18 - PERSONAL PROTECTIVE EQUIPMENT PROGRAM
18.1 PURPOSE AND SCOPE
Personal protective clothing and equipment (PPE) shield or isolate individuals from the chemical, physical, electrical, radiological, and biological hazards that may be present in the workplace. The objectives of this PPE program are to protect students, faculty, and staff from safety and health hazards and to prevent injury through proper use of PPE. Wherever possible, engineering and administrative/work practice controls should be utilized to minimize the need for PPE.
OSHA regulates the use of PPE in Subpart I of part 29 CFR 1910, Personal Protective Equipment. The standard specifically addresses: eye and face protection, respiratory protection, head protection, foot protection, electrical protective equipment, hand protection, and hearing conservation. Respiratory protection is further regulated and is independently detailed in Section 10 of this manual.
This program applies to all students, faculty and staff who may be exposed to chemical, physical, electrical, biological, or radiological hazards while performing their regular duties.
PPE must be provided by the employee’s department wherever it is necessary by reason of hazards of operations or environment, chemical or radiological hazards, or mechanical irritants potentially causing injury or impairment in the function of any part of the body through absorption, inhalation, or physical contact.
Protective equipment as necessary, including PPE for eyes, face, head, and extremities, protective clothing, shields and barriers must be provided, used and maintained in a sanitary and reliable condition. Each employee is responsible for the care and condition of equipment that is issued to them.
Supervisors must perform regular checks to ensure that equipment is maintained as required and ensure that equipment that is damaged is promptly replaced. Supervisors shall not permit employees to conduct tasks without the proper PPE.
18.3 HAZARD ASSESSMENTS
Each University department shall assess the workplace(s) it operates and determine the hazards present which may require the use of PPE. Department chairs, directors, deans or their authorized representatives are responsible for ensuring initial and subsequent assessments are conducted. The department of Environmental Health & Safety (EHS) may assist upon request.
The hazard assessment should begin with a study of the accident history within your department. Consider how and why accidents occurred, and think of ways in which past accidents could have been prevented. Near misses should also be studied. EHS may be able to assist with past accident reports and injury logs if permissible and applicable.
A job review should then be conducted. For the review process, it is critical that each department involve their employees in the assessment process. Workers have first-hand knowledge of daily routines and duties which supervisors may often be unaware of. Consulting all levels of personnel will minimize oversights and ensure a quality assessment. Discuss with employees the hazards they know exist in their current work surroundings and together brainstorm for ideas to eliminate or control the hazards.
Examples of hazards may include, but are not limited to: thermal stresses, harmful dusts/mists/fumes/vapors, noise, vibration, radiation, electrical hazards, physical hazards, etc.
The assessment should note items including:
- sources of electricity;
- sources of motion such as machines or processes where movement could result in an impact between personnel and equipment;
- sources of heat that could results in burns, eye injuries or fire;
- types of chemicals used in the workplace, including standard housekeeping materials;
- sources of harmful dust;
- sources of light radiation, such as welding, brazing, cutting, furnaces, etc.;
- the potential for falling or dropping objects;
- sharp objects that can poke, cut, stab or puncture; and
- biological hazards such as blood or other potentially infectious materials.
After the assessment, you should be able to list jobs with hazards that present unacceptable risk, based on those most likely to occur and those which have the most severe consequences. If any hazards exist that pose an immediate danger to an employee’s life or health, take immediate action to protect the worker. Any problems that can be corrected easily should be corrected as soon as possible.
Rank the hazards and set priorities among all jobs within your department. Consider the pros and cons of various control methods to eliminate or reduce identified hazards. The most effective options are typically engineering controls that physically change the work environment to prevent employee exposure to the hazard (examples include a muffling system on a mechanical chiller to reduce noise output which eliminates the need for hearing protection, or a guardrail system around a roof to eliminate the need for fall harnesses.) Where engineering controls are not feasible, administrative controls, such as the use of personal protective equipment, may be required.
