Personal Protective Equipment Best Practices - Meatingplace.com - Technical Article - updated 03/12/2022

The history of protective clothing can be traced back to the eighth century B.C., where it was documented from within an ancient Greek poem “Homers Odyssey.”

In the poem, there is a brief description of someone using gloves to protect his hands from thorns as he worked away in his garden.

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BEST PRACTICES FOR PERSONAL PROTECTIVE EQUIPMENT

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By Steve Sayer on 7/11/2016 - Meatingplace.com - Technical Article - updated 03/12/2022

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This technical article limits its focus to the unique personal protective equipment (PPE) that’s commonly utilized within the food, beverage, meat and poultry industries regarding production, sanitation and shipping/receiving employees.

General maintenance practices, in-house fire brigades, respiratory protection (29 CFR 1910.134) fall protection (29 CFR 1910 General Industry) emergency response teams (29 CFR 1910.120) including in-house nursing/health care shall not be discussed as they warrant a technical review of their very own because of their inherent breadth and depth.

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PPE is one of the most important safety and health programs that exist 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.

Using PPE is often essential, but it’s generally the last line of defense after engineering controls, work practices and administrative controls have been exhausted:

• Engineering controls involve physically changing a machine or working environment.
• Work practices involve training workers on how to perform tasks in a manner that will reduce their exposure to acceptable and safe exposures to the workplace hazards that exist.
• Administrative controls involve changing how or when workers perform their jobs, such as scheduling and rotating workers to shorten exposure.

Examples of PPE

Head protection – When appropriate, American National Standards Institute (ANSI) rated hardhats are used if the employer’s intention of the helmet is for head protection. The hardhat must meet ANSI Z89.1 1986 specifications for protection. Prudent companies have adopted such hardhats so that ear protection and face-shields may be easily attached.

Eye and face protection – Safety glasses/goggles must meet ANSI Z87.1-1989 specifications. Face-shields that attach to hardhats provide added protection. Such a combination leaves no gap between the shield and the brim of the cap while preventing overhead splashes from running down inside the face-shield. Face-shields must meet ANSI Z87.1-1989 specifications. Whenever such PPE is intended to guard against chemical exposure, safety data sheets (SDS) will list recommended requirements under Section 8 - Exposure Controls/Personal Protection.

Hand protection – This includes steel mesh and cut guard gloves; chemical resistant gloves; heavy-duty gloves. Steel mesh and cut guard gloves guard are designed to guard against knife cuts but will not protect against punctures by the tips of knives. Such gloves should never be worn when operating band saws.

Heavy leather gloves may be worn over chemical protective gloves when performing heavy work. If gloves become contaminated, they should be discarded because leather is difficult to decontaminate. Jacket cuffs may be worn over glove cuffs to prevent any liquid from spilling into the gloves. If hands are elevated above the head during work, the gloves should be sealed with tape to the coveralls or splash-suit.

When selecting gloves consider thickness and cuff length. The thicker and longer the glove, the greater the protection. However, the material should not be so thick that it interferes with dexterity. Two pairs of gloves should be considered for extra protection of hands if the outer glove is torn or permeated. A pair of inner gloves also adds an extra layer of protection for the hands during the removal of outer gloves and other chemically protective items. When PPE is intended to help guard against chemical exposure, SDS will recommend such requirements.

Forearm protection – Plastic arm shields: chemical resistant plastic arm covers. Plastic arm shields guards against knife cuts. When PPE is intended to help guard against chemical exposures, SDS will recommend such requirements.

Body protection – Steel mesh aprons, plastic, neoprene or dissimilar chemical resistant aprons. Steel mesh aprons guard effectively against knife cuts. Clothing that’s intended to protect the body against hazardous liquids, gases, or vapors is available in a variety of styles and materials. If the hazard present is minor, minimal protection is warranted. As the hazards to the body increase, so does the level of protection needed. A splash suit made of PVC is suitable for a liquid such as an acid or base or when there will be minimal contact with organic materials. Splash suits similar in design to the PVC splash suits are good barriers against toxic hazards that are made of neoprene and butyl rubber. When PPE is intended to help guard against chemical exposures, SDS will recommend such requirements.

Foot and leg protection – This includes steel toed, anti-slip footwear. Footwear worn (including leather work boots and rubber boots) must meet the specifications of ANSI Z41.1-1991. The material used to make the boots is not subject to any standards. Protection against liquid hazardous chemicals requires a boot of neoprene, PVC, butyl rubber. Boots are available in two styles: pullover and shoe-boot. Pullovers may be inexpensive enough to be considered disposable. With chemical resistant boots, the pant leg should be outside and over the boots to prevent liquids from entering.

Hearing protection – Earplugs or muffs should be issued when noise may be a problem. The need to provide hearing protection for employees depends on several factors:

1. Loudness of the noise as measured in decibels (dB).
2. Duration of each employee's exposure to the noise.
3. Whether employees move between work areas with different noise levels.
4. Whether noise is generated from one or multiple sources.

Generally, the louder the noise, the shorter the exposure time before hearing protection is required. For example, employees may be exposed to a noise level of 90 dB for eight hours per day (unless they experience a Standard Threshold Shift) before hearing protection is required. However, if the noise level reaches 115 dB, hearing protection is required if the anticipated exposure exceeds 15 minutes. More detailed discussions involving the requirements for a hearing conservation program can be found at 29 CFR 1910.95, Occupational Noise Exposure, section C.

Required OSHA PPE standards

OSHA has made it the responsibility of each employer to conduct a job hazard analysis (click 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)(ii) – When 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.

Relevant PPE OSHA updates

• On Nov. 15, 2007, OSHA issued a final rule on "Employer payment for PPE." This rule helps clarify to employers in the general industry that the majority of PPE is to be paid by the employers – not by the workers.
• On Jan. 12, 2009, OSHA amended its standard to add language clarifying that the PPE and training requirements impose a compliance duty to each 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 this directive called the "Enforcement guidance for PPE," for the general industry. This directive proffers OSHA personnel with instructions for determining whether employers have complied with the OSHA PPE standard. This directive also further delineates the November 2007 final rule on employer payment obligations concerning PPE.

Note: As with any OSHA standard or directive that may be discussed, know 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.

-- Steve Sayer owns Sayer Consulting / Auditing, LLC - Technical article from Meatingplace.com