Building a Robust PPE Program

Establishing a PPE program will provide guidance to the organization, visitors and the OSH professional.

• By Robert M. Ridpath
• Jan 05, 2024

OSHA’s requirements under the general duty clause state that “each employer shall furnish to each of its employees employment free from recognized hazards that are causing or are likely to cause death or serious physical harm.” It is the employers’ responsibility to understand the hazards associated with the type of work within their organization and to mitigate hazards to an acceptable level.

According to the Bureau of Labor and Statistics (BLS), employers reported 2.7 million injury and illness cases in the private industry in 2020. Occupational safety and health (OSH) professionals have the responsibility to assess and address workplace hazards and to provide a means to mitigate the hazards that are known or identified through an assessment in their organization. To mitigate hazards, OSH professionals must have a vast knowledge of codes and industry safety standards to assess and address workplace hazards and implement corrective actions.

Once the hazards have been recognized, and all other controls have been exhausted, personal protective Equipment (PPE) shall be selected as the last line of defense. The OSH professional shall select the appropriate PPE and establish a program. The purpose of a PPE program is to ensure processes and procedures are met and to ensure consistency. To have a successful PPE program, the OSH professional must establish a process that identifies management’s commitment, worker participation, hazard evaluation, hazard mitigation, training and education, program evaluation and continuous communication for the PPE program to be successful.

Hierarchy of Controls

Once the OSH professional understands the hazards with the job or task within their organization, the OSH professional shall determine a means to address the hazard before directly utilizing PPE. One methodology is to use the National Institute of Occupational Safety and Health’s (NIOSH) Hierarchy of Controls. The Hierarchy of Controls consists of five methods to help evaluate and mitigate the hazard, listed below from most effective to least effective:

• Elimination: physically remove the hazard
• Substitution: replace the hazard
• Engineering controls: isolate people from the hazard
• Adminstrative controls: change the way people work
• PPE: protect the worker with personal protective equipment

When using the Hierarchy of Controls, the OSH professional must consider various factors before selecting the appropriate method for the job or task. For example, not every method is feasible, or some methodologies may add additional hazards after implementation. 

The first step in the hierarchy of controls is the elimination process. This action focuses on an attempt to eliminate the hazard. In some cases, you may not be able to eliminate the process. Therefore, the next step must be taken to evaluate the hazard.

The second step in the Hierarchy of Controls is to substitute. Typically, substitution is the utilization of a safer alternative. When considering substitution, you must ensure that the substitution does not create new or additional hazards. An example of substitution is substituting a chemical of a lesser hazard for the employee. For instance, replacing acetone with a safer water-soluble chemical instead of a chemical with high volatile vapors that could harm the employee.

If you cannot substitute and mitigate the hazard, the third step in the process is to apply engineering controls. Engineering controls include isolating people from the hazard and reducing the likelihood of a hazard coming in contact with the worker. This is typically preferred but may not be economically feasible for the employer to implement. Some examples of engineering controls may include modification of equipment, using protective barriers and ventilation.

If elimination, substitution or engineering controls are unable to mitigate the hazard, the next step is administrative controls. Administrative controls are work practices that reduce the duration, frequency or intensity the employee is exposed to the hazard. Examples of administrative controls include job rotation, breaks and training. 

The last and final selection of the Hierarchy of Controls is PPE. PPE is considered the last line of defense in the Hierarchy of Controls and should not be used unless having evaluated all prior steps listed in the Hierarchy of Controls. There are many types of PPE, and PPE is worn to protect the worker by providing a barrier between the employee and the hazard. Examples of PPE include hard hats, safety glasses, body garments, gloves and steel-toe boots. If PPE is selected, be sure to document this selection process within your program and address how you came to utilizing PPE instead of the other items listed in the hierarchy of controls.

PPE Hazard Assessment

After selecting PPE from the Hierarchy of Controls, the first step is to develop a comprehensive PPE program that addresses how to further evaluate the hazards that are associated with the various job or tasks in your organization. This process is known as a PPE hazard assessment. A PPE hazard assessment is different from a general hazard assessment as the PPE assessment investigates further on how to protect the employee from the identified hazards with PPE. If this assessment is done right, the assessment will identify physical and health hazards employees are exposed to and address which types of PPE to protect the worker.

Physical hazards cause damage to the body, while health hazards present dangers to the employee’s overall health. Some examples of physical hazards are sharp objects, pinching and moving objects. Examples of health hazards deal with chemicals, radiation and harmful dust.

When conducting the PPE hazard assessment, OSH professionals are required by OSHA to document their assessment through written certification. The assessment shall include the person conducting the assessment and the date of the assessment. A best practice would be to generate a PPE hazard assessment template and attach the assessment to your PPE program. Various types of PPE assessments are available online and can be customized to fit your jobs and tasks. The PPE assessment template in your program will provide the OSH professional with a structured and documented process that will be consistent when assessing hazards in the future. 

