Training & Education
The OSHA Standards addressing Personal Protective Equipment (PPE) for General Industry is located within Subpart I of 29 CFR 1910. These standards consist of General Requirements (1910.132), Eye and Face Protection (1910.133), Respiratory Protection (1910.134), Head Protection (1910.135), Occupational Foot Protection (1910.136), Electrical Protective Devices (1910.137) and Hand Protection (1910.138). Additionally, there are 2 non-mandatory appendices A (References for Further Information) and B (Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection).
Keep in mind that the standards alone are not going to provide all of the information that you will need to be effective in your PPE program, as reviewing and being familiar with the Interpretations, Letters of Understanding, and Directives will also benefit you in selling your plan and obtaining the necessary buy-in from management and employees.
â€œFlesh outâ€ your plansAfter reviewing the General Requirements (1910.132) for the application (subpart a), assessment and selection (subpart d) of PPE, you should be ready to start â€œfleshing outâ€ your plans for PPE (i.e., what, when and where PPE are necessary). As you may already have all or some of the necessary PPE onsite you can take advantage of the familiarization and training materials provided by the manufacturers of that PPE; this will usually include written materials and, perhaps, video materials. Speaking of video-based training, OSHA now expects:
Training shall consist of a combination of formal instruction (e.g., lecture, discussion, interactive computer learning, video tape, written material), practical training (demonstrations performed by the trainer and practical exercises performed by the trainee), and evaluation of the operatorâ€™s performance in the workplace.
So not only is it prudent (from an OSHA compliance standpoint) of you to put together a comprehensive plan of training and education, it is best to finally let go of the old ways of doing things (sitting the employee down to sign in, watch a video while you do paperwork or leave and have breakfast, and then release them as â€œtrainedâ€).
Start with supervisorsDeciding who will be the first employees to undergo training and education is no less important or critical than any of the steps taken up to this point in your plan. My advice? Start with supervision, and then implement your plan with â€œTraining and Verification (subpart f)â€ in mind, which states: â€œThe employer shall provide training to each employee who is required by this section to use PPEâ€¦â€ It goes on to list various items that each such employee shall be trained to know, things like: when PPE is necessary; how to properly don and wear PPE; proper care, maintenance and disposal of PPE; and so on. It also discusses when retraining is needed.
Rather than this being the end it is actually just the beginning. Supervision, enforcement and coaching (along with discipline, as necessary) follow closely in order to ensure proper use and, more importantly, appropriate protection. Now add inspection and maintenance to the mix, and donâ€™t forget about refresher and retraining sessions.
To me though, finally, I believe that each of us has to be open to critical evaluation of any of our efforts and be open and resilient enough to make changes that are in the favor of the employees whom we have been given the responsibility to watch over. So be ready to adapt, and revise any of your efforts.