Part II: An action plan for implementing a personal protective equipment program
BY FRANK GREER, COMPANY SAFETY OFFICER
Editor's Note: This article is the second in a three-part series on personal protective equipment (PPE). This article outlines the steps necessary for a painting contractor to implement and maintain a personal protective equipment program as part of an effective, ongoing company safety program. Part III of this series (May/June) will be a sample written PPE program that can be used by most painting contractors with little modification.
The acronym "PPE" is commonly used by safety professionals to mean personal protective equipment. PPE includes all clothing, equipment, and work accessories designed to create a barrier against workplace hazards. As of Jan. 5, 1995, new PPE standards went into effect for all federal and state OSHA plans. The Final Rule on Protective Equipment requires written assessment of workplace hazards and written certification of worker training in PPE. Additionally, a new section on hand protection is incorporated into the updated PPE standards.
Survey: Conducting a thorough survey of workplace hazards is the first step in establishing an effective PPE program. Hazard surveys should be conducted by a competent person. To OSHA, a competent person is one who is capable of identifying existing or predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
Workplace hazards can be surveyed by a variety of methods. These methods include a general survey of typical hazards found in your workplace at large, which should then be supplemented by specific hazard assessment surveys on a job-to-job basis. Here are some areas to consider:
Past injuries: A review of past injuries of company employees is a good place to start with any workplace hazard survey. Obviously, if certain injuries have occurred, then at least some of those injuries have a strong likelihood of recurring unless corrective measures are taken. More often than not, a review of past injuries will enable you to see that PPE is essential in preventing workplace injuries. Such an observation should provide another incentive - in addition to OSHA compliance - to implementing an effective PPE program.
Review your worker compensation case history. If you employ 11 or more people, also review your OSHA 200 Injury Log. Draw a stick person and tally past injuries by bodily location. Also, tally injuries by type: cuts, skin irritation, sprains and strains, etc. Your records may show recurring back injuries, eye injuries due to lack of PPE, or recurring cuts to the hand. You may also want to tally injuries by person or by month, to see if you employ any accident-prone people or have accident-prone months.
MSDS: The chemical nature of coatings and related surface preparation materials requires the use of certain PPE. Therefore, when conducting a hazard survey, thoroughly review material safety data sheets for those materials commonly used by your company. In particular, don't forget to review MSDS for solvents, wood bleaches, or materials used to etch concrete and galvanized metals.
Procedures: Every painting company has certain procedures that require PPE use: sanding, scraping, spraying, waterblasting, etc. Consider all the tools and equipment used by your company. Mentally survey painting procedures associated with painting tools and equipment. Supplement this mental survey with specific jobsite inspections.
Specific jobsite exposures: Look at your company procedures with an eye toward safety. Additionally, look to see if your painters are exposed to hazards created by other workers, or by specific jobsite conditions. Observe the workplace layout, sources of motion, the location of other workers. Look for electrical hazards. Consider if any of the basic hazards present a threat to your employees' safety: impact, penetration, compression, chemicals, heat, harmful dust, or light radiation. For instance, it is not unusual for painters to work while other crafts, such as roofers or pipefitters, work directly overhead. Also, it is not uncommon for painters to walk under scaffolds erected by plasterers or masons. These exposures present the potential of serious head injury by impact, and are predictable.
Assessment: Assessment is the next step in establishing a PPE safety program. Assessment must be conducted by a qualified person. OSHA defines a qualified person as one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.
Under the new PPE standard, employers are required by OSHA to certify in writing that a workplace hazard survey has been performed. This certification must identify the workplace evaluated, who performed the certification, and the date. Also, this document must be identified as a certification of hazard assessment.
Organize the data and information gathered and determine if hazards can be controlled by any of the following administrative measures:
Elimination, reduction, and control: The first question that should be asked when evaluating workplace hazards is "Can the hazard be eliminated, reduced, or controlled?" Some of the best methods of hazard elimination, reduction, and control in painting include 1) substituting a safer material for a hazardous one; 2) using a safer process; 3) controlling the environment by ventilation; and 4) scheduling work at the safest possible time.
