Safe Workplace and Safety News

OSHA announced yesterday in the Aug. 19 Federal Register that it is accepting public comments on a Notice of Proposed Rulemaking (NPRM) on Personal Protective Equipment (PPE) and training standards. The proposal clarifies that when an OSHA standard requires an employer to provide PPE, such as respirators, or training to employees, the employer must do so for each employee subject to the requirement. Each employee not protected may be considered a separate violation for penalty purposes.

"We want employers to understand the importance of complying with OSHA’s PPE rule for each and every one of their employees," said Assistant Secretary of Labor for OSHA Edwin G. Foulke, Jr. "Without question, providing PPE for all employees will reduce costs, save money and, most importantly, save lives."

The proposed rule affects OSHA’s general industry, construction, and maritime standards. In many cases, OSHA combines separate violations of a single requirement in a standard into a single penalty. However, under the instance-by-instance penalty policy, OSHA may propose a separate penalty for each specific violation where the employer demonstrates a flagrant disregard for safety and health.

The proposed rule makes clear that failure to provide appropriate PPE or training may result in per-instance penalties in appropriate cases. The proposed rule does not add new compliance obligations, nor are employers required to provide any new type of PPE or training. The amendments merely clarify that a separate penalty may be assessed for each employee not provided the required PPE or training.

The agency will accept public comments on the proposed rule until Sept. 18. Interested parties may submit comments electronically at http://www.regulations.gov, the Federal eRulemaking Portal; by sending three copies to the OSHA Docket Office, U.S. Department of Labor, Room N-2625, 200 Constitution Avenue, NW, Room N-2625, Washington, DC 20210; or by FAX at (202) 693-1678 if the comments and attachments do not exceed 10 pages. Comments must include the Agency name and Docket Number for this rulemaking (Docket No. OSHA-2008-0031).

Labels: OSHA, PPE, safety regulations, Safety Training

Safety Online reports that, according to a survey taken at the 2007 National Safety Council (NSC) Congress, noncompliance with PPE requirements is the #1 safety issue in the workplace. The article reports that 87% of those who responded to the survey report having "observed workers failing to wear PPE when they should have been." This is statistically the same as it was in 2006 when the survey found 85% answered yes to this same question. The survey also asked why people did not comply with PPE requirements. The answer is that it is an issue of comfort and style. The article states:

"So it's not surprising that when asked 'what' could be improved about the PPE they were currently purchasing, three quarters of survey respondents said they would make it "more comfortable." Safety professionals also gave the nod to more fashionable PPE. Eighty-four percent said that they would be more apt to purchase fashionable and attractive PPE if workers would be more likely to wear it and the price was comparable to what they were currently paying for similar products."

For more information read the entire article at:
http://www.safetyonline.com/content/news/article.asp?docid=a9441b5b-0008-48a3-8c71-79ae2c948182

Labels: PPE

The U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) yesterday announced a final rule on employer-paid personal protective equipment (PPE). Under the rule, all PPE, with a few exceptions, will be provided at no cost to the employee. OSHA anticipates that this rule will have substantial safety benefits that will result in more than 21,000 fewer occupational injuries per year. The rule will be published in the Federal Register on November 15, 2007.

"Employees exposed to safety and health hazards may need to wear personal protective equipment to be protected from injury, illness and death caused by exposure to those hazards," said Assistant Secretary of Labor for OSHA Edwin G. Foulke Jr. "This final rule will clarify who is responsible for paying for PPE, which OSHA anticipates will lead to greater compliance and potential avoidance of thousands of workplace injuries each year."

The final rule contains a few exceptions for ordinary safety-toed footwear, ordinary prescription safety eyewear, logging boots, and ordinary clothing and weather-related gear. The final rule also clarifies OSHA's requirements regarding payment for employee-owned PPE and replacement PPE. While these clarifications have added several paragraphs to the regulatory text, the final rule provides employees no less protection than they would have received under the 1999 proposed standard.

The rule also provides an enforcement deadline of six months from the date of publication to allow employers time to change their existing PPE payment policies to accommodate the final rule.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA's role is to assure the safety and health of America's working men and women by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual process improvement in workplace safety and health. For more information, visit www.osha.gov.

