Personal Protective Equipment (PPE) – Getting Back to the Basics!

Gary Smith for AAM BlogWRITTEN BY GARY SMITH, APARTMENT BUILDING MANAGEMENT WORKERS COMPENSATION SELF INSURED FUND

In order to improve performance in any given area, we often times are best served to refocus our efforts on the fundamentals (i.e., “getting back to the basics”).

So, what are the fundamentals with PPE that we need to focus on? Well, let’s focus our attention on the answers to these key questions when considering PPE:

What are employers’ responsibilities?
What are employees’ responsibilities?
How do I know what PPE to require?
How will a system ensure top-level performance with PPE requirements?

What are employers’ responsibilities concerning PPE?
Michigan operates under an OSHA-approved state program, which means that the Michigan Occupational Safety and Health Administration (MISOHA) is responsible for ensuring that the minimal federal OSHA requirements are met by industries throughout the state. MIOSHA’s PPE standards regulate us both under general industry (e.g., any service, maintenance, or housekeeping activities) and construction (e.g., any operation beyond the daily service, maintenance and housekeeping activities such as building/unit renovations and expansions) related operations.

  • Essentially, employers are responsible for:
  • Performing a “hazard assessment” of the workplace to identify and control hazards.
  • Certifying, in writing, completion of a hazard assessment.
  • Identifying and providing appropriate PPE for employees. [Note: The employer must pay for required PPE, except in the limited cases specified in the standard. Safety-toe protective footwear and prescription safety glasses were excepted from the employer payment requirement, in large part because these items were considered to be very personal in nature and were often worn off the job; Final Rules 72:64341-64430, (2007, November 15).]
  • Training and retraining employees in the use and care of the PPE.
  • Maintaining PPE, including replacing worn or damaged PPE.
  • Periodically reviewing, updating and evaluating the effectiveness of the PPE program.

For a great employer resource (i.e., checklists, worksheets, etc.), refer to MIOSHA’s Guide for Personal Protective Equipment for General Industry, SP#16 (see References section).

 responsibilities concerning PPE
Generally, employees are required to:

  • Properly wear PPE.Attend training sessions on PPE.
  • Care for, clean and maintain PPE.
  • Inform a supervisor of the need to repair or replace PPE.

How do I know what PPE to require?
In many cases, your organization will already be using PPE to manage hazards associated with certain procedures, tasks or chemicals. But, how do you know if all your bases are covered with when and how PPE is to be used? Simple, a workplace survey needs to be completed to assess all hazards to employees. A workplace survey will include sources of impact/motion, high temperatures, chemical exposures, hazardous atmospheres, hazardous radiation, falling objects or potential for dropping objects, sharp objects, rolling or pinching objects, layout of the workplace and location of co-workers, and any electrical hazards. By completing a hazard survey of your workplace, you will be able to assess and organize the hazards requiring PPE, select the proper PPE, and train your employees to properly use and maintain the required PPE.

 How will a system ensure top-level performance with PPE requirements?
A “system” in this case is best defined as “an organized or established procedure” (Merriam-Webster). Such a system does not leave certain things to chance, but rather it allows for plans to be successfully realized.

Consider these important aspects in your system:

  • Clearly assign responsibilities amongst your staff for conducting a survey/assessment, purchasing PPE, training, maintaining, etc. as part of your PPE program; and follow-up to ensure that each aspect is completed.
  • Ensure that your written PPE program contains the necessary tools (i.e., checklists, survey forms, etc.) to guide personnel in their efforts.
  • Reassess your program whenever new chemicals, equipment or processes introduce hazards that may require revised PPE strategies. A good rule of thumb is to conduct, at least, an annual survey to ensure you have considered such scenarios in your workplace.
  • Conduct training at proper intervals, which include new hire orientation and periodic refreshers. Refresher training need not be long. In fact, shorter duration training performed at high frequency leads to greater retention than longer duration training performed once a year. For this reason, short safety talks/tool box talks are commonly encouraged to reinforce knowledge and behaviors.

Safety suppliers are often times willing to provide assistance with hazard surveys, selection of proper PPE, and training on use/maintenance without cost. They consider this a necessary service to gain and retain your business. Be sure to take advantage of their expertise, which can save you time, money and frustration!

References

PART 33. PERSONAL PROTECTIVE EQUIPMENT (General Industry) at www.michigan.gov/documents/CIS_WSH_part33_34779_7.pdf

PART 433. PERSONAL PROTECTIVE EQUIPMENT (Occupational Health) at www.michigan.gov/documents/CIS_WSH_part433Rev_53316_7.pd

PART 6. PERSONAL PROTECTIVE EQUIPMENT (Construction) at www.michigan.gov/documents/lara/lara_miosha_CS_6_3-18-2013_414601_7.p

MIOSHA Guide to PPE for General Industry (SP #16) at www.michigan.gov/documents/dleg/deleg_wsh_cetsp16_336065_7.doc

For additional assistance with implementing an effective PPE program and strategies in your workplace, please contact Gary Smith, CRM, at (517) 338-3367 or Gary.Smith@cmi-yorkrsg.com.

 

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