Staying on Top of the Problem

Occupational injuries are very costly, and not just to the affected party. They can drain the company's coffers, its employees' morale, and its standing in the community.

• By Jerry Laws
• Mar 01, 2013

It bears mentioning that head and face PPE is one of the categories that employers are required to provide at no cost to employees. That's one of the givens for this vital category of protection, which is addressed in OSHA's general industry PPE standard, 1910.132.

This standard explains that begins the process starts with a written assessment documenting the hazards in the workplace. Based on what they are and whether they can be adequately addressed through engineering and/or administrative controls, the employer might need to provide various types of PPE: head and face, hearing, vision, hand and arm, foot, respiratory, etc.

The requirements of 1910.132 should be familiar to all of us:

• 1910.132(e): Workers shall not use defective or damaged PPE.
• 1910.132(f)(1): The employee shall train each employee required to wear PPE on when it is needed; what to wear; how to put it on, remove it, adjust it, and wear it; its limitations; its useful life; and proper maintenance and disposal of it.
• 1910.132(f)(3): If the employer has reason to believe an already trained employee does not understand or cannot use the PPE properly, or when changes render previous training obsolete of the types of PPE in use under the previous training are obsolete, that person shall be retrained.

Enforcement cases involving violations of this and the specific eye and face (1910.133) and head protection standards (1910.135) are fairly common and usually are listed by OSHA enforcement releases among an array of alleged violations of varying severity. A recent case involved an Illinois manufacturer investigated last year following a hydrochloric acid leak and cited for allegedly failing to have evacuation routes and procedures specified in its emergency response and contingency plan, failing to ensure respiratory protection was worn and workers were trained to use it, and also failing to ensure workers who were exposed to chemicals, acids, or caustic liquids wore hand, eye, and face PPE. OSHA proposed $41,200 in fines in the case.

The High Costs of Injuries
Occupational injuries are very costly, and not just to the affected party and his or her family. Workplace injuries can drain the company's coffers, sap its employees' morale, and harm its standing in the community.

Former OH&S Technical Editor Linda J. Sherrard always urges safety professionals to keep their programs fresh and alive by reviewing them and updating them regularly. She suggests surveying management and employees to find out how they perceive their facility's safety program and talking with your worker's comp provider to find out where head and facial injuries have occurred and, if possible, whether PPE was not being used by those workers or possibly was not right for the task being done.

Tracking past PPE purchases is another good practice because it helps you pinpoint problem areas or gaps in the program. If processes have changed, it's important to determine whether the PPE being ordered is still appropriate for the hazards in those new processes.

Training is the next piece, as noted in 1910.132(f)(3). Sherrard advises training on safety in general, first aid, PPE use and maintenance, obtaining replacement items, and how to report an injury or a damaged item.

OSHA's Guidance on Hazardous Chemical Exposures in Labs
Head and face PPE includes hard hats, welding helmets, safety eyewear, sideshields, goggles, and faceshields. OSHA mentioned most of these in the recently issued (Jan. 22, 2013) technical amendment to the non-mandatory appendix in its standard on occupational exposure to hazardous chemicals in laboratories, 1910.1450. That amendment was made to include contents from a 2011 National Academy of Sciences publication; adhering to the hierarchy of controls is the third general principle listed in the technical amendment, following minimization of chemical exposures/risks and making an accurate assessment of the risks.

The hierarchy of controls principle says this:

"The hierarchy of controls prioritizes intervention strategies based on the premise that the best way to control a hazard is to systematically remove it from the workplace, rather than relying on employees to reduce their exposure. The types of measures that may be used to protect employees (listed from most effective to least effective) are: engineering controls, administrative controls, work practices, and PPE. Engineering controls, such as chemical hoods, physically separate the employee from the hazard. Administrative controls, such as employee scheduling, are established by management to help minimize the employees’ exposure time to hazardous chemicals. Work practice controls are tasks that are performed in a designated way to minimize or eliminate hazards. Personal protective equipment and apparel are additional protection provided under special circumstances and when exposure is unavoidable.

"Face and eye protection is necessary to prevent ingestion and skin absorption of hazardous chemicals. At a minimum, safety glasses, with side shields, should be used for all laboratory work. Chemical splash goggles are more appropriate than regular safety glasses to protect against hazards such as projectiles, as well as when working with glassware under reduced or elevated pressures (e.g., sealed tube reactions), when handling potentially explosive compounds (particularly during distillations), and when using glassware in high-temperature operations. Do not allow laboratory chemicals to come in contact with skin. Select gloves carefully to ensure that they are impervious to the chemicals being used and are of correct thickness to allow reasonable dexterity while also ensuring adequate barrier protection.

"Lab coats and gloves should be worn when working with hazardous materials in a laboratory. Wear closed-toe shoes and long pants or other clothing that covers the legs when in a laboratory where hazardous chemicals are used. Additional protective clothing should be used when there is significant potential for skin-contact exposure to chemicals. The protective characteristics of this clothing must be matched to the hazard. Never wear gloves or laboratory coats outside the laboratory or into areas where food is stored and consumed."

This article originally appeared in the March 2013 issue of Occupational Health & Safety.