Labels: PPE

A growing safety issue is that of arc flash protection and determining the proper PPE. An article in Maintenance Technology magazine addresses this topic. The problem is that PPE requirements are based on tests that may not be reflecting real-life situations. The article states:

"Recent research into arc flash phenomena, however, indicates that workers could be under-protected against the heat generated during an arc flash event. Test results presented at IEEE conferences and at the 2007 IEEE Electrical Safety Workshop show that different configurations of electrodes (conductors) yielded heat energy higher than current predictions due to the directional nature of the arc development. Additionally, initial tests of PPE, when placed within this directional plasma fl ow, did not provide the level of thermal protection predicted by its APTV."

You can read the article at: http://www.mt-online.com/articles/0507_electricalsafety.cfm

Labels: Arc Flash, Electrical Hazards, PPE

Kimberly-Clark Professional has an online Safety Knowledge Network that provides free access to safety related information and white papers. Accessing some of the white papers requires going through a quick registration process, following which you have immediate access to the white paper.

Topics covered include:

• Eyewear Technical Guide


• Evaluating Chemical Splash Protection


• Chemical Barrier Performance & Protective Apparel Selection


• Safety Doesn't Cost: It Pays


• Katrina Clean-up Crews Threatened by Lack of Personal Protective Apparel


• Protecting Workers From Bloodborne Pathogens


• How To Select The Right Protective Clothing For The Job


• Interactive Chemical Selector Tool

I've included a link on the first topic, protective eyewear, because this is an excellent paper providing information covering everything a safety professional needs to know about protective eyewear. This paper is freely available, so it provides an example of the quality of these resources without having to register.

Labels: Industrial Safety, PPE

Occupational Health and Safety Magazine reports that: "OSHA has scheduled a December 4th informal public hearing in Washington, D.C., about its proposal to steadily update some PPE standards according to changes in 'good design standards.'"

Anyone wishing to testify at this public hearing must file a written notice by October 1st.

Labels: OSHA, PPE

A new International Safety Equipment Association (ISEA) draft standard for chemical protective clothing has begun the consensus review process, and is now available for public review and comment (see comments). Draft ANSI/ISEA 103-200x is designed to help users select the appropriate protective apparel for a variety of chemical hazards, providing minimum performance classifications and labeling requirements.

Members of ISEA Protective Apparel Group developed this standard to present a testing philosophy based on garment category and performance level. This approach was modeled after activities ongoing within the European (CEN) and international (ISO) standards communities, and represents one of the first attempts at harmonizing testing and labeling of chemical protective clothing worldwide. Garment categories (e.g., US Category 1, gas-tight) are defined by matching the expected chemical exposure scenario with various material swatch and finished garment item test requirements. This standard uses multiple performance levels (e.g., three levels of performance for permeation testing) for the majority of properties. Thus the standard will provide the end-user with a tool that helps define adequate protection by matching a unique exposure scenario to a specific garment configuration (category) and a minimum level of performance (level).

According to ISEA technical director Janice Comer Bradley, CSP, "This standard will fill a gap in that's existed since OSHA issued its regulations for personal protective equipment." OSHA requires employers to conduct documented hazard assessments in the workplace, and select personal protective equipment (PPE) appropriate to the hazard. "Although OSHA provides references to performance-based standards for certain types of PPE such as eye and face protection, until now there has been no consensus standard for the majority of chemical protective clothing worn by the US workforce," Bradley said.

The ANSI/ISEA 103 standard is applicable to the vast majority of chemical protective clothing used within industry including, but not limited to, the following applications: agricultural, chemical processing, hazardous materials redemption, pharmaceuticals operations, paint spraying, tank cleaning, laboratory operations, cleanroom operations, petrochemical operations, waste collection/recycling, general manufacturing, bulk chemical transfer/handling operations, general maintenance and clean-up, etc. It would not apply to hazardous materials or emergency response operations covered by National Fire Protection Association (NFPA) standards.

To obtain a review copy of the draft standard contact Cristine Fargo, ISEA manager of standards programs. There is a $30 charge, payable by check or credit card.

