/1989 American National Standard Practice for Occupational and Educational Eye and Face Protection consensus standards. Although not included in the OSHA standard, the ANSI standard was updated to ANSI Z87.1-2010. (See Quick Tips #125: Personal Protective Equipment (PPE) Requirements for more information on the standard and safety glasses selection. Also, see Quick Tips #315: Safety Goggles: Types, Uses and Cleaning of goggle selection, and Quick Tips #373: Face Shield Protection for information on face shields.)

29 CFR 1910.135: Head Protection

The Head Protection Standard states: “The employer shall ensure that each affected employee wears a protective helmet when working in areas where there is a potential for injury to the head from falling objects. The employer shall ensure that a protective helmet designed to reduce electrical shock hazard is worn by each such affected employee when near exposed electrical conductors which could contact the head.” The protection must comply with any of the ANSI Z89.1-2009/2003/1997 American National Standard for Industrial Head Protection consensus standards. (See Quick Tips #241: Hard Hat Requirements for complete standard information.)

29 CFR 1910.136: Occupational Foot Protection

The Foot Protections Standard states: “The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where such employee's feet are exposed to electrical hazards. Protective footwear must comply with any of the following consensus standards: ASTM F-2412-2005: Standard Test Methods for Foot Protection, (American Society for Testing and Materials), ASTM F-2413-2005: Standard Specification for Performance Requirements for Protective Footwear, ANSI Z41-1999/1991: American National Standard for Personal Protection - Protective Footwear. (See Quick Tips #252: Protective Footwear Standards for complete standard information.)

29 CFR 1910.138: Hand Protection

Employers must select appropriate hand protection for employees exposed to hazards such as those from skin absorption of harmful substances, severe cuts or lacerations, severe abrasions, punctures, chemical burns, thermal burns and temperature extremes.

Employers should select appropriate hand protection relative to the application, present conditions, duration of use and any hazards or potential hazards identified in the hazard assessment. (See Quick Tips #191: Chemical Resistant Gloves Guide for information on chemical protective gloves, Quick Tips #262: Electrical Safety Gloves: Inspection and Classification for electrical protective gloves and Quick Tips #301: Cut-Resistant Glove Selection and Use for cut-resistent gloves. Quick Tips #306: Safety Glove Size Chart contains information on glove sizing.

29 CFR 1910.132: General Requirements

Because of the increase of females in the workplace, OSHA felt that wording was needed to accommodate all sizes of workers.

The general requirements section includes information on hazard assessment, training and defective PPE.

Hazard Assessment (1910 Subpart I Appendix B)

The general requirements require the employer to conduct a hazard assessment (walk-through survey) of each work area and certify that it has been done. This certification must show the date of assessment, workplace evaluation and the name of the person certifying the evaluation. The survey should consider the following items:

  • Impact
  • Penetration
  • Compression (roll-over)
  • Chemicals
  • Heat
  • Harmful dust
  • Light (optical) radiation

After the survey has been completed, the employer shall select proper PPE to suit the hazards. Employees who purchase their own equipment must follow the same criteria the employer uses.

Training

Employees must be trained in several aspects of PPE. These include, but are not limited to:

  • When they must wear PPE
  • What type of PPE is necessary
  • How to properly don, doff, adjust and wear PPE
  • Care, maintenance, useful life and disposal of PPE

To ensure each employee is properly trained, clear measurable objectives should be thought out. Since the regulation requires the employee to demonstrate an understanding of the above list, objectives should center around these criteria. For example, in reviewing limitations of gloves, the employee should know about permeation and breakthrough times of the chemicals they are dealing with. They should also know how to clean and inspect the gloves and how to properly dispose of a glove that cannot be decontaminated.

The employer must verify that all the necessary training has been provided. A written certification showing the name of the employee and the date of training is required. The document must be identified as a certificate of training. Retraining must be completed if there is a change in workplace conditions, a change in the PPE used or the employee demonstrates inadequacies in the skills required to use the PPE.

Defective PPE

The general requirements section indicates defective or damaged PPE shall not be used. It covers all defects or damages—not just visible ones. Employees can determine if the protective ability of the PPE has been compromised by handling or donning the equipment.

Payment of PPE

While some OSHA standards specifically require the employer to pay for PPE, this standard was silent on the issue. It did not explicitly address the issue of payment for personal protective equipment. OSHA established a nationwide policy on the issue of payment for required PPE in a memorandum to its field staff in 1994. However, the Review Commission declined to accept the interpretation embodied in the 1994 memorandum as it applied to a specific citation issued. This led to OSHA issuing a proposed standard on March 31, 1999, which became a final rule on February 13, 2008.

This rule outlines what is required of employers in regards to the payment of the PPE. It does not set forth any new requirements regarding the PPE that must be provided. The rule also provides clarification on:

  • Replacement of PPE
  • Employee-owned PPE
  • Upgrading PPE
  • PPE for which employer payment is required
  • Acceptable methods of payment
  • Affect on existing union contracts

The full rule can be viewed in the Federal Register dated November 15, 2007 pages 64341-64430.

As an addendum, OSHA came out with a clarification to the rule regarding how they will treat violations of the personal protective equipment standard by employers. Because PPE and training is to be provided to each and every employee covered by the standard, employers will be cited for each violation separately. This clarification does not add any new compliance burdens, but makes clear that each violation will be treated as a separate citation.

Commonly Asked Questions

Q.   Are employers required to select PPE that meets ANSI standards?
A.   The revised personal protective equipment standards require employers to select PPE that either meets ANSI standards or is equally effective.
 
Q.   When is a reassessment of work areas needed?
A.   Work areas must undergo a hazard assessment any time there is a process change, new equipment is used or accident statistics point to a problem area.
 
Q.   Do these revisions address respirators?
A.   No. 29 CFR 1910.134, Respiratory Protection and 29 CFR 1910.137, Electrical Protective Devices were not addressed with these revisions. They were discussed separately at a later date.

 

Sources

OSHA 29 CFR Part 1910

www.osha.gov

(Rev. 9/2014)


Find even more information you can use to help make informed decisions about the regulatory issues you face in your workplace every day. View all Quick Tips Technical Resources at www.grainger.com/quicktips.

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Please Note:
The content in this newsletter is intended for general information purposes only. This publication is not a substitute for review of the applicable government regulations and standards, and should not be construed as legal advice or opinion. Readers with specific compliance questions should refer to the cited regulation or consult with an attorney.


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