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Enforcing PPE Use
YOU've conducted a hazard assessment, identified personal protective equipment requirements, and trained your employees, but they don't always wear their PPE. Sooner or later, their failure to use PPE will lead to an injury.
How do you get employees to wear assigned PPE? Your goals to accomplish this include:
- Getting employees to understand the need for PPE and to recognize the control they have over their own safety.
- Getting employees to think about safety every day so they wear assigned PPE.
Eliminating the Need for PPE
First, determine whether you can eliminate the need for PPE through engineering controls, work practices, and administrative controls. If PPE isn't necessary, employees won't need to wear it.
Engineering controls involve physically changing a machine or work environment to prevent exposure to the hazard, such as adding a guard to a machine, building a barrier between employees and the hazard, altering a process, or switching to a non-toxic (less hazardous) material.
Work practices involve training workers to perform tasks in ways that reduce exposure to workplace hazards. Changing the way employees do their jobs is a work practice control, such as wetting an area before sweeping to reduce dust.
Administrative controls involve changing how or when employees do their jobs, such as rotation schedules to reduce exposures.
You should implement all feasible engineering, work practice, and administrative controls to reduce or eliminate hazards before using PPE. When such controls are not feasible or effective, provide appropriate PPE that properly fits the workers, communicate PPE selection decisions, and require workers to use and maintain it in sanitary and reliable condition. However, getting employees to actually wear PPE is often a problem.
Typically, employers address PPE use through training, incentives, and enforcement.
The first Step: Training
Training should introduce employees to PPE use and establish the need for PPE. Training not only should help employees understand why they need to wear PPE, but also should encourage them to use it. In addition to communicating the regulatory requirements, inform employees about the hazards of not wearing PPE.
Train employees how to:
- Use PPE properly;
- Be aware of when PPE is necessary;
- Know what kind of PPE is necessary;
- Understand the limitations of PPE;
- Don, adjust, wear, and doff PPE; and
- Properly care for, maintain, and dispose of PPE after its useful life.
The training requirements at 29 CFR 1910.132(f)--Training include specific provisions for both the employer and the employee. These include the following:
- The employer must provide training to each employee who is required to use PPE.
- The employer must train these employees to know when PPE is necessary and what PPE is necessary.
- The employer must verify that affected employees received and understood the required training through a written certification that contains the name of each employee trained, the date(s) of training, and the subject of the certification.
Make sure employees know that PPE does not eliminate a hazard. If the equipment fails, they will be exposed to hazards. To reduce the possibility of failure, equipment must be properly fitted and maintained in a clean and serviceable condition.
During training, describe your company's hazard assessment. Match your presentation with the needs of the group (the level of detail will be greater if the group has continual exposure to extensive hazards than if it has occasional exposure). Provide detail on the hazards in the facility and what kind of PPE employees need to protect themselves.
Tell employees exactly what hazards they may face, and review company experience with each hazard they encounter. Perhaps you have an unfortunate (or extremely fortunate) story that you can share, whether at your company or at another. The goal is to make them understand the need for PPE and recognize the control they have over their own safety.
Keep a copy of your training materials or a training outline as a guide for your next program. If you follow up on how trainees perform after the session, you can improve your program the next time you give it.
When you believe a trained employee does not have the understanding and skill to use PPE properly, you need to retrain that employee. Situations where this may happen include:
- Changes in the workplace.
- Changes in the types of PPE used.
- Inadequacies in an affected employee's knowledge or use of assigned PPE.
- Reacquaint employees with any engineering controls (e.g., machine guards) and emphasize how important their use is to injury prevention.
Safety incentive programs can encourage employees to wear PPE. The program should make them feel responsible for safety and encourage co-workers to look out for one another and point out unsafe behaviors. Managers and supervisors should set the example by always wearing appropriate PPE for the work area.
Engineering, administrative, and work practice controls, as well as the use of PPE, help to eliminate hazards. Incentive programs attempt to eliminate unsafe behaviors, including failure to use PPE.
Posters and warning signs can increase safety awareness, but they don't get employees involved. Recognition programs, safety committees, and incentive programs get employees involved in the safety process. The program implementation may vary, but the goal is to get employees to think about safety every day.
Make sure employees use PPE whenever it is required, and encourage them to take the time to don appropriate PPE. They may not want to bother with PPE if they're expecting to enter the "danger zone" for only a short time. Make them accountable for such behavior. Encourage participation by rewarding those who follow the rules.
Incentive programs should allow for feedback. As noted in the case study included in this article, employees may refuse to wear PPE because they forget, because it is uncomfortable, or because it interferes with their work. A feedback system, or simply walking the floor to question employees, can help identify such problems. You may be able to identify changes in equipment or processes that will improve the consistency of PPE use.
A Case Study: Eye Protection
A chemical company reported an employee's eye injury on its 300 log and listed the cause as the employee's failure to wear eye protection. An OSHA interview found the manager was reluctant to discipline the employee, who was an excellent worker. Typical of most companies, the accident report appears to blame the victim.
Employee interviews were conducted to determine why employees failed to wear eye protection. The interviews found that employees did not wear goggles 75 percent of the time because they forgot them in their lockers, 10 percent of the time because they felt the goggles did not fit or slipped off, and 15 percent of the time because they experienced fogging. To address these issues, the company could purchase retainer clips that attached the goggles to the workers' hard hats and change the style of goggles to eliminate the fogging problem.
This case study shows a common problem: inconsistent enforcement. It also illustrates steps that employers can take to promote PPE use by understanding why employees don't wear PPE and addressing the cause directly. As illustrated, the employer might not need disciplinary action to encourage PPE use.
The Final Option: Enforcement
Enforcement is the last line of defense, but is no less important. Enforcement comes last because when you discipline an employee for not wearing PPE, you have already missed the goal: getting the employee to wear it in the first place.
During training or safety meetings, review your company policy on discipline for failure to use assigned PPE. Remind them OSHA developed these rules for their benefit: to reduce or eliminate injuries. Remind them the company cares about their safety. Talk about the costs of injuries and downtime, and how these affect them. Consider the effects of injuries on their morale. You may want to cover company policy on workers alerting supervisors, visitors, or other persons who are not wearing appropriate protection for the hazards present.
Remember, enforcement does not necessarily mean blaming the employee. Keep an open mind toward changes you could make to improve employee use of PPE, as illustrated in the case study.
Records of accidents can serve to identify problem areas. An injury might be caused by failure to wear PPE or by other factors. Therefore, outline supervisor responsibilities in tracking injuries. For instance, you may have them:
- Record and file reports from date of injury through all subsequent follow-up activity, including workstation evaluations and disciplinary action.
- Forward information about the injury for entry on the OSHA Injury and Illness form.
- Recommend that the job receive a job hazard analysis.
The Bottom Line
A PPE program sets procedures for selecting, providing, and using PPE. A written PPE program is easier to establish and maintain as company policy. It is also easier to evaluate than an unwritten one. Employers need to decide how to enforce PPE use, provide for any required medical examinations, and evaluate the PPE program.
Your program should incorporate training requirements, incentives, and enforcement into a comprehensive plan to protect employees. After all, protecting employees and preventing injuries is the ultimate goal. How you go about doing this may vary, but remember that the responsibility lies both on employees to follow the rules and on the employer to enforce the rules through training, incentives, and discipline.
This article originally appeared in the February 2004 issue of Occupational Health & Safety.