Labels: PPE

The International Safety Equipment Association (ISEA) has challenged a U.S. Occupational Safety and Health Administration (OSHA) proposed rule to regulate the use of safety eyewear and hard hats, and offered an alternative approach that ISEA says would maintain worker protection.

In comments submitted July 16, ISEA said OSHA's May 17th proposal to change the way it recognizes product performance standards for personal protective equipment (PPE) could potentially reduce the level of protection for workers and make compliance with the rule more difficult for employers.

Current OSHA regulations require that eye and head protection devices meet product performance standards issued under the banner of the American National Standards Institute (ANSI). ANSI standards are voluntary, but they are widely accepted in the United States and are recognized by OSHA and numerous other regulatory agencies.

OSHA adopts specific product performance standards. Those standards may go through several revisions before OSHA is able to update its rules to incorporate the newer versions. Under the OSHA proposal, however, references to these standards would be replaced with a requirement that PPE meet “good design standards,” an approach that ISEA says offers no assurance of a minimum level of protection.

ISEA’s alternative would maintain the reference to the current version of the standard, and include a method by which OSHA could evaluate standards that offer equivalent protection and allow employers to use products meeting those standards.

This approach “maintains the level of performance of PPE that meets the consensus standard in the current regulation, so that worker protection is not compromised,” according to the ISEA submission. It gives employers the flexibility to select PPE that best meets their workers’ needs, based on hazard assessment. And it gives OSHA the flexibility to update references to consensus standards when they are revised, and add new product standards as they are issued without a lengthy and laborious regulatory process.

“We fully appreciate what OSHA is trying to do in this rulemaking,” said ISEA President Dan Shipp. “They aren’t able to keep up with revisions to the product standards they reference in their regulations, and they’re searching for a way to keep the rules current without having to go through a full rulemaking every few years for each standard.

“But to take those references out of the regulation, and replace them with the requirement that PPE comply with some vaguely defined good design standard shows a lack of understanding of the role of performance standards and their use in regulation.”

In its comments, ISEA points out that there are hundreds of PPE product standards around the world that might qualify as good design standards, but that they are not equivalent to the ANSI standards that have been part of the regulation. Without the reference to a specific standard in the regulatory text, OSHA would provide no baseline performance requirements for PPE, ISEA said.

“If the rule is published the way OSHA is proposing it, the ANSI standards would still be the baseline, and OSHA would include them in an appendix as examples of what makes a good design standard,” Shipp said. “But what happens in the future?”

The proposed requirements for a good design standard are that it incorporate safety, that it is recognized as providing an adequate level of protection, and that the standards-developing organization use an open process that considers the views of a broad constituency.

“There’s nothing in this proposal that says the standards recognized in the future have to be as protective as standards recognized today,” Shipp said. “That’s why we’re trying to convince OSHA not to take the reference to a specific standard out of the regulatory text.”

ISEA asked OSHA to convene an informal public hearing to discuss all the aspects of this proposed rule.

Labels: PPE

OSHA has a guide to Personal Protective Equipment available free online.

Hazards exist in every workplace in many different forms: sharp edges, falling objects, flying sparks, chemicals, noise and a myriad of other potentially dangerous situations. Controlling a hazard at its source is the best way to protect employees. When engineering, work practices and administrative controls can’t protect employees, employers must provide personal protective equipment (PPE) to their employees and ensure its use.

PPE is equipment worn to minimize exposure to a variety of hazards.

The OSHA guide to PPE helps employers and employees do the following:
• Understand the types of Personal Protective Equipment.
• Know the basics of how to conduct a "hazard assessment" of the workplace.
• Know how to select the appropriate PPE for a variety of circumstances.
• Understand what the training that is needed for the proper use and care of PPE

You can download the OSHA guide OSHA 3151-12R - Personal Protective Equipment

Labels: PPE

A free chart, showing required PPE, is available from the Hazardous Material Labels (HazMatLabels) web site.

The chart shows hazardous material categories across the top, and lists the required PPE for each category. The bottom half of the chart has pictograms for each of the required PPE and for each PPE shows the categories that require that PPE.

