Let’s get personal

WORKING SAFELY BY STEVE SAYER

(The views and opinions expressed in this blog are strictly those of the author.)

Steve Sayer is a 41-year veteran of the beef / poultry industry and a food safety / FDA / OSHA / Humane Handling and GFSI consultant representing Sayer Consulting / Auditing, LLC (San Clemente, Calif.) Reach him at sayersteve9@Gmail.com.

You don’t tug on Superman’s cape, you don’t spit into the wind, you don’t pull the mask off the old Lone Ranger and … you always wear your assigned personal protective equipment.

James Joseph Croce  Jan. 10, 1943 – Sept. 20, 1973) was an American folk and rock singer-songwriter.  

Personal protective equipment (PPE) is one of the MOST important safety and health programs that exists today.

Its wide and expansive breadth can potentially mean the difference between vision or blindness; hearing or deafness; health or injury/disease; including life or death.

Federal OSHA’s PPE standard (tap here) clearly states that whenever employees are exposed to hazards at the workplace, including instances where engineering or administrative controls are not effective or feasible in eliminating the hazard(s), then PPE are to be provided and used.

OSHA has made it the responsibility of each employer to conduct a job hazard analysis (tap here) of each assigned job and to determine if PPE is needed or not.

If PPE is to be used, then a written PPE program is required to be created and implemented for each individual PPE put into use. Each PPE program should address the following areas; 

        1910.132(d)(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

        1910.132(f) -Training.

        1910.132(f)(1) -The employer shall provide training to each employee who is required by this section to use PPE. Each such employee shall be trained to know at least the following:

        1910.132(f)(1)(i) - When PPE is necessary;

        1910.132(f)(1)(ii) - What PPE is necessary;

        1910.132(f)(1)(iii) - How to properly don, doff, adjust, and wear PPE;

        1910.132(f)(1)(iv) - The limitations of the PPE; and,

        1910.132(f)(1)(v) - The proper care, maintenance, useful life and disposal of the PPE.

        1910.132(f)(2) - Each affected employee shall demonstrate an understanding of the training specified in paragraph (f)(1) of this section, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

         1910.132(f)(3)- When the employer has reason to believe that any affected employee who has already been trained does not have the understanding and skill required by paragraph (f)(2)of this section, the employer shall retrain each such employee. Circumstances where retraining is required include, but are not limited to, situations where changes in the workplace render previous training obsolete; or changes in the types of PPE to be used render previous training obsolete; or inadequacies in an affected employee's knowledge or use of assigned PPE indicate that the employee has not retained the requisite understanding or skill.

Nov. 15, 2007 OSHA issued a final rule on "Employer payment for PPE." This rule helped to clarify to employers in the general industry that the majority of PPE is to be paid by the employers – not by the workers.

On January 12, 2009 OSHA amended its standard to add language clarifying that the PPE and training requirements impose a compliance duty to each and every employee covered by the standard and that noncompliance may expose the employer to liability on a per-employee basis.

On Feb. 10, 2011 OSHA released a directive called the "Enforcement guidance for PPE," for the general industry. This latest directive provides OSHA personnel with instructions for determining whether employers have complied with the OSHA PPE standard. This directive also further delineates the Nov. 2007 final rule on employer payment obligations concerning PPE.

NOTE: As with any OSHA standard or directive that may be discussed in this working safely blog, keep in mind that if your state legislators elected to have their own state-OSHA, there can be marked differences between your particular state-OSHA requirements and that of federal OSHA's requirements; differences that your company must be aware of and abide to.

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WORD OF THE DAY

INTERLOCUTOR

Interlocutor is a formal word that means “one who takes part in dialogue or conversation.”

"It is crucial in our age of e-mail scams to verify the validity of one’s online interlocutors before sharing sensitive information."

“The Turing Test is a test of intelligence, sentience, consciousness and self-awareness. A machine passes the Turing Test if it can convince a human interlocutor that it is sentient.”