When PPE Isn’t Enough: Rethinking Chemical Safety Through the Hierarchy of Controls

A hands-on assessment of hazardous chemical handling reveals how overreliance on PPE can introduce new risks—and why engineering controls and worker engagement are critical to safer outcomes.

• By Brittney Vetter, GSP
• Jun 18, 2026

I’ve been working with a client recently on safety and industrial hygiene assessments and improvements for a process that involves handling some pretty hazardous chemicals. It’s an older process that involves manual handling of drums, as well as weighing and adding chemicals to process tanks using buckets. While some engineering controls are in place, there is a heavy reliance on personal protective equipment for chemical handling.

This experience reinforced the value of the hierarchy of controls. In this situation, the chemical protective PPE created heat stress concerns in the summer. Worker acceptance and compliance is a challenge with bulky and uncomfortable PPE that makes their job harder. This is particularly noticeable with experienced workers who may become complacent around chemicals that should normally instill a little fear and/or respect.

Selecting the right level of PPE for these tasks can be challenging. While worker protection is always a priority, every layer of PPE for chemical protection can create other risks. Respirators affect visibility and communication. Gloves can affect dexterity and grip. Chemical protective suits become uncomfortably sweaty quickly and eliminate evaporative cooling, increasing the risk of heat stress.

Health and safety management systems such as ISO 45001 and OSHA VPP emphasize the importance of employee involvement. Getting input from workers on this process has helped with adjustments to the level of PPE, balancing the chemical and other risks with the demands of the job. Involvement has also improved understanding of the risks and the need for PPE among both new and experienced workers, and compliance with both.

PPE will be an ongoing challenge and will create unwanted risks in this chemical-handling task. This takes time and effort for workers, supervisors, and health and safety staff.

One of the key lessons from behavioral safety is that people learn and make decisions based on repeated outcomes, drawing conclusions from both their own experiences and the behavior of others around them. For example, if most of the time I don’t get splashed with a chemical, but every time I wear PPE it is hot, uncomfortable, and makes my job harder, then there is a lot of negative reinforcement in wearing it, and positive reinforcement for short-cutting PPE. Over time, the absence of incidents can create a misperception that the hazard is less than it really is. If hazards are perceived as low risk, PPE is less likely to be valued or used consistently. It makes sense that PPE would not be as reliable as engineering and other controls.

It's crucial that operators are trained and aware of their environment. If operators are unaware of the hazards of the chemicals they are working around, it can lead to misperceptions of those hazards and complacency about wearing proper PPE.

It’s also important that information shared with operators does not fear monger, because that can lead to a whole new set of issues. It can be easy to lose credibility with workers by overstating hazards or having impractical requirements. Operators should be included throughout the process, and a PPE plan should be created. It’s beneficial to know how operators perceive chemical hazards and why they have that perception. Understanding and showing care is not only important for this application of chemical safety, but for health and safety in general.

Hierarchy of Controls

Those are some of the reasons why, in this situation, I immediately referred to the Hierarchy of Controls to improve the hazardous chemical handling process.

The Hierarchy of Controls is defined by OSHA as “a method of identifying and ranking safeguards to protect workers from hazards.” The hierarchy of controls is ranked most to least effective, the most effective control being elimination and the least effective control being PPE. The best results for worker protection for high hazards or complex situations are often when control methods are combined. This could be a combination of engineering and administrative controls along with PPE.

Elimination of hazardous chemicals was not an option. Specific chemistry was needed in the process. However, handling the chemicals as a prepared solution from the supplier (rather than mixing concentrated powders onsite) reduced risk by lowering the potential for exposure. This is a situation, input from the process engineers, quality and operations were all important to find safety improvements that met operational requirements. It’s much easier and more cost effective when developing a process to make these kinds of decisions.

The next step in the hierarchy of controls is engineering controls, including how to handle these hazardous liquids. Can we have a closed process, how do we transfer the material, is local exhaust ventilation needed? If we can reduce the potential for contact and exposure, we can reduce risk, even if we may still need PPE. Can we select equipment that is easier to clean and maintain? In this case, hose connections were added to tanks to reduce the need to manually handle the chemical hoses during transfers.

In reviewing administrative controls, we wanted to make sure our procedures were practical and reliable. This is when worker input is important. Confusion, or what is perceived as impractical or cumbersome procedures, decreases acceptance and compliance. Worker involvement also helps build their knowledge of the hazards and reasons for controls. Maintenance should not be overlooked. We will need to maintain equipment and protect the workers doing those tasks. Emergency procedures were also addressed, including air monitoring and alarms.

Ultimately, we still needed PPE for the process. And it’s still hot and cumbersome, but an improvement from where we started, and the workers and management in the process have a better understanding of the hazards and acceptance of the controls.

Solutions From My Perspective

In this situation, I had to look at every possible risk for each different operation in the department. Some operations only posed a chemical drip hazard, while others posed a hazard of chemical reactions occurring, leading to toxic vapors emitting in the air. It might seem like an easy solution- require operators to wear the most PPE for the high hazard operations, but if there is a risk of operators passing out and potentially hitting a tank, or overflowing a tank due to their unconsciousness, the heavy PPE needed to be reassessed.

To properly assess PPE, create effective procedures, and, all in all, create a safer workplace, I collaborated with the entire team, including maintenance operators. It’s crucial to gain others' perspectives and communicate effectively with them. Effective communication can include meetings, one-on-ones, and short training sessions. I created easy to read handouts for employees, explaining why certain controls are in place. I communicated the dangers of hazardous chemicals without adding unnecessary fear. The controls and procedures that I set have a purpose, and it’s important that employees understand that.

Effective communication may be difficult due to employee pushback- there will most likely always be people who do not trust or understand why you are in their space and trying to make changes. In my experience, some people pressured me to get my job done faster so they could continue working. It’s important to hold your ground as a safety and industrial hygiene professional, especially when you are in a situation like mine and dealing with high-risk operations and hazardous chemicals. You are there to make a difference, even if it seems like you are holding others back. In this situation, the best thing that you can do is communicate and explain why you are doing what you are doing and make sure that people feel heard. When you include employees and make them feel important, that can also impact their overall attitude towards the changes.

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