OSHA Seeks to Update Personal Protective Equipment Standards

ON May 17, OSHA proposed to make its personal protective equipment (PPE) standards perpetually current, a simple step that might well work -- but only if those who routinely challenge the agency's standards accept or at least learn from the D.C. Circuit Court of Appeals' May 11 decision upholding recognition of the threshold limit values.

Changing from updating them by adopting each specific new consensus standard in place of an old one, which freezes the mandatory standard at that point in time, OSHA said it wants to add a requirement that PPE be constructed "in accordance with good design standards." Whether genius or madness, this approach recognizes the reality of rulemaking: "Despite its best efforts, OSHA cannot propose and finalize its standards as frequently as the consensus standards development organizations (SDOs)," OSHA said in a May 17 rulemaking notice. "Some consensus standards are updated every three to five years; OSHA simply does not have the resources to engage in full rulemaking at this frequency for all of its PPE standards."

A section of the notice titled "The Provisions of the Proposal" spells out the agency's thinking: "The crux of the proposed revision is the requirement that the PPE be constructed in accordance with good design standards. Eye and face, head, and foot PPE are commonly worn in general industry, shipyard employment, longshoring and marine terminals. The PPE must be strong enough to protect employees from the hazards they face in the workplace. It also must be constructed and tested in accordance with sound and accepted principles that will ensure the safety of employees.

"An inherent part of any good design standard is a testing protocol for ensuring that the manufactured equipment will provide a specified level of protection. Accordingly, the requirement that the PPE be constructed in accordance with good design standards includes the requirement that the PPE be tested in accordance with a testing protocol that is designed to ensure that the PPE provides the level of protection the good design standard is intended to achieve," the agency said.

The notice then states OSHA has examined American National Standards Institute (ANSI) and ASTM International standards for these PPE types for the past 40 years. "OSHA has found that these standards reflect the state of the art in terms of design safety that existed at the time they were issued. Furthermore, each successive edition of these standards has improved the design features of the PPE. For example, a comparison between the 1989 and 2003 versions of the ANSI standard for protective eye and face equipment shows that ANSI has strengthened the impact resistance requirements of the standard. Similarly, the current ASTM International standard for footwear improves on prior ANSI standards for footwear by increasing protection against electrical hazards."

The agency stated that by replacing the existing PPE provisions with performance requirements, the proposal would "facilitate employer efforts to improve the safety and health of employees by providing state-of-the-art PPE. In addition, the proposal does not add any compliance burdens on employers."

According to the agency, these proposed revisions are a continuation of OSHA's effort to update references to specific consensus and industry standards located throughout the agency's standards, an initiative discussed in a previous Federal Register notice (69 FR 68283). That notice, published on Nov. 24, 2004, can be accessed at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=18260.

Comments by July 16. Information on how to submit comments can be found in the May 17 Federal Register at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=19573.

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