This chart is available free to businesses, government agencies, non-profits, schools and the military.

Labels: Industrial Safety, PPE

Who should pay for safety gear such as gloves and safety boots? If safety gear is considered a "tool of the trade" some industries have employees pay for that safety gear. While most employers provide safety equipment such as ear plugs, safety glasses and hard hats, this is not true of all industries. In construction workers are commonly required to provide their own hard hats and in the chicken processing industry workers typically provide their own puncture proof gloves.

Unions have sued the government to implement new rules that would require employers to provide needed safety gear. Read about it on Bloomberg News. The opening paragraph of this article states:

"For almost eight years, labor unions have been waiting for the Labor Department to finish a rulemaking that would make it clear employers are supposed to pick up the tab for safety equipment for millions of workers."

The article explains:

"The controversy has a long history. When the initial protective equipment rule was issued in 1994, it said employers had to 'provide' various safety gear. But unlike a series of health-related OSHA standards, it didn't say who should pay the bill, and not every company did."

Labels: PPE, safety regulations

An article in the ISHN e-Newsletter brings out the importance of using the right gloves in winter. Not only is cold a consideration, but vibration from tools, reduced grip strength, and decreased friction all combine during winter to result in an increased safety hazard.

The article is titled: Winter Wear for Safety’s Sake - Cold weather considerations for protecting workers’ hands.

The article points out that "In order to keep the hands warm, gloves are used. Unfortunately, the wrong type of glove can reduce grip strength, and workers may use even more force to compensate for the glove’s effect. In general, the following principle applies:

'When temperatures drop, the likelihood that a previously acceptable level of powered tool use now becomes dangerous increases.'"

Labels: PPE, workplace safety

This month's issue of Occupational Health & Safety magazine has an article called "Step By Step - Overall workplace organization and work practices are often at fault when workers sustain foot injuries." by Fred Elliott

You would think that an article about foot injuries would be an article about workboots. But, as the leading paragraph points out, the problem is more commonly found in workplace organization and practices:

"Crushing, punctures, lacerations, sprains, and even aches and pains are common problems workers have with their feet. Footwear that doesn't match their hazard exposures are a leading reason for these, but overall workplace organization and work practices are often at fault."

Learn what can be done to prevent foot injuries. Many of the recommendations in this article should be part of an overall improvement effort. For example, one recommendation is that there be worker involvement. This is exactly what a Kaizen program does... Kaizen is a method for improving safety, productivity, quality, employee retention, and other areas, through continue improvements made as a result of employee suggestions.

Labels: PPE, workplace safety

The October 4th issue of Occupational Hazards magazine includes an article that not only provides a good discussion of noise control, it also provides an excellent overview of how to address safety problems in general.

The article opens by reporting that "An OSHA inspection at an Atlanta steel mill resulted in a citation for failure to reduce sound levels that could damage employees' hearing. The noise exposures for an 8-hour day were between 91 and 94 decibels (dB)."

It then looks at various ways this noise problem can be addressed, including source controls, path controls, and administrative controls.

It concludes with a summary of the benefits of hearing lose prevention: "A hearing loss prevention program is good business, and it protects employees' hearing and ability to communicate. With no cure for noise-induced hearing loss, preventing exposure is the only way to avoid hearing damage. Because hearing loss creeps up slowly, many individuals are not aware of the damage until it is too late. Long-term noise exposure also may contribute to stress-related disease, especially cardiovascular disease."

"Noise also can affect productivity. Studies show that employees in effective hearing loss prevention programs generally feel less tired and irritable. They report that they sleep better, and do not experience temporary hearing reductions at the end of the day or ringing in the ears that often precedes hearing loss. Companies with effective hearing loss prevention programs also showed reduced accident rates, illnesses and lost time."

Labels: Industrial Safety, PPE

If you are looking for information about PPE and safety equipment, try the International Safety Equipment Association web site. ISEA is the trade association in the United States for companies that manufacture safety equipment.

The web site features safety equipment related news, information about government regulations, a product and vendor guide, and information about product standards. You'll find their web site at: http://www.safetyequipment.org/

Labels: PPE