To conduct a PPE hazard assessment, a walk-through of the facility for each job or task needs to be conducted and the hazards evaluated. During the walk-through, the OSH professional will need to incorporate managers, supervisors and employees to help understand the job or tasks the workers are performing. Within your program, be sure to spell out who is involved and the frequency of these assessments. Keep in mind that PPE assessments need to be conducted when a new process is being introduced, when processes change or on a periodic basis.

 The OSH professional shall then organize and evaluate the information from the assessment so that it can be used in determining the proper PPE for the hazard or hazards. To do this, the OSH professional needs to be familiar with the various types of PPE to provide the proper protection. Be sure to work with the manufacturer of the equipment during this process, as the manufacturers will know the limitations of the PPE and the level of protection the PPE is capable of providing.

Selection of PPE

PPE should be selected based on the hazards identified in the PPE assessment. An example of this would be using safety glasses during grinding operations instead of also incorporating a face shield to protect the worker’s eyes and face. All PPE clothing and equipment shall be designed, constructed and maintained to the manufacturer’s recommendations to provide adequate protection to the worker. If unsure of the level of protection the PPE can provide, contact the manufacturer. 

The OSH professional should consider various factors when selecting PPE. These factors include how well the PPE fits and if the PPE is comfortable for the user. Remember to always involve employees in the selection process. Doing so will ensure the PPE is comfortable for their job and fits the employee. After all, they are the ones wearing the PPE.

Hazards of PPE & Manufacturers Recommendations

Even though the goal of PPE is to protect the employee, worker or visitor from the hazard, wearing PPE can also result in a hazard and cause exposure of its own. Ways that this can occur includes improper storage, lack of inspection and maintenance. To ensure PPE provides adequate protection to the user, OSH professionals should review the manufacturer’s recommendations. The manufacturer of the PPE will provide the requirements for proper storage, inspection and maintenance for the type of PPE selected.

Once the OSH professional understands these requirements, incorporate them into your PPE program and train your employees to ensure the manufacturer’s requirements are being met. Once you have trained the employees on the manufacturer’s recommendations, conduct an audit to ensure these requirements are being followed.

Recommended Practices for PPE Programs

The Hierarchy of Controls should be documented within your program to ensure consistency and effectiveness when selecting PPE for your organization. To have a successful PPE program, OSHA recommends seven core elements for safety and health programs. Those seven core elements for a successful PPE program are the following:

• Management commitment
• Worker participation
• Hazard assessment and identification
• Hazard control and prevention
• Education and training
• Program evaluation and improvement
• Communication and coordination

The first core element is management commitment. When in the process of writing your PPE program, you need to start with the management’s commitment to safety and their roles and responsibilities within the PPE program. For any safety program to be effective, the PPE program needs to be evaluated periodically by management and the person managing the PPE program. Typically, the company president and the OSH professional oversee and manage the program. Having top management review the program enforces management’s commitment to safety and shows management’s commitment to safety within the organization.

The next core element is worker participation. To have an effective PPE program, workers must be involved and encouraged to participate. This can be done while conducting the assessment or discussing at safety meetings, such as program evaluations and committee meetings. When employees are involved, employees have a say in selecting the type of PPE that will protect them. This provides buy in and increases the likelihood of the PPE being worn by the employee.

After worker participation, you will want to identify and assess the workplace for hazards. Keep in mind that workplace hazards may already be available to you from internal and/or external sources. Some typically overlooked sources involve equipment manuals, safety data sheets, OSHA 300 logs and results from other PPE assessments that may have already been conducted. If PPE assessments have already been conducted, be sure to re-evaluate the job or task to ensure nothing has changed. For instance, no processes or hazards have been introduced to the job or task. Once completed, update the assessment name and date the PPE assessment was conducted.

Next, spell out the education and training that is provided to managers, supervisors, employees, workers and visitors with the knowledge and skills they need to conduct their work safely. This training shall be addressed within the program and shall spell out the roles and responsibilities of all the affected personnel that may be required to wear or manage the PPE within the organization. 

Once the program is in place, it should be evaluated initially, periodically or when processes change. The evaluation shall include what is and is not working and include appropriate personnel. Typically, the evaluation will identify any shortcomings and opportunities for improvement. Once addressed, make the corrections and document within an appendix to track all the changes you have made. This will also allow you to see if the changes within your program are effective.

The last core element is discussion and communication. The program shall be communicated to all workers, including personnel that may visit the facility. This includes contractors, suppliers, vendors, visitors and customers. Effective communication with employees and personnel visiting the facility is critical to ensure PPE is being used and employees and visitors are protected. A few best practices to communicate with visitors and/or employees include orientation for visitors and new employees, periodic training and company meetings.

Conclusion

Employers and OSH professionals have an obligation to understand the hazards and develop a process in which the hazards are recognized, evaluated and mitigated to an acceptable level. If PPE is the final selection from the Hierarchy of Controls, establishing a PPE program will provide guidance to the organization, visitors and the OSH professional. The PPE program shall define management’s commitment, hazard evaluation, hazard mitigation, training and education, program evaluation and continuous communication. Once these core elements are in place, the program will need to be evaluated on an ongoing basis to ensure any gaps within your program are mitigated. Following these processes will help the employer and the OSH professional establish an effective and robust PPE program.