Part III: A Model Personal Protective Equipment Program

BY FRANK GREER, COMPANY SAFETY OFFICER

Editor's Note: This article concludes the three-part safety series on personal protective equipment (PPE). The purpose of Part III is to establish useful guidelines which will help the painting contractor implement and maintain a written policy for PPE as part of an effective, ongoing company safety program. This model program is a good start toward that end. However, this model is not all-inclusive, and the painting contractor should assess the particular and specific hazards of his company's workplace and modify this program according to those needs.

Additionally, the painting contractor should develop a written hazard assessment of the company workplace. A written respiratory protective program is also required by OSHA Construction Standard 29 CFR 1926.103 (e).

Written Personal Protective Equipment Program

(Company Name)

Purpose: The purpose of this written personal protective equipment (PPE) program is to set forth uniform policies and procedures concerning the use of PPE by this company and its employees. Strict conformance with this company policy is required.

Proper selection and use of PPE provides effective means to prevent or reduce bodily injury to employees. This company will reduce possible exposure to employees' health risks and bodily injury by maintaining an effective PPE program.

Employees should realize that PPE cannot provide protection against all hazards. Therefore, PPE should be used in conjunction with administrative and engineering controls that provide the safest workplace possible. In the painting trade, these controls include ventilation and proper coordination of painting work when other trades are present. Substitution of safe painting materials, or changing traditional painting practices, may also help eliminate or reduce employee exposure to health risks or bodily injury.

Assessment: This company will assess the specific hazards of the painting trade and determine what hazards are present, or likely to be present, which necessitate the use of PPE in field operations. This workplace assessment will identify sources of particular hazards to painters, including typical exposures created by other construction trades. This survey will evaluate hazards in the following basic categories: impact, penetration, compression (rollover), chemical, heat, harmful dust, and light radiation.

Program administration and surveillance: When hazards are present, or likely to be present, the company will select and require the use of PPE that will help protect against the identified hazards. The company has developed written detailed instructions covering each of the basic elements of this program. The company will amend this company PPE program whenever necessary. Periodic evaluations will include a survey of employee suggestions and complaints. In addition, workers' compensation and/or OSHA consultation may be used to assist with this evaluation if necessary.

Any job or field supervisor will halt any operation of this company when an unsafe job condition exists. Work will not resume until the unsafe condition is remedied. Company management will support this policy of shutting down unsafe field operations.

Employees who report to work without assigned PPE, or who refuse to wear PPE, will be subject to reasonable and appropriate disciplinary action. Likewise, if assigned PPE cannot protect the employee against a specific hazard of a task, the employee may refuse to perform that task until proper PPE is provided. This refusal is an employee right and such refusal will not result in any reprimand or discipline.

PPE selection: PPE is specifically designed and tested to protect the employee against specific bodily injuries. All PPE has limitations and does not provide unlimited protection. Different types of PPE protect against different exposures to bodily injury. Use of improper or damaged PPE may reduce or eliminate the intended protection. Injury or illness may result from the use of improper PPE.

This company has selected PPE which is comfortable, yet provides adequate protection based upon intended use. Only PPE conforming to recognized standards (ANSI, MSHA, NIOSH) will be selected and used by this company. Employees may not substitute other PPE, or supply their own PPE, without written authorization. Field supervisors may purchase special PPE for a particular hazard at their own discretion or at the request of any employee. When working out of town, supervisors may purchase basic PPE as long as it meets applicable standards. The company safety officer will oversee PPE selection.

Fitting: Poor-fitting PPE will not provide the necessary protection. Careful consideration must be given to comfort and fit. Therefore, various sizes of PPE will be provided so that selected PPE will properly fit each employee. Wearing PPE is also more likely if the device fits comfortably. Therefore, PPE will be provided in a variety of sizes, or have adjustments for proper fitting. Care will be taken to ensure that each employee has the right size of PPE provided for use.

All employees shall be required to demonstrate donning and removal of PPE.

Training: General: Employees will be effectively trained to know 1) when PPE is necessary; 2) what PPE is necessary; 3) how to properly don, duff, adjust, and wear PPE; 4) the limitations of PPE; 5) the proper care, maintenance, useful life, and disposal of PPE.

Initial Training: All employees will be given basic PPE that includes manufacturers' instructions for use. In addition, employees will be given copies of this company's PPE policy, the PDCA Employee Safety Handbook, and the PDCA Hazardous Communications Handbook. All employees will be required to watch the PDCA Safety Orientation Video and the PDCA Hazardous Communications Video. These resources identify hazards particular to painting and provide instructions for PPE use in the painting trade.

