Personal protective equipment (PPE) could be considered the ‘fall guy’ of safety management. As any safety professional knows all too well, the dogma in risk management is that PPE is the absolute last resort as a control against a given hazard or risk. There may be variations between different hierarchies of control, but without exception, the use of PPE should always be considered last. Be that as it may, it is contended here that PPE gets a bad rap and deserves its rightful place in the prevention of injuries and occupational disease.
PPE does have its place in safety management, of course. According to OSHA, PPE is “designed to protect workers from serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards.” PPE is varied and can include face shields, safety glasses, hard hats, non-slip safety shoes, protective coveralls, gloves, and earplugs. OSHA’s primary PPE standards can be found in Title 29 of the Code of Federal Regulations (CFR), Part 1910 Subpart I, as well as equivalent regulations in those states with OSHA-approved state plans. Also important from a regulatory standpoint is OSHA’s Personal Protective Equipment Standard Compliance Directive (Directive Number: CPL 02-01-050) which came into effect in October 2011 and which is known informally as the PPE Guidelines for General Industry. It’s important that you read them up if you haven’t already!
OSHA also insists that an organization undertake its own PPE Hazard Assessment, and which must include all necessary PPE considerations within a management system, particularly with regard to the risk assessment process and the implementation of operational controls thereafter. Failure to do this would be a contravention of an organization’s safety and health due diligence, according to OSHA.
The statistics keep reminding us how PPE usage is often lacking. According to the Centers for Disease Control and Prevention, more than 1-million hospital emergency visits by workers in the U.S. could be avoided each and every year if only PPE had been worn. In 2009 alone, hand injuries cost American employers over $500-million dollars in lost time, claims, and the other costs typical of occupational injuries. That is why it so important that PPE be part of a formal incident reporting system such as ConvergePoint – the failure to use appropriate PPE is not only a system non-conformance but should even be recorded as a near miss.