Hazard Assessment, Eye Protection, and You
You can make sense out of the PPE necessity. Here's how to end the confusion and take the ambiguity away from the worker and the OSHA inspector.
YOU have read the MSDS for the special alcohol that your plant uses and it says to use eye protection. But what does that mean?
One manufacturer's MSDS says to use safety glasses when using the chemical, but the MSDS from another manufacturer says to use safety goggles. What are you to do?
When working with the liquid sealer, the MSDS says use a faceshield. When working with the dry abrasive, the MSDS says goggles, and the MSDS for the pigment says only safety glasses. What type of eye protection should the employees use, or do they have to keep changing? And how will they know?
Subpart I of the General Industry Standards covers the use of Personal Protective Equipment (PPE). Selection and use of PPE can sometimes be confusing because of the numbers of each type of equipment. There are multiple classes of hard hats, and they are available in plastic, fiberglass, or metal. You can have safety shoes, boots, metatarsal covers. Gloves come in more than 10 different materials, several thicknesses, and several lengths.
Do your employees need safety glasses, goggles, or faceshields? Here's how to make sense out of the PPE necessity. (For the purposes of this article, I am going to use eye protective equipment as my primary PPE example. Keep in mind that these same principles apply to other types of protective equipment.) Here's how you can end the confusion and take the ambiguity away from the worker; away from a capricious OSHA inspector; and put the control back into your hands as the safety professional.
You can set the standards for protection. OSHA inspectors will be the first people to tell you OSHA standards are the minimum you have to comply with, and if your company develops its own standards that are more restrictive that OSHA's, then it is your standards, not OSHA's, that must be followed.
Here's what you can do . . . .
The Hazard Assessment
First, do a hazard assessment as described in 29 CFR 1910.132 and Appendix B to Subpart I.
(d) (1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:
(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;
(ii) Communicate selection decisions to each affected employee; and
(iii) Select PPE that properly fits each affected employee.
Next, use the results of that hazard assessment to determine what the appropriate PPE should be, based on sound safety principles. This may require that you read the Material Safety Data Sheets from several manufacturers to see what they recommend. If all of the MSDSs agree on the same type of eye protection, then your job is easy: Use what they recommend. If, however, they don't all agree or if your workers use several different chemicals that require different types of eye protection, then you need to set the standard.
Setting the standard means that you write up a company procedure that describes every situation and how it is to be handled. This, then, becomes the standard your company has to follow. If OSHA comes to investigate, show them how your standard provides better protection than the OSHA standard and they will then inspect your facility using your standard as their criteria. "However, the employer will need to show that a particular [OSHA] safety or health standard is inadequate to protect his workers against the specific hazard it is intended to address."
Here's an example of a procedure on eye protection
(1) Eye Protection Types
a. ANSI Z-87.1 approved spectacles (safety glasses) with side shields.
b. ANSI Z-87.1 approved goggles.
c. Impact resistant faceshield--note: spectacles with side shields or goggles must be worn under the faceshield.
a. When handling test tubes or petri dishes, safety glasses with side shields are to be used.
b. When handling any liquid chemicals other than acids or liquid alkali, any of the following can be used:
i. Fully enclosed goggles
ii. Full faceshield with either goggles or spectacles with side shields.
c. When handling acids or liquid alkalis, a full faceshield with spectacles is required.
d. In the Fabrication Department, a full faceshield and goggles.
e. Visitors in all departments who are only passing through and will stay within the yellow-lined walkway are required to wear spectacles with side shields. If they leave the walkway, they are required to use the same level of eye protection as the workers in that area.
a. All eye protection is to be inspected at the beginning of each shift.
b. Cleaning supplies for lenses are available at the entrance to each work area.
c. Additional supplies can be requisitioned from the supply room in the main building.
d. Request form for new prescription safety glasses should be sent to the safety officer.
(4) Disciplinary Action
a. Any employee failing to wear the appropriate eye protection will be subject to progressive disciplinary action up to and including termination.
b. Supervisors and manager are responsible for ensuring compliance within their departments.
c. The Human Resources Department will handle all disciplinary action.
To complete your analysis, you will need to train your employees in the proper use of the PPE they will be using. It is very easy to show an employee how to wear spectacles correctly, how to inspect them, and how to clean them. But for people who do not wear spectacles on a regular basis, you may need to motivate them. Here's one suggestion from Mike Kubeck, safety supervisor at Pelco, Inc. in Clovis, Calif.:
"Before class, set up these props. Start with two watermelons and some raw eggs. The watermelons had a slice taken off the bottom so they would sit up straight without rolling around.
"Draw a face on each one. Where the eyes are supposed to be, cut out holes in the watermelons and carefully fit raw eggs (in the shells, of course) into the watermelons for eyes. Paint the ends of the eggs to look like eyeballs.
"Fit one with a pair of safety glasses over the eyes (eggs) and leave the other one without safety glasses. Cover both with paper bags.
"Introduce the topic and remove the paper bags from the watermelons. Your group will probably have a very good laugh at the watermelon faces. Take a wood pointer and hit the watermelon face (without the safety glasses) in the eye, while you say, 'This is what happens to your eyes without safety glasses.' With the eggs shattered, fresh, raw egg yolks and egg whites will drip from the 'eyeballs.' If your group was like mine, the group that was just laughing immediately becomes totally quiet.
"To show that eye protection works, hit the watermelon face (wearing safety glasses) in the 'eyes' and say, 'This is your eyes with safety glasses.' Of course, the 'eyes' did not break because the watermelon face was wearing safety glasses!!"
Mike told me, "I think my props were effective because the group was still silent, not a peep, not a word from them as they sat there. I thanked them for their attention and they quietly left the room."
In this article I have used eye protection to illustrate the use of hazard assessments and the development of company policies to protect workers. You should develop your company's policies to cover the necessary PPE for your operations and use creative techniques such as Mike's to drive home your point.
This article originally appeared in the October 2004 issue of Occupational Health & Safety.