Headline: Hazard Assessment

The person who conducts it must have an intimate knowledge of each task and should directly observe the employees.

HOW to prevent eye, face, and head injuries isn't a mystery. But knowing how to protect yourself or your workers does take some analysis, attention, effort, and money. Wearing inadequate protection or none at all is not an alternative if the hazards involved in a given task cannot be eliminated, engineered out, or solved through administrative controls.

Because these preferred strategies in the hierarchy of controls are not tried or would not be effective in many cases, eye, face, and head protective products are required in all sorts of workplaces. Proper training is still necessary. And you begin the process of selecting and using these items of PPE by making a comprehensive assessment of eye and face hazards and assigning proper PPE to each one. Then, you have to require that the appropriate PPE is worn by exposed workers, that they wear it as they should, and that no one--no visitors, temps, inspectors, supervisors, consultants, delivery personnel, security guards, or anyone else--enters a hazardous area unless he or she is wearing that PPE.

Your disciplinary policy must be the enforcer that backs up your PPE policy.

Conducting the Hazard Assessment
A hazard assessment is simply the investigation of a task and the hazards and potential hazards associated with it. Doing this right allows you to choose spectacles, sideshields, goggles, faceshields, hard hats, and other head and face PPE that will be effective.

You can conduct a hazard assessment for one employee who performs a single task or groups of employees who perform the same task, such as welders who are exposed to ultraviolet radiation during one type of welding or laboratory workers who are exposed to chemical splashes. The person who conducts the hazard assessment must have an intimate knowledge of each task and should directly observe the employee(s), looking for these potential hazard sources:

  • High temperatures that could result in burns, eye injury, ignition of equipment, etc.
  • Chemical exposure, including airborne or skin contact that would have the potential for splash on the skin or eyes
  • Harmful dust or particulates
  • Light radiation from welding, cutting, brazing, furnaces, heat treating, high-intensity lights, etc.
  • Sources of falling objects and the potential for dropped objects
  • The potential for collision with other personnel or objects because of the layout of the workplace and the locations of co-workers
  • Any other potential hazard.

Where present, these should be noted on a hazard assessment form and/or checklist that is tailored to this facility. MSHA, for one, suggests constructing a risk matrix that rates each hazard as high, medium, or low based on probability and severity. Supervisors should use these forms to re-evaluate the hazards on a regular basis, noting anything that has changed in terms of processes, staffing, materials used, line speeds (if applicable), lighting, clutter, signage, and more.

Training
OSHA has pointed out that employers should be mindful that multiple and simultaneous exposures to various hazards are possible. Workers should be cautioned, too, that PPE does not provide absolute protection from hazards.

Along with the hazard assessment is an obligation to train employees who are exposed to the hazards. Do they understand what protective gear to wear, why it must be worn, and also how to adjust it properly? Do they know how to inspect PPE for damage and wear, and how to obtain replacement PPE when necessary? Is their use of PPE enforced, and is all PPE kept sanitary and inspected before use? Finally, are eyewash facilities and drench showers within work areas where employees are exposed to corrosive materials?

New and Existing OSHA Standards
General Industry eye and face protection standards enforced by OSHA (or not mandatory, in the case of appendices) include 1910.132, the main personal protective equipment standard; 1910.133, Eye and Face Protection; and 1910.252(b)(2), the eye protection section within the Welding, Cutting, and Brazing standard.

OSHA addressed eye protection in its June 15, 2005, proposed revision of the 1910 and 1926 standards governing safe maintenance and repair of electrical generation, transmission, and distribution lines. "To protect employees from contacting energized parts, paragraph (h) of proposed Sec. 1926.960 would require fuses to be installed and removed using insulated tools or gloves when a terminal is energized at over 300 volts or when live parts are exposed at any voltage over 50 volts," OSHA explained in the proposed rule. "When an expulsion fuse operates on a fault or overload, the arc from the fault current erodes the tube of the fuse holder. This produces a gas that blasts the arc out through the fuse tube vent or vents, and with it any loose material in the way. Employees could be injured by the arc blast or by particles blown, by the blast, in their eyes. Employees should never install or remove such fuses using gloves alone. Therefore, paragraph (h) would also require employees installing expulsion-type fuses energized at 300 volts or more to wear eye protection, would have to use a tool rated for the voltage, and would have to stand clear of the fuse's exhaust path. This paragraph, which has no counterpart in existing Subpart V, has been taken from Sec. 1910.269(l)(7)."

Interestingly, the proposed rule's 1926.951 section, Medical Services and First Aid, specifies cardiopulmonary resuscitation training. It will preserve the existing provisions (in 1926.50) for available medical personnel, first aid training and supplies, and drench showers or eyewash facilities for flushing workers' eyes and body after exposure to corrosive materials. The rule would apply when employees perform work on or associated with exposed lines or equipment energized at 50 volts or more, with OSHA proposing to require that employees with first aid and CPR training be available to render assistance in an emergency. CPR training would be required for field crews of two or more employees and for fixed work sites, which would have to station enough trained employees to provide assistance within four minutes.

OSHA chose 50 volts as "a widely recognized threshold for hazardous electric shock," and 50 volts is recognized by other OSHA standards and the National Electrical Code. The agency sought comments on whether the revised standard should require employers to provide AEDs and where they should be required.

The agency's relevant construction standards are 1926.102, Eye and Face Protection; and 1926.95, Criteria for Personal Protective Equipment.


2005 Head & Face Protection Checklist

Yes

No

Has your facility been evaluated for potential hazards requiring hard hats, goggles, eyewear, or faceshields?

Yes

No

Are areas requiring head and face protection marked off limits to unauthorized personnel or employees without proper PPE? Is this policy strictly enforced?

Yes

No

Do employees understand the signs and barriers used to prevent unauthorized entry when they are not wearing the proper PPE?

Yes

No

Do employees perform entries for inspection, maintenance, repair, cleanup, or similar tasks where particles could fall into their eyes?

Yes

No

Are they going into cramped locations where bumps on the head could occur on pipes, nails, and other protrusions?

Yes

No

Do tasks and processes at your facility require the use, transfer, or cleanup of chemicals?

Yes

No

If so, do you have a comprehensive PPE program for employees' protection for chemical and physical hazards?

Yes

No

Are biological exposures from splashes or spills possible on your site?

Yes

No

Are employees handling or performing entries involving storage or use of hazardous or corrosive solid granular products?

Yes

No

Are appropriate eyewash facilities available (as required by the ANSI standard) for their immediate use if needed?

Yes

No

Are all eyewash facilities labeled as to their purpose and how to use them? Are they tested and kept clean for use at all times?

Yes

No

Are on-site rescue personnel equipped with complete first aid supplies and given special instructions for head injuries, such as deep puncture wounds?

Yes

No

Do you conduct rescue planning and training, including of part-time or temporary staffers?

Yes

No

Are appropriate hard hats used in any area in which there is a potential hazard from falling, flying, or slung objects?

Yes

No

Are faceshields provided in addition to protective eyewear, not instead of it?

Yes

No

Is all head and face PPE inspected before it is given to the employees?

This checklist was compiled by Linda F. Johnson, a former technical editor of Occupational Health & Safety. It is not intended as a substitute for a comprehensive safety program.

This article appeared in the November 2005 issue of Occupational Health & Safety.

This article originally appeared in the November 2005 issue of Occupational Health & Safety.

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