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Job Hazard Analysis/PPE

Personal Protective Equipment (PPE) at Seton

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Job-related injuries and fatalities occur every day in the workplace. These injuries often occur because employees are not trained in the proper job procedure. One way to prevent workplace injuries is to establish proper job procedures and train all employees in safer and more efficient work methods. Establishing proper job procedures is one of the benefits of conducting a job hazard analysis- carefully studying and recording each step of a job, identifying existing or potential job hazards (both safety and health), and determining the best way to perform the job or to reduce or eliminate these hazards. Improved job methods can reduce costs resulting from employee absenteeism and workers' compensation, and can often lead to increased productivity.


Employer Payment for Personal Protective Equipment

Many Occupational Safety and Health Administration (OSHA) health, safety, maritime, and construction standards require employers to provide their employees with protective equipment, including personal protective equipment (PPE), when such equipment is necessary to protect employees from job-related injuries, illnesses, and fatalities.

These requirements address PPE of many kinds: hard hats, gloves, goggles, safety shoes, safety glasses, welding helmets and goggles, faceshields, chemical protective equipment, fall protection equipment, and so forth. The provisions in OSHA standards that require PPE generally state that the employer is to provide such PPE. However, some of these provisions do not specify that the employer is to provide such PPE at no cost to the employee. In this rulemaking, OSHA is requiring employers to pay for the PPE provided, with exceptions for specific items. The rule does not require employers to provide PPE where none has been required before. Instead, the rule merely stipulates that the employer must pay for required PPE, except in the limited cases specified in the standard.

The final rule becomes effective on February 13, 2008. The final rule must be implemented by May 15, 2008.

64342 Federal Register / Vol. 72, No. 220 / Thursday, November 15, 2007

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Fatal FactGo to the top of this page
While changing out an electric drive motor for an elevator leg, Employee #1 was struck several times by a rotating turnbuckle used to maintain tension on drive belts. As a crane lifted the electric motor, the loose tension turnbuckle started rotating and struck him. He fell out through the existing guardrails 55 ft to the ground. Employee #1 sustained multiple fractures and was killed.
OSHA StandardsGo to the top of this page



A hazard assessment is an important element of a PPE program because it produces the information needed to select the appropriate PPE for any hazards present or likely to be present at particular workplaces. Your employer is then capable of determining and evaluating the hazards of a particular workplace. 29 CFR 1910.132(d) of the PPE standard details hazard assessment requirements. It is a performance-oriented provision that simply requires management to use their awareness of workplace hazards to enable them to select the appropriate PPE for the work being performed. 

Examples of equipment required to be provided by employers include but are not limited to:

  • Welding or wire mesh gloves;

  • Respirators;

  • Hard hats;

  • Specialty glasses and goggles such as those used for laser and ultraviolet radiation protection;

  • Specialty foot protection such as metatarsal shoes and lineman's shoes with built-in gaffs [such as those used for climbing];

  • Face shields;

  • Rubber gloves, blankets, cover-ups; and

  • Hot sticks and other live-line tools used by power generation workers.
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Subpart I - Personal Protective Equipment

OSHA requires the use of personal protective equipment (PPE) to reduce employees' exposures to hazards when engineering the administrative controls are not feasible or effective in reducing these exposures to acceptable levels. Employers are required to determine all exposures to hazards in their workplace and determine if PPE should be used to protect their workers.

If PPE is to be used to reduce the exposure of employees to hazards, a PPE program should be initialized and maintained. This program should contain identification and evaluation of hazards in the workplace and if sue of PPE is an appropriate control measure; if PPE is to be used, how it is selected, maintained and its use evaluated; training of employees using the PPE; and vigilance of the program to determine its effectiveness in preventing employee injury or illness.

  •  1910.95  General requirement

  • 1910.132  General requirement

  • 1910.133  Eye and face protection

  • 1910.134  Respiratory protection

  • 1910.135. Head protection

  • 1910.136  Foot protection

  • 1910.137  Electrical protective equipment

  • 1910.138  Hand protection

  • 1910.139  Respiratory protection for M. tuberculosis (Revoked 68 FR 75776)

  •  1926.28   Personal protective equipment.

 Federal Register Preamble to the Hazard Communication Standard

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Chemical Storage Signs - Identify all your chemical storage equipment and areas
Written ProgramsGo to the top of this page

The employer must perform a hazard assessment of the workplace to determine if hazards are present, or are likely to be present, which require the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

  • Select, provide and require the use of appropriate PPE for each affected employee.

  • Communicate PPE selection decisions to each affected employee.

  • Select and provide PPE that properly fits each affected employee.

  • Conduct and document appropriate employee training.

Written plan

Training RequirementsGo to the top of this page
After proper PPE for each process/equipment has been selected, the employer must provide the equipment to employees and train them in its proper use.

At a minimum, each employee using PPE must know:

  • When PPE is necessary
  • What PPE is necessary and which PPE has been selected for each process the employee operates
  • How to properly put on, take off, adjust and wear PPE
  • The limitations of the PPE
  • How to determine if PPE is no longer effective or is damaged
  • How to get replacement PPE
  • How to properly care for, maintain, store, and dispose of PPE

After employees have been trained, periodic assessment of the process/equipment should be conducted to ensure that the PPE is adequate and training is appropriate.

Retraining of employees is required whenever:

  • Changes in the workplace render the previous training obsolete
  • Changes in the type of PPE render previous training obsolete
  • Employer observed inadequacies in an employees' knowledge or use of assigned PPE indicates that an employee has not retained the necessary understanding or skill

Employers must verify that each employee who is required to use PPE has received and understood the required training. This must be accomplished via a written certification of training.

Finally, injury and accident data (OSHA 300 Log, first aid logs, Worker's Compensation injuries) should be reviewed to help identify problem areas.

Sample Training Program
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OSHA 3151 Assessing the Need for Personal Protective Equipment: A Guide for Small Business Employers
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