Ongoing Training: All company employees will be provided effective, ongoing training by using PDCA Toolbox Topics as well as other toolbox talks and handouts.

Supervisory Training: As a condition of advancement, a 10-Hour OSHA Training Course in Construction Safety and Health will be required to become a job or field supervisor for this company.

Retraining: The company will require retraining of employees when any affected employee does not demonstrate understanding and skill required for effective use of PPE when 1) changes in the workplace render previous training obsolete; 2) the type of PPE is changed; 3) inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

Certification: The company shall verify that each affected employee has received and understood the required training through a written certification that contains the name of each employee trained, the date of training, and the subject of the certification.

Reassessment: The company will reassess workplace hazards as necessary by reviewing accident records, by reviewing protection information of material safety data sheets, and evaluating new equipment and processes.

PPE assignment: New and current employees will be assigned PPE for their own use. Employees not wearing PPE required for a task, for whatever reason, are strictly prohibited from entering any work area where PPE is required for adequate protection from bodily injury.

Cleaning and storage: For reasons of both personal responsibility and sanitation, employees may not borrow PPE assigned to another employee or lend their PPE to another employee.

Employees shall care for personal PPE. Each employee is responsible for marking all personal PPE issued. All PPE must be kept clean. All employees have standing permission to leave the work area to clean their PPE when necessary.

When not in use, PPE should be kept in a convenient, clean, and sanitary location and protected from physical damage, sunlight, extreme cold, heat, and chemical conditions.

Damaged or defective PPE: Damaged or defective PPE shall not be used. Employees must immediately notify the office of any damaged or defective PPE. Replacement PPE will be issued.

Inspection and maintenance: Inspection of assigned PPE is the responsibility of the employee. All defects need to be reported to the office for repair. PPE in need of repair will not be used until that repair is completed. (Company name) will be responsible for all normal repairs. Repairs due to improper use, storage, or neglect will be the responsibility of the employee. Only parts of the original manufacturer will be used in the repair and maintenance of PPE. A supply of replacement parts is kept at the office.

Reporting to work: All employees reporting to work must have all their assigned PPE. No exceptions.

Replacement costs: The company will replace PPE free of charge that is no longer usable due to normal wear and tear. As long as an employee turns in PPE no longer usable due to normal wear and tear, there will be no charge for obtaining new PPE. Failure to surrender worn PPE will result in the employee assuming the cost of replacement.

In any circumstance, if an employee forgets, loses, or neglects his assigned PPE, the costs of replacing the PPE will be the responsibility of the employee.

Company employee PPE kit: The following items compose the company's PPE kit for all employees:

Hardhats, ratchet style

Protective eyeglasses, clear

Protective eyeglasses, tinted

Chemical splash goggles

Chemical gloves

Disposable earplugs

PDCA Employee Safety Handbook

Wallet card (spray injection injury)

Spray safety booklet

Other PPE: The company provides each employee with a dual-cartridge half-mask respirator as defined under the company written respiratory policy. Self-contained breathing apparatus (SCBA) is available for specific respiratory hazards.

Specialized PPE, such as safety vests, face shields, wet suits, etc. for specific hazards are available for checkout from the office.

Acknowledgement: This verifies that the company has furnished me with the personal protective equipment as noted above under Company Employee PPE Kit. I will read the employee safety handbook provided, and the company instructions for use of PPE. I understand that I must bring this PPE to work each day and wear it when needed. I agree that if I fail to do so, that I cannot work without the necessary PPE. If I take care of my PPE, and turn in used PPE, the company will replace such equipment that has normal wear and tear free of charge. If I forget, lose, or neglect my PPE, I agree to replace it at my own expense. I understand that certain job tasks may require additional specific PPE that the company will provide on an as-needed basis.

____ I wear eyeglasses and have been given safety glasses and goggles for eyeglass wearers.

Signature/date

Issued by _____________

Notes

Frank Greer is the company safety officer for Nelson J. Greer Painting Contractors of Tucson, AZ, whose company safety program was recently recognized by the Tucson Chapter of the American Subcontractors Association and national PDCA. Greer has completed the 40-hour basic instructor course in Occupational Safety and Health Standards for the Construction Industry, and has conducted 10-hour construction safety training courses for company personnel and for Southern Arizona PDCA Chapter painting contractors and their employees. He is also, of course, the author of the regular PWC estimating column.