By Kyle Gagnon, CSP, EHS Client Advisor II, U.S. Compliance
A safety professional’s primary purpose is to identify, analyze, and eliminate hazards before the risk of potential employee exposure. While many of these hazards can be controlled through means of workplace design and modification, some hazards are not as easily controlled and can remain even after thorough process improvements. For the hazards that continue to exist, the last line of defense in the safety arsenal is Personal Protective Equipment (PPE).
What is Personal Protective Equipment (PPE)?
PPE is a physical barrier worn by employees that prevents direct exposure to hazards. Forms of PPE may include eye & face protection, hand protection (gloves), protective footwear, respiratory protection, hearing protection, and fall protection. If an employer has exhausted all other means of controlling a hazard, they then will select the appropriate PPE needed to protect employees based on the present hazards.
Since PPE worn by employees is the very last line of defense, it is imperative that employers accurately select equipment that is suitable for the hazard it is protecting against and fits the employees properly. Failing to provide sufficient PPE for employees not only continues to expose them to the same workplace hazards unprotected but, in many circumstances, can lead to more serious risks. For example, if an employee wears safety glasses that are not designed for impact resistance (meeting ANSI Z87 requirement), then the glasses could break upon impact, and plastic shards could cause additional injury to the employee. This is why careful selection of PPE should only take place after the job/task is thoroughly assessed for all hazards.
What Does a Thorough Hazard Assessment Look Like?
Per OSHA 1910.132(d), employers shall assess the workplace to determine if hazards are present or are likely to be present, which necessitate the use of PPE. In the safety world, we refer to these assessments as Job Hazard Assessments (JHAs), and they are the cornerstone of any effective PPE program.
JHAs are task-specific assessments that analyze how a task is performed, any tools needed to perform the task, the potential risks associated with the activity, and any controls needed to reduce said risks. For each risk that is present in a task, an associated control should be present to reduce exposure to that risk scenario. If no control exists or one is not feasible to implement, then this is a potential safety gap that may be addressed using personal protective equipment.
Now, you might be curious why, in this context, we refer to these unsafe conditions and behaviors in a task as “risks” rather than “hazards.” That’s because JHAs don’t just take into consideration a hazard that is present, but assess the severity of the hazard as well as the likelihood of it causing an injury to employees. If hazardous tasks are repeated at a high frequency (multiple times in an hour), those are said to have a high probability of resulting in an injury. While hazardous tasks that have a large consequence of injury (loss of limb, hospitalization, death, etc.) are considered to have a higher severity. During the completion of a JHA, if a task is determined to have a hazard that is both high severity and high probability of resulting in injury, that task should be examined first for implementation of additional controls to lower its overall risk.
On the other hand, tasks that have less severe and less probable hazards are less of a focal point and can be addressed at a later time. It’s important to note that PPE is not an acceptable control for any task that is determined to be “high risk.” Other means of control must first be explored before PPE is deployed. If engineering or administrative controls cannot feasibly be utilized to eliminate or reduce the risk, then proper PPE must be selected based on the hazard identified in the JHA process.
What Are Some Common Issues When Managing a PPE Program?
One of the hardest parts of an effective PPE program is managing your on-site inventory of equipment. While necessary, PPE can also be very expensive, and if supplies are not managed properly by the site, costs can begin to add up quickly. Some issues surrounding inventory management include employees taking more equipment than is needed for a job, unauthorized employees taking equipment outside their job scope, and insufficient equipment re-stock times. If left unchecked and improperly managed, these scenarios can cripple a PPE budget and drive overhead costs for necessary safety items to exorbitant levels. For a PPE program to be effective, it is imperative that companies develop a balanced system that helps control the materials being selected and obtained by employees while also ensuring equipment is readily available when the time arises.
Another contributor to unsuccessful PPE programs is not having a responsible party selected by management that will oversee and manage the PPE inventory. In an ideal world, the person responsible for PPE inventory management will have a proper understanding of all the on-site tasks that require specific PPE, as well as the reasonable allocations that employees need on a daily or weekly basis to ensure their protection without overspending. However, what happens in many cases is that a purchasing agent or someone removed from the operations side of the business is put in charge of acquiring and managing the PPE inventory since their primary role is acquiring materials to run the business. While this person may have a good understanding of raw materials usage and small components that are needed to sustain production, they may lack the understanding of what protective equipment is needed for each employee’s job function, which can lead to improper PPE inventory management at the facility. Before an employee can be assigned to this role, management must do their due diligence to verify the employee’s knowledge of the job functions requiring PPE use, as well as the total number of allocated items needed per employee.
What Can Be Done to Maximize the Effectiveness of a PPE Program?
As stated above, the best way to ensure a PPE program thrives is by having a knowledgeable company representative assigned to inventory management who can oversee the items being purchased. To assist with the purchase and acquisition of materials, there are several options available in the industry that can make this process less “hands-on” and limit the amount of responsibility that the on-site PPE inventory manager has.
Industrial equipment suppliers have an entire sub-sector of their business that is tailored towards PPE selection and inventory management. Leveraging these suppliers for on-site PPE assessments to determine which equipment can efficiently yet affordably protect employees can lead to long-term cost savings for the company. Many PPE suppliers also offer equipment vending machines that allow pre-determined allocations to be set for each employee based on their job functions at the facility. This can assist with controlling the amount of PPE distributed to employees on a daily or weekly basis without exceeding a set threshold. Vending machines are also monitored remotely by the supplier to assist with re-stock times and track trends in material usage to ensure enough inventory is available at any given time. For more information on vending machine capability and applicability, we highly encourage reaching out to your current PPE supplier and see if this is an option at your respective site.
Having an effective PPE program not only increases worker safety but can also lead to major cost savings for a business. Leveraging PPE supplier relationships can offer effective ways to ensure the proper equipment is selected for the workplace hazards assessed while also reducing unnecessary spending. By ensuring responsible parties are assigned for inventory management, assessing the workplace to determine what PPE is necessary, and having a systemic process for inventory control, a business can effectively yet affordably protect its employees.
For more information on PPE and tailored assistance, contact U.S. Compliance today to prioritize safety at your facility and maintain complianc.