This material is for training purposes only. Its purpose is to inform Oregon employers of best practices in occupational safety and health and general Oregon OSHA compliance requirements. This material is not a substitute for any provision of the Oregon Safety Employment Act or any standards issued by Oregon OSHA. For more information on this online course and other OR-OSHA online training, visit the Online Course Catalog.

MODULE ONE: 1910.132 GENERAL REQUIREMENTS

What is required?

An employer has an obligation to provide protective equipment PPE, including personal protective equipment for eyes, face, head, and extremities, and protective clothing and barriers. The employer must also make sure employees use and maintain PPE in a sanitary and reliable condition.

What is proper use?

Personal Protective Equipment must be worn and used in a manner which will make full use of its protective qualities.

Take a look at the photo to the left. If you came upon an employee using PPE improperly in your workplace, what would you recommend? What recommendation would you make to this employee?

Low rates of compliance in wearing PPE usually indicate the safety management system is failing in some way. Any one of the following root causes may result in general non-compliance:

the employer does not provide quality PPE
the employer does not properly supervise the use of PPE
the employer fails to enforce the use of PPE, or
the employer does not properly train employees on the use of PPE

Paying for PPE

The employer is obligated to provide and to pay for personal protective equipment required by the company for the worker to do his or her job safely and in compliance with OR-OSHA standards. Where equipment is very personal in nature, such as safety shoes, and is usable by workers off the job, the matter of payment may be left to labor-management negotiations. However, items such as safety shoes which are subject to contamination by carcinogens or other toxic or hazardous substances, and which cannot be safely worn off-site, must be paid for by the employer.

What are the different categories of PPE?

PPE includes:

Face and eye protection
Head protection
Foot protection
Hand protection
Protective clothing
Protective ointments
Shields
Barriers
Restraints

Where and when is it required?

PPE is required wherever the following conditions are encountered that are capable of causing injury or impairment by being absorbed, inhaled, or physically contacted:

hazards of processes
environment hazards,
chemical hazards,
radiological hazards, or
mechanical irritants

Employee-owned equipment

The intent of the PPE standard assigns responsibility to the employer to pay for and provide PPE to the employee when it's required by the employer. Although employers may arrange for employees to provide their own protective equipment, it's important to understand that in such circumstances the employer remains responsible and accountable to assure its adequacy, including proper maintenance, and sanitation of such equipment.

Design

All personal protective equipment must be of safe design and construction for the work to be performed.

What should not be worn?

The PPE rules require that rings, wristwatches, earrings, bracelets, and other jewelry must not be worn if it's possible for it to come into contact with power driven machinery or electric circuitry.

Why this rule? Read how this rule might have prevented some serious injuries.

De-gloving of a finger caused by a ring. From Bob F.
The accident occurred when the individual was jumping off the side of an Army tow truck. He placed his hand on the railing of the bed and jumped off. The ring caught on the side of truck bed. Upon reaching the ground, the ring had removed all the skin from the finger, leaving the muscles, bone and fingernail exposed.
The individual was rushed to an emergency room where the finger was inserted into the wall of the stomach area. A pedicle graft was preformed using the skin from the stomach area. After more than eight operations and over a 100 plus days in the hospital the finger is semi useable. The stomach skin on the ring finger is more sensitive than the other finger's skin.
Nothing but air? NOT! From Joan R.
I took care of a man who got his ring caught on a basketball hoop as he made a dunk and pulled his whole finger off---skin, bone, and all at the knuckle. Not a pretty site.

What about backbelts?

It's important that you understand that back belts should not be considered personal protective equipment in that they physically "protect" you from back injuries.

Devices such as back belts are not recognized by OR-OSHA as control measures to prevent back injury. While they may be accepted by individual workers because they feel as if they provide additional support, if used improperly, they may restrict the body's range of motion and possibly aggravate other ergonomic stressors in the job. Research indicates that the primary value in back belts, when used properly, is that they "remind" the employee to use proper lifting techniques. As a result, fewer back injuries occur. Thus, OROSHA does not forbid the use of back belts and similar devices, nor does it endorse their use.

Work Clothing

Clothing must be worn which is appropriate to the work performed and conditions encountered.

Loose sleeves, ties, lapels, cuffs, or other loose clothing must not be worn near moving machinery.

Make sure that you immediately remove clothing that becomes saturated or impregnated with flammable liquids, corrosive or toxic substances, irritants, or oxidizing agents. Don't wear it again until it's properly cleaned.

