Performing the PPE Hazard Analysis

Select PPE only after the first four options in the hierarchy of controls have been evaluated and found to be infeasible.

THOUSANDS of people are blinded each year from work-related eye injuries that could have been prevented with the proper selection and use of eye and face protection. Eye injuries alone cost more than $300 million per year in lost production time, medical expenses, and worker's compensation. (Source: Occupational Safety and Health Administration).

Failure to adequately assess the workplace for potential hazards and identify appropriate personal protective equipment (PPE) not only results in thousands of eye injuries each year; it is also responsible for numerous injuries to the hands and arms, torso, feet, and head.

PPE Hazard Assessment
To ensure employees wear appropriate PPE for their work tasks, OSHA's 29 CFR 1910.132 (d)(1) requires that employers perform a PPE assessment to determine whether hazards are present, or likely to be present, that necessitate the use of personal protective equipment. In addition, 29 CFR 1910.132 (d)(2) requires a written certification of the assessment.

Hierarchy of Controls
A systematic review of each work task is needed to identify potential hazards. Prior to requiring employees to wear PPE, however, the hierarchy of controls should be utilized to eliminate or reduce the existing hazard(s) to avoid the need for PPE. The hierarchy of controls states that hazards should be controlled in this preference:

1. Elimination
2. Substitution
3. Engineering Controls
4. Administrative Controls
5. Personal Protective Equipment

PPE should be selected only after the first four options have been evaluated and found to be infeasible.

Personal Protective Equipment for Various Exposures
Once the hazard assessment is complete, appropriate PPE must be selected. Listed below is a summary of typical PPE for various work tasks based upon National Safety Council, OSHA, and ANSI requirements and recommendations.

Work Task

Typical Personal Protective Equipment

Wire brush wheels

Safety glasses with side shields or impact goggles

Grinding stones

Faceshield with either safety glasses and side shields or impact goggles

Metalworking machines

Safety glasses with side shields or impact goggles, barrier creams

Compressed air

Impact goggles or safety glasses with side shields

Woodworking machines

Abdominal guard or anti-kickback apron, impact goggles or safety glasses with side shields

Handling wood, metal, glass, etc.

Kevlar, leather gloves, or hand pads

Landscaping tools

Safety glasses with side shields


Breast pockets sewn closed or removed, tool belt with tools on side, gloves, safety harness and lanyard, impact goggles, or safety glasses with side shields

Material handling

Gloves, hard hat, eye protection

Cold weather

Hard hat liners

Close quarters work

Hard hats

Falling objects

Hard hats

Sparks, hot metals

Flame-resistant caps, aprons, hoods, Nomex® canvas spats

Long hair protection

Cool lightweight cap with long visor (hair under cap), and hair nets

Acids, alkalis, etc.--splash hazard

Large quantities: Acid suits, hoods. Small quantities: Faceshield and splash-proof goggles

Limited direct splash from acids, alkalis, etc.

Faceshield and chemical goggles

Lifting 15-pound solid objects 1 foot or more at least once per day; rolling rolls of paper, steel, hogsheads

Toe protection

Chain saws

Chaps, eye protection, hearing protection, hard hats

Working in vicinity of flammable liquids handled at > autoignition temperature

Flame-retardant clothing

Sun exposure

Wide-brim hats, long-sleeve clothing and/or sunscreen

Working on energized electrical conductors > 50 volts

Flame-retardant clothing and voltage-rated tools and gloves, based upon NFPA 70E flash hazard analysis and OSHA 1910.335 requirements

Who Pays for PPE?
During training classes, I am routinely asked whether OSHA requires employers to pay for employee PPE. In an OSHA letter of Interpretation dated August 25, 2004, addressed to Brad Milleson of the Kellogg Company, OSHA states the following: "29 CFR 1910.132 requires employers to provide PPE and ensure its use. However, at the present time, OSHA does not view this section as imposing an enforceable obligation on employers to pay for PPE. Therefore, employees must be afforded the protection of PPE, regardless of who pays." OSHA has initiated rulemaking proceedings to clarify who is required to pay for required PPE.

It is important to note that there are numerous OSHA standards that specifically require the employer to provide PPE at no cost to the employee. Those standards include: Occupational Noise Exposure (1910.95); Respiratory Protection (1910.134); Permit-Required Confined Spaces (1910.146); Fire Brigades (1910.156); Logging Operations (1910.266); Asbestos (1910.1001); Inorganic Arsenic (1910.1018); Lead (1910.1025); Cadmium (1910.1027); Benzene (1910.1028); Bloodborne Pathogens (1910.1030); 1,2-dibromo-3-chloropropane (1910.1044); Acrylonitrile (1910.1045); Ethylene Oxide (1910.1047); Formaldehyde (1910.1048); Methylenedianiline (1910.1050); 1,3-Butadiene (1910.1051); and Methylene Chloride (1910.1052).

Apparel Policy
An apparel policy should be included in the PPE procedure. Loose clothing should be prohibited around rotating equipment, and long hair should be tucked under the collar or secured with a hair net. Rings, necklaces, and gloves should not be worn while working around rotating equipment because they may become entangled in the equipment.

Used properly, PPE provides a significant increase in protection for employees. The key components include a documented hazard assessment, employee training as well as periodic inspections to verify program effectiveness.

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

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

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