Improve PPE compliance
March 1, 2008
At my workplace, we’ve put together a personal protective equipment (PPE) plan that has worked effectively for us over the past ten years. Each year we review it â€” unless incidents indicate more frequent review â€” update/revise it, and then present it to employees via toolbox and/or supervisor safety meetings. Here’s how our PPE plan works:
The purpose of this plan is to establish procedures for the use of personal protective equipment (PPE) at O’Hare Airport Transit System (OATS) Inc.
This plan supports compliance with the Occupational Safety and Health Administration (OSHA) standards that cover PPE, specifically, 29 CFR 1910.132 (General Requirements), .133 (Eye and Face Protection), .134 (Respiratory Protection), .135 (Head Protection), .136 (Foot Protection) and .138 (Hand Protection).
The Plan Administrator is the general manager-safety/training or his/her designee, and is responsible for:
- Issuing and administering this plan and making sure that it is in compliance with all applicable federal, state and local PPE requirements;
- Identifying hazards to the eyes, face respiratory system, head, feet, hands, and prescribing appropriate PPE;
- Ensuring that employees receive initial and refresher training on PPE use;
- Maintaining education and training records for all employees included in the education and training sessions.
- Knowing the hazards in their particular areas and for their particular activities;
- The appropriate PPE for those hazards;
- Assuring that safe operations are maintained within their departments to prevent injuries to the eyes, face, respiratory system, head, feet and hands;
- Enforcing PPE use in the areas, and for the activities, that require it.
- Using appropriate PPE, in the proper way, in the areas and during activities that require its use;
- Maintaining, cleaning and storing PPE, as directed;
- Changing out PPE when it wears out, cannot be cleaned or can no longer be maintained in usable condition.
1. Eye, face, respiratory, head, foot and hand hazards have been assessed within the facility; where those hazards have not been eliminated or controlled via engineering means appropriate protection will be provided for all affected employees.
2. A change in materials, processes, procedures and/or equipment may result in the introduction of new hazards to which the employees are exposed. Supplemental assessments of the hazards of work activities will be undertaken whenever such changes occur.
3. Employees are required to use PPE wherever hazards exist.
4. PPE will be replaced when damaged or worn out.
5. PPE will be used, maintained, stored and replaced, as directed.
6. Visitors are required to wear the following PPE:
a. Eye protection equipped with sideshields when within the “yellow” lines in the maintenance and machine shops, or wherever/whenever flying particle hazards are present;
b. Bump caps in areas that contain “head strike” hazards (i.e. beneath vehicles or within two feet of vehicles elevated on jacks);
c. Hard hats in areas that contain overhead falling objects hazards (i.e. directly beneath, or within five feet of track areas where work activities are underway);
d. The same level of PPE as employees engaged in the chemical-related activity (i.e. face shields, splash goggles, chemical protective clothing, etc.) or when within ten feet of those active work areas.
Eye and Face Protection
1. Employees who work in areas with potential flying particle hazards are required to wear eye protection (i.e. safety glasses equipped with sideshields or impact-resistant goggles); a face shield, used in combination with eye protection, may also be necessary during hammering, drilling, sawing, sanding, grinding, chipping, etc.
2. Employees who work in areas with potential chemical splash hazard, such as during pressure-washing or parts cleaning, are required to wear splash-proof goggles and a face shield.
3. All safety glasses will be equipped with sideshields.
4. Prescription glasses:
a. Employees who wear prescription glasses and work in areas that contain eye injury hazards are required to wear prescription safety glasses that are equipped with sideshields, or an over-the-glasses style of eye protection;
b. Employees should obtain an eye exam from optometrists approved for reimbursement under the health benefits plan (if enrolled), or an optometrist of choice at their own expense;
c. Employees should obtain prescription safety glasses from optometrists/opticians approved for reimbursement under the health benefits plan, or optometrists/opticians of choice at their own expense;
d. Employees will be required to replace prescription safety glasses if damaged or when the corrective lens prescription changes.
1. Areas and activities requiring mandatory use of respiratory protection:
a. No work areas or activities have, through air monitoring and analysis, been established to require the use of mandatory respiratory protection.
b. Employees, who work in areas that contain airborne contaminant hazards that present nuisance, physical and/or health hazards (according to OSHA and/or ACGIH standards), are required to wear respiratory protection.
c. The degree of respiratory hazard must be assessed through sampling, monitoring, instantaneous readings and/or laboratory analysis for all routine and non-routine employee activities. Appropriate exposure controls, engineering and administrative, will be established prior to the requirement for respiratory protection.
d. The degree of respiratory protection required will be based on sampling results. The highest level of respiratory protection, deemed appropriate for the exposure, will be used until sampling results establish that a downgrading of protection factors is appropriate.
e. Incidental exposure hazards, such as those posed from contractor activities, will be assessed during preconstruction planning. Appropriate exposure controls will be established prior to the introduction of those incidental hazards into the OATS environment; personal protective equipment will be the last resort, after engineering and administrative controls.
2. Disposable respirators are available for voluntary use only.
3. Respiratory protection equipment must be used according to the Respiratory Protection Plan.
1. Employees who work in areas that contain overhead falling object hazards are required to wear hard hats (i.e. directly beneath or within a five-foot perimeter of overhead work activities).
2. Bump caps are available for those employees who work in areas that contain head strike hazards.
3. Hard hats must be used according to manufacturer’s instructions and cannot be altered in any way.
4. Approval must be gained prior to the application of any sticker or decal to the hard hat or bump cap.
1. Employees who work in areas that contain foot hazards are required to wear appropriate footwear.
2. Hard-toe footwear (preferably composite, rather than steel) shall be worn by electronic, electro-mechanical and mechanical technicians, custodial and stores personnel, and any employees, visitors or contractors exposed to similar hazards.
3. Protective footwear must meet the ANSI Z4-1991 (or currently accepted) standard for same.
1. Employees who work in areas that contain hand hazards are required to wear appropriate gloves as prescribed in the Rules Book.
2. To prevent employees from getting caught on equipment, gloves will not be worn in operations around moving machinery such as the lathe or drill press.
3. If contamination of other work surfaces is possible, gloves shall be removed before those work surfaces are touched.
4. High voltage gloves shall be:
a. Inspected on a weekly basis as a part of the self-inspection protocol;
b. Inflation-tested on an “as-used” basis;
c. Dielectrically tested on a six-month basis;
and used for:
a. Voltage testing;
b. Application of shorting devices;
c. Attaching, detaching or otherwise handling the umbilical cords.