Hazard assessments must be reviewed periodically, especially when duties change, new employees begin service, accidents or near misses occur, or when hazardous work practices or misuse of personal protective equipment is observed.
The hazard assessment must be documented through a written certification which includes at a minimum: identification of the workplace evaluated, the name of the person conducting the assessment, and the date(s) of the assessment.
18.4 EMPLOYEE TRAINING
Recommendations resulting from hazard assessments must be relayed to affected personnel and Department Chairs/Directors/Deans or their authorized representatives, must ensure that the proper training is provided for each of their affected employees. EHS may assist with training upon request.
Minimum training must include: when PPE is necessary, what PPE is necessary, how to wear PPE, limitations of PPE, and proper care and maintenance of PPE. Always refer to manufacturers’ information for details on PPE use and care.
Employees must demonstrate that they have an understanding and the skills required to use the proper PPE. When there is a change in the workplace involving the use or type of PPE, affected employees must be retrained. Training must be appropriately documented and include the names of each employee trained, the date of training, and a clear identification of the subject of training.
New employees shall receive appropriate PPE training upon employment.
- flying objects (particles, nails, etc.)
- hot liquids (e.g., molten metal)
- liquid or particulate chemicals (acids, caustics, organics, etc.)
- chemical gases, vapors, fumes
- light radiation (resulting from welding, brazing or soldering operations; ultraviolet light, lasers, etc.)
Common types of Eye and Face Protection include:
Safety glasses: The most commonly used item for eye and face protection. They are designed primarily to protect from flying objects that may strike the eyes from the front. Safety glasses can be equipped with side shields which offer additional protection from flying objects that may enter the eye from the side. Clip-on slide-on shields may be used on safety glasses if they meet applicable requirements.
Street-wear eyeglasses are not designed to be safety glasses and should never be used as such.
Goggles: Protect the eyes from hazards that may strike from any angle. They are available with regular ventilation or hooded ventilation. Regular ventilation protects eyes against dust, sparks, flying objects approaching from any angle. Hooded ventilation protects eyes against chemical splashes in addition to dust, sparks, and flying objects. Straps on goggles adjust to ensure proper fit.
Face shields and welding helmets: Both devices are designed to be worn over safety glasses or goggles to protect exposed facial skin against splashes, heat, glare and flying objects. In addition, welding helmets protect against the intense light radiation from welding operations.
Welding Operations: The intense light associated with welding operations can cause serious and permanent eye damage without the use of proper eye protection. The intensity of light or radiant energy produced by welding, cutting or brazing operations varies according to a number of factors, including the task producing the light, the electrode size and the arc current. Refer to this table for the minimum protective shades for welding, cutting and brazing operations, (http://www.keengas.com/technical-tips/index_32_559999548.PDF).
All eye and face protection must meet the requirements of ANSI Standard Z 87.1, such as being durable, easily cleanable and capable of being disinfected. They must provide adequate protection, including side protection for most tasks, and shall be reasonably comfortable, fit snugly and not unduly interfere with movements. Every eye and face protector must be distinctly marked to facilitate identification of the manufacturer and ANSI Z 87.1 markings.
Persons requiring corrective lenses shall wear one of the following: Spectacles whose protective lenses provide the correction; goggles that can be properly worn over corrective spectacles; or goggles that incorporate corrective lenses. The choice of providing one of these three options will be at the discretion of the Department Head. Workplaces where there may be exposure to chemical fumes, vapors, splashes, intense heat or molten metals are not suited for contact lens use.
Safety glasses will last longer and offer more protection with proper care. Proper fit, care and maintenance of eye and face protection includes:
- Adjusting the frame periodically to prevent the glasses from sliding down the nose and to keep the lenses directly in front of the eyes.
- Always put safety glasses on and remove them with both hands. Using one hand can loosen the frames, which could impair your vision over time.
- Regularly check eye protection for damage and keep the lenses clean. When not in use, store the eye protection in a clean, dry place.
