Originally posted by Chris Kilbourne on http://safetydailyadvisor.blr.com
In the health and safety professional’s “hierarchy of controls,” PPE falls in last place—behind engineering controls and work practice or administrative controls. The reasoning is that engineering controls address the hazard directly, and have the fewest potential failure points, so they are most protective.
Work practice or administrative controls are generally the next choice, but they do not control the hazard at its source, the way engineering controls do. Rather, they rely on the worker to interact safely with the hazard, adding a potential failure point if the worker does not comply with the work practices.
And PPE, last in the hierarchy:
- Does not address the hazard directly;
- Won’t protect a worker who doesn’t use it; and
- Can also fail to protect if there is a problem with the equipment itself.
Because it addresses the hazard only indirectly and has the most potential failure points, PPE has historically been considered the least desirable option for employee protection.
One of the potential failure points for PPE occurs at the point of interaction between the worker and the equipment, when employees can make critical mistakes in the care, use, and replacement of PPE. Some typical mistakes are illustrated below.
- Mistake No. 1: Workers take their foam earplugs out to consult with each other about a problem, then roll the foam earplugs again with dirty hands and reinsert them in their ears. At the end of the day, they leave the earplugs inside their hard hats and reuse the same plugs the next workday.
These workers have failed to care for their PPE appropriately. Most PPE requires some care to function properly. At the very least, employees should inspect PPE before and after use for signs of weakness, damage, or wear that would indicate a reduced level of effectiveness.
PPE that is not appropriately cared for may also:
- Become a hazard in itself. For example, workers who reinsert dirty earplugs are at risk of irritation and infection. Dirty earplugs should be cleaned or replaced.
- Lose effectiveness. Workers who are not careful to clean their safety equipment after use may not realize that workplace chemicals and oils from their skin can begin to degrade the equipment prematurely.
Whatever PPE your workers use, make sure they know how to care for it and keep it in good working condition.
Mistake No. 2: A worker wearing a fall protection harness leaves the harness loose but pulls the lanyard tight. Another worker who uses a respirator at work decides to grow a beard.
These workers have failed to use PPE correctly. Sometimes it’s just not clear from looking at the equipment how a piece of PPE should be properly used. Workers need to practice, under the eye of someone with experience, putting on and taking off their protective equipment.
They also need to understand the theory behind their equipment and how it works. PPE that is not used correctly won’t protect workers.
- Mistake Number 3: A brick falls on a worker’s head, but his hard hat takes the impact. The worker declares the hat his “lucky hat” and continues to wear it every day. A supervisor whose workers are supposed to use a new pair of chemical protective gloves each day decides he will save his department money by telling workers to use each pair of gloves for a week before replacing it. After all, the gloves still look fine after a week’s use.
These workers have failed to replace PPE as needed. Workers can’t be safe if they don’t use or care for their PPE properly—but they also can’t be safe if they don’t know when to replace old equipment. Employees need to replace their equipment:
- Each shift, if it is disposable—earplugs, gloves, protective clothing, respirators, and face protection all come in disposable varieties. These are not designed to be cleaned or reused, and may lose effectiveness if they are. Make sure workers understand that this equipment is supposed to be discarded and replaced.
- Whenever it shows signs of wear and tear or damage that could compromise its effectiveness. You will need to train workers to recognize when each type of equipment has worn out and needs replacement.
- On schedule, if it is reusable equipment that must be replaced before it shows obvious signs of being past its useful life. Some types of chemical protective gloves, respirator cartridges, and other PPE can be used multiple times but must be replaced before their effectiveness is compromised. Change schedules are one common way to track this. Make sure employees understand the reason for and the necessity of change schedules.
- After a save, if it is a single use PPE. Hard hats as well as fall protection harnesses and lanyards are two examples of single-use PPE—they can be reused continually until they actually perform a save—taking an impact or catching a falling worker. At that point, they should be replaced.