Defective and damaged equipment

Of course, defective or damaged personal protective equipment must not be used. It's important to inspect PPE regularly, and before each use to make sure it's capable of adequately protecting an employee from exposure to hazards. Remember, PPE that is defective...is not PPE.

Hazard assessment and equipment selection

A hazard assessment is an important element of a PPE program because it produces the information needed to select the appropriate PPE for any hazards present or likely to be present at particular workplaces. Your employer is then capable of determining and evaluating the hazards of a particular workplace. Paragraph d. (see below) of the PPE standard details hazard assessment requirements. It is a performance-oriented provision that simply requires management to use their awareness of workplace hazards to enable them to select the appropriate PPE for the work being performed. Paragraph (d) clearly indicates that management is accountable both for the quality of the hazard assessment and for the adequacy for the PPE selected.

1910.132 General Requirements
(d) Hazard assessment and equipment selection

(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
(ii) Communicate selection decision to each affected employee; and,
(iii) Select PPE that properly fits each affected employe.

Note: Non-mandatory Appendix B contains an example of procedures that would comply with the requirement for a hazard assessment.
(2) The employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

Your employer must verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.

Take a look at a sample hazard assessment form that would comply with the PPE standard...and more.

Controlling hazards

PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with engineering controls and other management controls.

Engineering Controls

Workplace hazards may be corrected using engineering controls which may be thought of as replacing or redesigning machinery, equipment, and tools, and/or substituting materials. Engineering controls are the "first line of defense" against injury/illness, because they have the potential to completely eliminate a hazard, and do not rely on human behavior to be effective. For instance, rather than require employees to wear respiratory protection which must be monitored, inspected, trained, managed, it's much more effective to install a ventilation system that does not require any of those management activities.

Management Controls

Management controls can be accomplished with the stroke of the pen. It involves changing or redesigning work procedures, rescheduling breaks, changing the number of workers doing a job, and using personal protective equipment to reduce the frequency and duration exposure to the hazards of tasks. Using management controls alone is not as effective as engineering controls because, in most cases, they only reduce exposure - they don't eliminate the hazard. And even more importantly, management controls do rely on human behavior (which introduces many variables in the long run) which must be managed.

If the person conducting the hazard assessment discovers that hazards requiring PPE are present, or likely to be present, then management must:

Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazard identified in the hazard assessment;
Communicate selection decisions to each affected employee; and,
Select PPE that properly fits each affected employee.

The Six-Step Assessment Process

It is important to consider certain general guidelines to assess foot, head, eye and face, and hand hazard situations that exist in a operation or process, and to match the protective devices to the particular hazard.

Step One: Conduct a survey

The most effective strategy for surveying the work area is to use a team of individuals conduct the assessment. The area supervisor, safety officer and/or experienced employee should conduct a walk-through survey of the areas in question. The purpose of the survey is to identify sources of hazards to workers and co-workers. Consideration should be given to the basic hazard categories:

Impact
Penetration
Compression (roll-over)
Chemical
Temperature extremes
Hazardous atmospheres
Radiation - ionizing and non-ionizing
Noise

Step Two: Determine sources of hazards

During the walk-through survey the assessment team should determine if any of the following hazard sources exist:

Sources of motion; i.e., machinery or processes where any movement of tools, machine elements or particles could exist, or movement of personnel that could result in collision with stationary objects;
Sources of high temperatures that could result in burns, eye injury or ignition of protective equipment, etc.;
Chemicals that could contact skin and eyes;
Sources of hazardous atmospheres;
Sources of light radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.;
Sources of falling objects or potential for dropping objects;
Sources of sharp objects which might pierce the feet or cut the hands;
Sources of rolling or pinching objects which could crush the feet;
Layout of workplace and location of co-workers; and
Electrical hazards.

Step Three: Organize the data

Following the walk-through survey, it is necessary to organize the data and information for use in the assessment of hazards. The objective is to prepare for an analysis of the hazards in the environment to enable proper selection of protective equipment. In addition, injury/accident data should be reviewed to help identify problem areas.

Step Four: Analyze the data

Having gathered and organized data on a workplace, an estimate of the potential for injuries should be made. Each of the basic hazards categories should be reviewed to determine the:

Nature of the hazard,
Degree of risk.
Seriousness or severity of potential injury
Possibility of exposure to several hazards simultaneously

What about "Risk"?

