Meeting the Compliance Challenge

In one case, we had start over with the supervisors and painstakingly work down to the line employees to communicate the correct message that every bit of protection helps.

It's an often invisible monster waiting for the hapless exposed worker: dust, fibers, fumes, particulates, gases, and even bloodborne pathogens exposures that workers may know about but cannot see. Or the may not understand fully the long-term health hazards. The exposure is often years before the damage is evident, as in the case of asbestos or Hepatitis B. Other factors, including personal choices such as smoking, can increase the likelihood of health problems later on.

Without a doubt, respiratory protection is one of the toughest standards to consistently enforce and to maintain compliance in the workplace. Few employees enjoy wearing respirators. They are hot, restrictive, interfere with movement, and if not cleaned/maintained/changed correctly may be worse than not wearing any at all.

Safety professionals nod knowingly when the topic of respiratory protection comes up. How do we maintain constant compliance? Every safety pro has stories of non-compliance, such as wrong respiratory protector being worn, PPE worn incorrectly or with missing pieces, incorrect maintenance or no maintenance of the PPE.

Employees who need protection either do not wear proper respiratory protection or wear it incorrectly. We see orphan respirators tossed carelessly on workbenches, hanging by stretched straps on walls, covered with a thick oily coating of dirt in shops, or missing the filtering elements that make them effective. We hear employees who sport beards say with enthusiasm that they regularly wear respiratory protection, know fully how to clean the respirators, and are in compliance. Sometimes an employee will wear a respirator without filtering elements so he can appear to be in compliance from a distance. We see N95 respirators worn by one strap instead of two or dangling stylishly around the employee’s neck. Respirators shared without cleaning.

How can we energize our employees to wear respiratory protection? I'm reminded of a crew with whom I worked in the 1980s removing asbestos from tunnels. Respirators had been issued, medical exams completed, training offered -- all of the bases were covered technically. An audit indicated fewer than one in 10 employees wore the needed PPE. Their average age was late fifties; upon questioning many of them, we discovered a root cause. A comment made during the training stated (at that time, it was common understanding) that asbestos-related illnesses took up to 15 years to develop. We all knew smoking made exposure worse. These seasoned employees made sure the younger workers (including me) wore correct PPE and ignored their own due to their age -- in order to have improved comfort, be able to smoke and drink, etc., while working. They knew the hazards but chose to avoid them, betting on the odds in a race with no winner. They felt their previous exposures had sealed their fates already.

Our solution was to start over with the supervisors and work down to the line employees, using a combination of reassurance, training, enforcement, daily (or more frequent) audits, and a lot of one-on-one interaction to get the correct message to the employees that every bit of protection helps.

Many workplaces have similar situations. Respirators are not worn when they're needed, they're not adequately stored, or maintained, or cleaned. The smaller and more remote the work site and crew, the worse the situation may become. Employees simply get lazy.

How do we improve compliance? Try shaking it up! Unfortunately, there is no single all-purpose answer. Each site will respond to different combinations of answers that may include:

Shake up the supervisors/department managers. Make sure the supervisors and upper department managers know they are being scrutinized for compliance and tie their bonus/promotions to safe work behavior. All too often, employees mirror the attitude and opinions of supervisors and follow their responses to PPE.

Ensure that supervisors encourage adherence to policy and are adequately trained on use, limitations of all respiratory PPE, and the hazards against which they protect employees. Use disciplinary action as needed to force compliance until the new training takes hold with employees. Encourage to the extent possible, and then enforce through disciplinary action, starting with supervisors.

Shake up training and awareness campaigns. Try a different method. If you are using classroom training, try toolbox meetings in the work area. Use smaller groups, present leadership training from your supervisors, or try incentives (such as raffles).

Employ equipment selection committees, focus groups for problem solving, posters, computerized training kiosks, interns from local colleges to pump up the training. Cross-train employees in different hazards/PPE types. Share useful Web sites. You know your employee base; use what works but keep the message fresh so they do not perceive it as the "same ol' same ol' stuff as before."

Monitor purchasing. Keep up with the bean counters and monitor every dime spent in trouble areas. If replacement PPE or parts have not been ordered in years, ask why. If the wrong PPE is being purchased to save money, find out who approved this. (Accounting sometimes selects/purchases PPE and tries to save pennies on unknown situations.)

Increase audits and inspections. Assess the work site and the need for respiratory protection and suggest options. You could change the chemicals being used, increase ventilation, remove outdated processes, or substitute better equipment to reduce the need for respiratory protection.

Talk to your employees and not just the management. Blind surveys, suggestion boxes for improvements, and roundtable discussions can make a positive difference. Use what works and keep trying. If time is an issue (it always is), put a note to follow up in your calendar or pin file.

Follow the standards yourself. Ensure employees who request from you or are fitted with respirators have the correct medical surveillance and training. I'm often asked to purchase PPE for employees not previously approved for respiratory protection or medical surveillance. Explain why you cannot legally fit them and discuss the hazards they perceive being exposed to and possible alternatives. (N95s for last fall's flu panic come to mind.) Document your decision, then send it back through the supervisory channels.

It is one more thing on your long list and, face it -- it's work. Monitoring respiratory protection selection, use, and non-use are draining work for most of us who are already stressed to the max. It may be easier to let it slide and hope for the best until something really bad happens. As Safety in our "what if" world, however, we have to be proactive, stay ahead of the hazards, and protect our workers to the fullest extent possible (including from themselves and their bad choices).

If you prevent one debilitating injury, it is worth all of the time and effort. Safety is truly compassionate service. We professionals have to make sure others benefit from our expertise as much as we can.

This article originally appeared in the July 2010 issue of Occupational Health & Safety.

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