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PPE Requirements: What You Absolutely Must Do

Original article from http://safetydailyadvisor.blr.com

By Chris Kilbourne

PPE is an employee’s personal barrier against many workplace hazards. That’s why OSHA makes a point of strictly enforcing PPE rules. And so should you.

OSHA requires you to provide personal protective equipment (PPE) and training to employees who are or may be exposed to physical or health hazards in the workplace when engineering and administrative controls cannot feasibly or effectively reduce exposures to safe levels.

PPE is designed to protect your workers from serious workplace injuries or illnesses resulting from contact with specific hazards. For example:

  • Chemical
  • Radiological
  • Physical
  • Electrical
  • Mechanical

Hazard Assessment

To determine if any of these hazards that require the use of PPE are present or are likely to be present in your workplace, OSHA says that you have to assess your workplace and the jobs employees perform. This is not a recommendation. It is a mandate.

If hazards are present, or likely to be present, you must:

  • Select, and make sure each affected employee uses, the types of PPE that will protect the employee from the hazards identified in the hazard assessment
  • Communicate selection decisions to each affected employee
  • Select PPE that properly fits each affected employee

The two basic objectives of any PPE program are to:

  • Protect wearers from workplace hazards
  • Prevent wearers from being injured if there is a malfunction of PPE or they use the equipment incorrectly

Regulations

OSHA has numerous regulations concerning PPE. For general industry, the most commonly applicable are found in Subpart I, Personal Protective Equipment (29 CFR 1910.132-136 and 29 CFR 1910.138. Hearing protection is required in 29 CFR 1910.95, and PPE for emergency hazardous waste operations are specified in the HAZWOPER standard (29 CFR 1910.120).

Remember, too, that failing a specific regulation, OSHA may also apply its General Duty Clause to PPE-related situations. The General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act (OSH Act), requires an employer to furnish to its employees “employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees ….”

Cost of PPE

You must pay for most types of PPE when used by employees exclusively in the workplace (i.e., not for personal use at home or other nonworkplace activities).

  • PPE replacement. You must pay to replace worn or damaged PPE as part of the your obligation to ensure that the PPE is in good condition. You are not, however, required to pay for replacement when the employee has lost or intentionally damaged the PPE.
  • Employee-owned PPE. When an employee voluntarily purchases and wears his or her own PPE and is allowed to use it at the workplace, you are not required to reimburse the employee for that equipment. If employees are allowed to use their own PPE, however, you are responsible for its adequacy, maintenance, and sanitation.

If an employee has provided his or her own PPE but the your hazard assessment determines that an upgrade to or replacement of PPE is required, then you must pay for the upgrade or replacement regardless of who paid for the original PPE.