- Before cleaning glasses, flush them with clean water. This removes dirt or grit that could be ground into the lens and result in a scratch as you wipe the lens. If you cannot flush the lens, blow on the lens surface to remove dirt.
- Promptly replace any item that does not fit properly or becomes scratched, bent, or broken.
Toes, ankles and feet are exposed to a wide range of injuries at work. Wearing the proper
foot protection helps to guard against:
- injuries from objects falling onto or rolling over the feet;
- injuries from objects that could pierce the sole of a shoe or boot;
- electrical hazards;
- chemicals and solvents;
- temperature extremes;
- fungal infections caused by wetness.
Generally, personnel who may require foot protection include laboratory workers, Facilities Maintenance & Operations staff, Facilities Planning and Construction staff, and those in work in machine shops. Employees working in wet environments such as Custodial Services staff or Aquatics Center personnel may require slip-resistant footwear.
Types of Protective Footwear:
The basic safety shoe or boot is designed to guard against impact, compression, or puncture. Some common features of common safety shoes/boots include safety toes which protect against falling objects or weight pressing against the toe, cushions between the toe cap and the foot which offers comfort and insulation, steel insoles for puncture protection and/or special soles made from assorted materials for protection against a variety of hazards.
Other options in protective footwear include:
- shoes or boots with instep protection
- insulated boots for protection against extreme temperatures
- boots with built-in ankle protection
- rubber or plastic safety boots (effective against water, oil, acids, corrosives and chemicals)
- foundry shoes with elastic gores rather than laces to provide easy removal in case sparks or hot metal get inside
- add-on protection such as metatarsal guards, shoe covers, rubber spats, strap-on cleats, and puncture-proof steel inserts.
All safety-toe footwear (safety shoes) must meet the requirements and specifications of ASTM F2413-18.
Proper Fit and Selection of Foot Protection:
The most important element in a good safety boot or shoe is how well it fits the wearer. Since proper fit is so important, select safety shoes or boots at the end of the day when the feet are a bit swollen and have both feet measured. The best fit will be the length of the longer foot and the width of the wider one. If possible, before making a selection, try to walk on the type of surface on which you work.
There are no exceptions made for uncomfortable shoes or medical waivers. If an employee is required to perform tasks requiring safety shoes then the employees must wear safety shoes or other toe protection complying with this policy. If standard safety toe footwear cannot be worn, then the employee will be offered external safety toe caps that may be worn over normal footwear. If an employee cannot wear the required protective equipment to perform a task safely, then the employee cannot be allowed to perform the task. The most important factor in solving the problem of uncomfortable safety shoes is buying shoes that fit and are designed for the type of work the employee performs. To this end, supervisors should make every effort to encourage employees to buy the most comfortable safety shoes.
Hand protection is required for employees who are exposed to hazards such as those from skin absorption, severe cuts or lacerations, severe abrasions, punctures, chemical and thermal burns, and harmful temperature extremes. Proper selection must be based on an evaluation of the job to be performed, to include the hazards and operations involved, the need for dexterity, etc.
Types of protective gloves include:
Fabric: Protects against dirt, slivers, chafing and abrasions. Do not provide sufficient protection for use with rough, sharp or heavy materials.
Leather: Sturdy gloves which protect against sparks, moderate heat, blows, chips and rough objects. Often used in welding activities.
Aramid fiber gloves: synthetic material which protects against heat and cold, are cut- and abrasive-resistant and wear well.
Metal mesh: Interlocked stainless steel mesh offers superior cut and puncture protection due to its strength.
Butyl gloves: made of synthetic rubber and protect against a wide variety of chemicals, such as peroxide, rocket fuels, highly corrosive acids (nitric acid, sulfuric acid, hydrofluoric acid and red-fuming nitric acid), strong bases, alcohols, aldehydes, ketones, esters and nitro compounds. Butyl gloves also resist oxidation, ozone corrosion and abrasion, and remain flexible at low temperatures. Butyl rubber does not perform well with aliphatic and aromatic hydrocarbons and halogenated solvents.