Risk may be thought of in terms of probability and severity. The higher the probability and/or severity of an injury, the greater the risk. According to the American Society of Safety Engineers Dictionary of Terms Used in the Safety Profession, Risk is defined as:

A measure of both the probability and the consequence of all hazards of an activity or condition. A subjective evaluation of relative failure potential.

Risk assessment is defined as:

The amount or degree of potential danger perceived by a given individual when determining of action to accomplish a given task.

The probability, or likelihood that an accident will occur is determined by Oregon OSHA by analyzing a set of conditions or factors associated with a hazard. They are:

The number of employees exposed;
The frequency of exposure;
The duration of exposure;
The proximity of employees to the point of danger;
The adequacy of training;
The adequacy of supervision;
The adequacy of workstation design; and
Other factors which may have significantly affect

Severity is actually a measure of the impact on, or consequence of the injury to the employee. If the injury does not prevent the employee from continuing to work in the same job at the same level of performance, it may be thought to be a minor, or other than serious injury. If, on the other hand, the injury prevents, for whatever reason, the employee from continuing work in the same job, it should be considered a major, or serious injury. The most extreme consequence of an injury is, of course, a fatality.

Step Five: Select the Personal Protective Equipment

After completing the hazard assessment it's time to select the right PPE for the job: To do this most effectively, it's important to:

Become familiar with the potential hazards and the type of protective equipment that is available, and what it can do, i.e., splash protection, impact protection, etc.;
Compare the hazards associated with the environment; i.e., impact velocities, masses, projectile shape, radiation intensities, with the capabilities of the available protective equipment;
Involve employees in the selection process;
Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards; and
Fit the user with the protective device and give instructions on care and use of the PPE. It is very important that end users be made aware of all warning labels for and limitations of their PPE.

Fitting the device

As you probably know, PPE that fits poorly will not properly protect employees. And, if the PPE is not comfortable, the employee is not likely to wear it long. Protective devices are generally available in a variety of styles and sizes, and care should be taken to make sure that the employee gets the right size for him or her.

Devices with adjustable features

It's important to realize that when it comes to PPE, "one does NOT fit all!" Adjustments should be made on an individual basis for a comfortable fit that will keep the protective device in the proper position. Where manufacturer's instructions are available, they should be followed carefully.

Step Six: Reassess for Hazards

It is the responsibility of management to reassess the workplace hazard situation as necessary, by identifying and evaluating new equipment and processes, reviewing accident records, and reevaluating the suitability of previously selected PPE.

Last Words

There it is! Module one is history...well, except for the module quiz below. Remember, if you are unsure about an answer, just scroll back up the page and review the subject area. Good luck!

MODULE Quiz

1. All of the following are considered personal protective equipment except:

a. Steel toed boots
b. Backbelts
c. Ear muffs
d. Hard hats
e. Face shields

2. All of the following are examples of hazardous conditions possibly requiring PPE except:

a. Environmental hazards
b. Chemical hazards
c. Psychological hazards
d. Mechanical irritants
e. Process hazards

3. Why might employees sometimes stop using PPE?

4. Employers are always responsible and accountable to make sure PPE used by their employees are used and maintained properly.

a. True
b. False

5. You're wearing a ring on your hand. The ring contacts electrical current. What other danger to you, in addition to electrical shock, exists in this example?

6. Personal protective equipment is most often used ______________ engineering and management controls. (Fill in the blank)

a. as a replacement for
b. in conjunction with
c. prior to the use of
d. to reduce the need for

7. If the person conducting the hazard assessment discovers that hazards requiring PPE are present, or likely to be present, management must do which of the following?

a. Select PPE for the affected employee from the specific hazard
b. Communicate selection decisions to each affected employee
c. Select PPE that properly fits each affected employee
d. All of the above
e. None of the above

8. It's important to realize that when it comes to PPE, "One does NOT fit all!"

a. True
b. False

9. The most effective strategy for surveying the work area is to use one individual to conduct the assessment.

a. True
b. False

10. _________ and __________ are analyzed to determine risk.

a. Probability
b. Severity
c. Cost
d. a and b above
e. b and c above

Congratulations on completing the first module! I'm sure you'll agree an effective ppe program is critical to the success of a safety management system. Continue on to the next module to learn more about ppe training requirements. If you have any questions or comments, just drop me an email at email.

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