Re-examining Issues of PPE and the Hierarchy of Controls

Before the pandemic, it seems that the vast majority of the population did not give PPE a second thought. That has changed.

In today’s world, personal protective equipment (PPE) is everywhere. The COVID-19 virus has profoundly affected people worldwide, and outside of social distancing, the next steps in protection are the PPE recommendations from the Centers for Disease Control and Prevention.1 Going to the grocery store or standing in line now requires six feet of separation, mouth coverings and face shields for counter employees.

In comparison to before the pandemic, it seems that the vast majority of the population did not give PPE a second thought. That has changed.

That is why it is important to revisit the issue of personal protective equipment on the job. Meetings after meetings are being held on complying with the guidelines regarding the virus, while in the shadows, there still lies danger to the worker from the other workplace hazards. We as safety professionals need to remember to bring those other hazards out of the shadows and place them back in the spotlight.

The basic PPE issued to many employees generally includes a hard hat, safety glasses, high visibility retro-reflective vest or clothing, safety toe boots and gloves. This discussion will focus on the issue of hand-protection and how the current supply of safety gloves has been able to curtail some of the more significant injuries sustained by the worker.

It’s About Protecting the Hands

Before COVID-19, some employees worked in hazardous conditions with basic hand protection. Providing employees with leather or latex gloves provided a way for some companies to check the box for hand protection and move on. Thankfully, developments over the years have improved the quality and functionality of the current supply of hand protection.2

One area where gloves proved to be an issue is with the nation’s meat packers. With the ever-increasing demand for beef, chicken and pork, the meat packing industry has had to increase production. This means that more people are needed to do the work faster than before and with little consideration for the packer. Combine those elements with sharp knives and a moving line, the chances of hand injuries are increased considerably.3 The response to this increased hazard is to provide cut-resistant gloves to the employee. Check the box and move on.

Hierarchy of Controls

As safety professionals, we know about the hierarchy of controls for safety and we know that PPE is the last line of defense; however, it is the go-to for most companies. Have a hazard to the hands? Buy gloves and check the box. The gloves that are purchased should not be expensive because there is a budget to maintain.

Why do we start with the last line of defense? Our first thought should be to eliminate the hazard. Find out what the issue is during that risk-assessment matrix discussion and try to eliminate it.

With iron workers, for example, it is not uncommon for them to place their hands in the pinch point areas. Lifting tons of iron and putting it in place using cranes and human muscle is how it is done. Lowering columns and beams into position requires the employee to be in between hazard zones. How do we eliminate that issue?

Replace the PPE

Substitution is the next in the line in the hierarchy. That is: “Can we find a different way to make the work happen?” Decades ago, firefighters would ride the rear step of the engine, or hang off the side of the ladder truck. They wore rubber coats with rolled-up boots and plastic helmets. They were issued orange rubber gloves and expected to go into high-heat environments wearing items that would melt onto their skin.

You cannot eliminate the high-heat situation of a structure fire, so the next step would be to substitute the PPE. Plastic helmets were transformed into today’s structural firefighting helmet. Rubber coats gave way to Nomex firefighting bunker gear. Orange rubber gloves were replaced with leather gloves that provide cut and puncture resistance. The hazards of firefighting are now mitigated by substituting out the PPE that would have created an issue.

Engineering a Solution

Engineering is the box below substitution in the inverted triangle of the hierarchy of controls. Construction work has routinely been a field where the typical leather glove was used. The typical leather glove had good dexterity with another layer of skin above the workers’ skin, but not much for cut resistance or puncture protection. However, they did help with keeping the blisters to a minimum when swinging that hammer all day long.

Later, engineering controls were placed in the hand-protection realm by incorporating different materials that would allow for breathability, dexterity, cut and puncture protection and impact resistance. One could always tell a person who used their hands a lot because they would have at least one or two blackened fingernails. Or, they scraped knuckles from working inside an engine compartment on an automobile. People in the industry demanded better protection from these hazards.

So, the safety engineers started looking at what workers do and how they do it. They came up with ways to help via Kevlar materials, impact resistant pads, and ventilation systems to make it more comfortable, etc. This allowed workers to complete their tasks in a more protected set of gloves that were easier to wear for an extended time.

Changing Things

Administrative controls are next in the upside-down triangle. Rotating people out of the hazard zone or changing up the tasks so that one person does not have to be exposed to the hazard is what this section highlights. For example, the employee working on the assembly line doing the same task over and over again can create an overuse hazard. Switching workers out of that task helps mitigate the damage done to an employee’s hands and arms.

Consider the worker who must have their hands in a water bath for hours. After a period, this can become a hazard for the worker. Wearing waterproof gloves is an answer, but with these gloves comes another form of hazard (medical dermatitis and fungal infections, for example). So, counting on the PPE alone is not the answer.

Finally, we come to the actual PPE control: Wear the gloves. That is the standard answer. With the COVID-19 issue, the recommendations are to wash your hands frequently throughout the day, do not touch your face and wear your gloves. Some even suggest washing your hands with gloves on, then removing them and washing your hands again.

Yet, considering the hierarchy of controls we have discussed, wouldn’t it be better to start at the top of the inverted triangle first? The wearing of gloves should be our last thought, not the first. What type of gloves should be worn? With all the different types out there, what is the best for the task at hand? The idea in today’s current culture is to simply wear something that will help avoid the hazard. Little thought is given to how to fix the issue prior to putting on a pair of gloves.

Safety professionals spend time and money on the last step and not so much on the first four steps of the hierarchy of controls. Perhaps we should rethink our approach to the hazards and spend the majority of our time trying to control the hazards with the items in the inverted triangle of the hierarchy of control before relying on the PPE answer.





This article originally appeared in the August 2020 issue of Occupational Health & Safety.

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