Natural (latex) rubber gloves: comfortable to wear and a popular general-purpose glove. They feature outstanding tensile strength, elasticity and temperature resistance. In addition to resisting abrasions caused by grinding and polishing, these gloves protect workers' hands from most water solutions of acids, alkalis, salts and ketones. Latex gloves have caused allergic reactions in some individuals and may not be appropriate for all employees. Hypoallergenic gloves, glove liners and powderless gloves are possible alternatives for workers who are allergic to latex gloves.
Neoprene gloves: made of synthetic rubber and offer good pliability, finger dexterity, high density and tear resistance. They protect against hydraulic fluids, gasoline, alcohols, organic acids and alkalis. They generally have chemical and wear resistance properties superior to those made of natural rubber.
Nitrile gloves: made of a copolymer and provide protection from chlorinated solvents such as trichloroethylene and perchloroethylene. Although intended for jobs requiring dexterity and sensitivity, nitrile gloves stand up to heavy use even after prolonged exposure to substances that cause other gloves to deteriorate. They offer protection when working with oils, greases, acids, caustics and alcohols but are generally not recommended for use with strong oxidizing agents, aromatic solvents, ketones and acetates.
General Use and Care Guidelines for Hand Protection:
When selecting chemical-resistant gloves, refer to applicable Safety Data Sheets, the Ansell Chemical Resistance Guide(http://www.ansellpro.com/download/Ansell_7thEditionChemicalResistanceGuide.pdf) and/or the Chemical Resistance Selection Chart for Protective Gloves from the US Department of Energy/Occupational Safety and Health Technical Reference Manual
Remove jewelry such as rings which can damage gloves and trap chemicals against the skin.
Inspect protective gloves before each use to ensure they are not torn, punctured or otherwise ineffective. Visual inspections may help detect discoloration, stiffness, cuts and tears but a more thorough inspection by filling the gloves with water and tightly rolling the cuff towards the fingers will help reveal any pinhole leaks.
Rubber insulated gloves used for arc flash protection must be electrically tested every six months.
Discard and replace damaged gloves.
Follow the manufacturer's instructions for care, decontamination, and maintenance of gloves.
Ensure all exposed skin is covered by gloves. Gloves should be long enough so that there is no gap between the glove and sleeve.
Contaminated gloves should never come in contact with door handles, elevator buttons, telephones, lavatory faucets, vending machines, bottled-water dispensers, ice-making machines, or other surfaces outside the laboratory.
Head protection must be provided as necessary for the protection of employees' heads from impact and penetration from falling and flying objects and from limited electric shock and burns. Some operations in which head protection may be necessary include construction work, work in areas with overhead bump hazards, work areas where overhead objects may fall on employees' heads, work under scaffolds, ladders or catwalks, etc. Examples of affected employees may include those from Facilities Maintenance & Operations or Facilities Planning & Construction.
Affected University employees shall utilize Type 2 hard hats, Class G or E dependent upon level of electrical shock protection required. Class G (general) hard hats shall be utilized in situations with a potential of exposure to low-voltage electrical conductors and Class E (electrical) hard hats shall be utilized in situations with a potential of exposure to high-voltage electrical conductors.
All hard hats shall comply with ANSI Z89.1-2014, “American National Standard for Personnel Protection – Protective Headwear for Industrial Workers – Requirements.” Compliance shall be illustrated by the following markings inside each hard hat:
- The manufacturer’s name
- The legend “ANSI Z89.1 – 2014”
- The class designation (G, E or C)
- Date of manufacture
Written instructions pertaining to sizing, care and service life guidelines shall also accompany each hard hat assigned to University employees.
Hard Hat Use and Care Guidelines:
All hard hat components shall be visually inspected daily for surface condition and signs of dents, cracks, penetrations, or any other damage sustained from impact, rough treatment or wear.
Any hard hat which fails such a visual inspection shall be immediately removed from service. If a hard hat sustains a known impact, the hat shall be removed from service, even if it shows no visible traces of impact or damage. All hard hats shall be removed from service upon the end of their manufacturer’s recommended shelf life, typically 5 years, regardless of usage.