Stand down: There will be occasions when your employees do not have the proper PPE to perform an operation safely, or when they are exposed to unnecessary hazards. Your company safety policy should specifically state that employees may refuse to perform that work, and perform other work, until such time that the necessary PPE is provided. The policy should state that standing down is an employee right and will not result in any reprimand or discipline.
Shutdown: Company policy should also allow employees to delay work if hazardous conditions are present. For example, your crew shows up to paint the exterior of a new house and there is a open trench running along the back wall, or a crew of roofers is laying concrete tile on a sloped roof above where your painters need to work. In either instance, the hazard can be remedied by rescheduling the exterior painting of the house.
Back your crews when a job is shut down for safety. Explain to the job superintendent that you will not needlessly expose your painters to harm. A good job superintendent will understand this and respect you. A bad one needs to learn to coordinate trades better and call for an OSHA consultation about his obligations regarding jobsite safety.
Other administrative controls: Your company should consider how certain strong solvents, acids, and other painting materials are purchased. For example, our company policy requires that all solvents be purchased through one supplier, and that certain materials, such as MEK, xylene, or acids, be purchased only with express permission and approval. This reduces solvent use, and also ensures that proper worker and environmental safeguards are implemented.
If hazards cannot be eliminated, reduced, or controlled, then it is necessary to further evaluate the information obtained by your survey and to select the appropriate PPE to perform the work safely. List what hazards exist, the level of risk, and the seriousness of potential injury from the hazards found.
Selection: To be able to select the appropriate PPE, you must familiarize yourself with the updated OSHA PPE standards. Review the types of PPE available and determine the specific protection each type of PPE can afford and its limitations. It is helpful to obtain several safety equipment catalogs and to compare the particular features of each type of PPE. If possible, enlist the help of a safety equipment professional to advise you in the selection of appropriate PPE.
In each instance, ensure that the selected equipment provides a level of protection greater than the minimum required to protect employees from hazards. PPE should be adjustable, or provided in different sizes when required. Carefully consider fit and comfort. Poor-fitting PPE may not provide the necessary protection, while employees will be reluctant to wear uncomfortable PPE. Particular purchases for specific needs should also be addressed. For example, corrective eyeglass wearers need specific safety glasses that fit over their regular eyewear.
Prior to purchasing any PPE in quantity, purchase a single unit and give it to an employee to field test. For example, purchase one respirator, let an employee wear it, and ask for an honest evaluation. Another good method of testing PPE is to purchase several of a particular type. For example, buy several pairs of safety glasses, pass them around to a crew, and see if one pair fits better than another, or if one style is preferred over another. Your employees will appreciate that you value their advice, and this lets them "buy into safety."
PPE training requirements: The purpose of safety training is to effectively eliminate unsafe employee work practices by instruction, discipline, and repeated practice. Under the new OSHA guidelines, the contractor is required to train employees in the use of PPE, and employees are required to demonstrate an understanding of the training received and the ability to use PPE properly, before they can work in any situation requiring its use. The employee must be trained by the employer to know 1) when PPE is necessary; 2) which PPE to use; 3) how to don, remove, adjust, and wear PPE; 4) the limitations of PPE; and 5) proper care, maintenance, useful life, and disposal of PPE.
Retraining: If the contractor has any reason to believe that an employee does not have the understanding and skill to properly use PPE, it is the contractor's responsibility to retrain the employee. OSHA guidelines require retraining when previous training is rendered obsolete by workplace changes, the type of PPE is changed, or when the employee's knowledge or use of PPE appears inadequate.
Certification: The painting contractor must verify in writing that each employee has received and understood the required training. This written certification must contain the name of each employee trained, the date(s) of training, and the subject matter of the certification.