Hard hats and associated plastic suspensions shall be cleaned regularly with a simple solution of soap and water or with a damp towel.
Placement of decals/stickers shall be kept to an absolute minimum as only necessary (i.e. placement of the Catholic University logo on hard hat as an identifier is acceptable). Decals/stickers shall be placed at least ¾ of an inch away from the edge of the hard hat to prevent the possibility of the decal/sticker acting as a conductor between the outside and inside of the hat. Excessive decals/stickers may inhibit proper visual inspections of the hard hat.
Hard hats shall not be painted without written authorization from the hard hat manufacturer. Many paints and thinners may damage the shell of the hard hat and reduce effectiveness.
Hard hats shall not be worn backwards, unless documentation illustrating ANSI compliance in a backwards position is provided.
Employees shall not carry or wear any items under or within the hard hat while in use (i.e. cigarettes, ball caps, etc.) Appropriate clearance between the head and hard hat shell is critical to maintain the integrity and effectiveness of the hard hat. Items specifically designed by the hard hat manufacturer such as winter liners may be deemed acceptable by EHS on a case by case basis.
Drilling of holes in hard hats to provide ventilation is prohibited.
Hard hats shall be stored appropriately, away from temperature extremes and out of direct sunlight.
Hearing protectors and annual training shall be available to all employees exposed to an 8-hour time-weighted average of 85 decibels or greater. Employees must wear hearing protectors if they are exposed to noise over the permissible exposure limit of 90 dBA over an 8-hour time weighted average. Hearing protective devices (ear plugs, muffs, etc.) shall be utilized only when engineering or administrative controls are considered to be infeasible or cost prohibitive.
Hearing protection devices may be recommended for staff working in mechanical rooms, or those who use utilize landscaping equipment or machine tools. Such devices are required for workers performing electrical tasks with a risk of arc flash.
Noise surveys were conducted from 2006-2008 of representative mechanical spaces during chiller operations. Selected spaces surveyed included the Power Plant, Columbus Law School B116, McMahon Hall 11, Leahy Hall 2, Pryzbyla Center 102E, and Ward Hall 1A. Measured levels ranged from 81.2 to 95.7. Given the average time spent by personnel in each space, 8-hour time weighted average exposures do not exceed permissible levels detailed in the OSHA Occupational Noise Standard, 29 CFR 1910.95, Table G-16. However, insert type earplugs are available for voluntary use via wall-mounted dispensers located in the above-mentioned mechanical rooms.
Common hearing protective devices include:
Insert Type Earplugs: A device designed to provide an air-tight seal with the ear canal.
Premolded Earplugs: Premolded earplugs are pliable devices of fixed proportions. Two standard styles, single flange and triple flange, come in various sizes, and will fit most people.
Formable: Formable earplugs come in just one size. Some are made of material which, after being compressed and inserted, expands to form a seal in the ear canal. When properly inserted, they provide noise attenuation values that are similar to those from correctly fitted premolded earplugs
Earmuffs: Earmuffs are devices worn around the ear to reduce the level of noise that reaches the ear. Their effectiveness depends on an air tight seal between the cushion and the head. Ear muffs consist of sound-attenuating material and soft ear cushions that fit around the ear and hard outer cups. They are held together by a head band.
Use and care of hearing protection devices:
- Follow the manufacturer's instructions.
- Check hearing protection regularly for wear and tear.
- Replace ear cushions or plugs that are no longer pliable.
- Replace a unit when head bands are so stretched that they do not keep ear cushions snugly against the head.
- Disassemble ear muffs to clean.
- Wash ear muffs with a mild liquid detergent in warm water, and then rinse in clear warm water. Ensure that sound-attenuating material inside the ear cushions does not get wet.
- Use a soft brush to remove skin oil and dirt that can harden ear cushions.
- Squeeze excess moisture from the plugs or cushions and then place them on a clean surface to air dry. (Check the manufacturer's recommendations first to find out if the ear plugs are washable.)
Employees who face possible bodily injury of any kind that cannot be eliminated through engineering, work practice or administrative controls must wear appropriate body protection while performing their jobs. In addition to cuts and radiation, other examples of workplace hazards that can cause bodily injury include:
- Temperature extremes;
- Hot splashes from molten metals or other hot liquids;
- Potential impacts from tools, machinery and materials;
- Electrical shock, burns, arc flash;
- Hazardous chemicals.
University departments which may require the use of body protection include, but are not limited to, laboratory personnel in Chemistry, Biology, Nursing, Engineering or Physics, staff in machine shops or the Art department who may perform welding or other cutting activities, or staff employed with Facilities Maintenance & Operations and conduct spill cleanup, pesticide applications, electrical tasks,etc.
Examples of body protection devices include laboratory coats, coveralls, vests, aprons, surgical gowns and full body suits. Protective clothing comes in a variety of materials, each effective against particular hazards. Always check with clothing manufacturers to ensure that the material selected will provide protection against the specific hazard.
Paper-like fiber: used for disposable suits/coveralls which protects against dust and splashes.
Treated wool and cotton: adapts well to changing temperatures, is comfortable, fire-resistant, protects against dust, abrasions, and rough and irritating surfaces.
Duck: closely woven cotton fabric that protects against cuts and bruises when handling heavy, sharp, or rough materials.
Leather: protects against dry heat and flames.
Rubber, rubberized fabrics, neoprene, and plastics: protect against certain chemicals and physical hazards.
Employees working around hazard materials or machinery shall not wear loose clothing (e.g. saris, dangling neckties, necklaces) or unrestrained long hair. Loose clothing, jewelry, and unrestrained long hair can become ensnared in moving parts of machinery or contact chemicals.
Clothing utilized for arc flash protection must be appropriately arc-rated.
Guidelines for use of lab coats, aprons or gowns for laboratory personnel:
Required use of lab coats in all laboratories shall be at the discretion of the lab manager. Lab coats, aprons or gowns shall be strongly considered to minimize clothing contamination and skin exposure to hazardous chemicals. They may also provide some temporary protection against fire. Although, most lab coats are not designed to be impermeable to hazardous substances or flameproof, they provide additional safety because they can be quickly removed to isolate harmful exposures or flames. To minimize body exposures in the lab and provide some temporary protection against fire, adhere to the following:
- Beware of limitation of each type of the lab coat;
- Make sure that additional protective measures are selected and in use based on the hazard assessments;
- Wash/maintain lab coats as recommended by vendors;
- Appropriate lab coats should be fully buttoned with sleeves rolled down;
- Don't wear lab coats in public places, such as offices, lunchrooms, or lounge areas, as they can transfer hazardous materials and contaminate these areas.
OSHA 29 CFR 1910 – General Industry Standard, Subpart I, Personal Protective Equipment
.132 – General Requirements
.133 – Eye and Face Protection
.134 – Respiratory Protection
.135 – Head Protection
.136 – Foot Protection
.137 – Electrical Protection
.138 – Hand Protection
OSHA 29 CFR 1926 – Construction Standard, Subpart E, Personal Protective and Lifesaving Equipment
.100 – Head Protection
.101 – Hearing Protection
.102 – Eye and Face Protection
.103 – Respiratory Protection
.104 – Safety Belts, Lifelines and Hazards
.105 – Safety Nets
.106 – Working Over or Near Water
American National Standards Institute (ANSI)
Z87.1 – 2010 - American National Standard for Occupational and Educational Personal Face and Eye Protection
Z88.2 - American National Standard Practices for Respiratory Protection
Z89.1 – 2014 – American National Standard for Industrial Head Protection
American Society of Testing Material (ASTM)
F2413-11 Standard Specification for Performance Requirements for Protective (Safety) Toe Cap Footwear
National Fire Protection Association (NFPA)
70E - Standard for Electrical Safety in the Workplace