How Much PPE Is Too Much PPE?

With so many legal requirements demanding employers protect their workers, Personal Protective Equipment (PPE) is a necessity. And PPE is cheapest of all potential solutions … so more must be better.

Hmmmm!?

Let’s look at a common scenario. A warehouse is a distribution hub for controlled products (items covered by hazardous material legislation). The company’s hazard assessment notes the warehouse is quite dusty and workers are exposed to hazardous materials creating risks to the workers’ respiratory system and vision. The hazard assessment also notes mobile equipment may strike workers and create noise levels that are harmful to workers’ hearing causing long term damage. Also, there is a potential for falling objects when adding or removing inventory from racking. The obvious answer is to ensure all workers in the warehouse are wearing half-mask respirators, sealed goggles, high visibility coveralls, high attenuation(1) earmuffs, and hard hats. There!! Now all workers are safe, with extra safety factors included for good measure.

Hmmmm!?

The Occupational Safety & Health Administration (OSHA [US]) states the following:

5. Personal protective equipment programs(2) …

The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication. For any given situation, equipment and clothing should be selected that provide an adequate level of protection. However, over-protection, as well as under-protection, can be hazardous and should be avoided where possible.

PPE is not the solution; it is the last resort!

As an employer, how do you know if your safety program is prescribing too much PPE? When does PPE become detrimental? This is where employers (and safety personnel) need to grasp concepts of the Hierarchy of Controls associated with OHS legislation. An employer must assess the practicability(3) of Hierarchy of Controls(4) in this order:

1) Eliminate the hazard,

2) Substitute the hazard with something less hazardous,

3) Engineered Controls prevent the hazard from reaching workers using physical means,

4) Administrative Controls prevent workers’ exposure using techniques and procedures,

5) PPE mitigates impact to workers when hazard cannot be eliminated or contained,

6) Emergency Response Plan (ERP) mitigates consequences when failures occur.

Armed with this knowledge we can reassess the warehouse scenario above. (Actual controls used can vary depending on specific risk and hazard analysis results and practicability.) An air quality assessment (as part of the hazard analysis) will define the type and amount of particulate enabling appropriate risk identification. Respirators may not be necessary. Determine the level of risk or hazard posed by controlled products in our inventory. Are controlled products contained by engineered controls? Are they stored in an appropriate location? What are workers exposed to that requires respirators? Can goggles be replaced with lightweight, non-fogging safety glasses? Will a breathable, high visibility vest suffice? Is there a quieter method for moving inventory (e.g., battery operated mobile equipment)? A noise assessment (as part of the hazard analysis) will define noise levels (decibels) and durations enabling the selection of appropriate hearing protection. Will ear plugs prevent workers from suffering long term hearing damage? Will prohibiting non-essential personnel from areas where overhead loads are active preclude the need for hard hats?

If employers make these types of adjustments, when and where applicable, they can still protect workers without causing (per OSHA) heat, physical, and psychological stresses, impaired vision, avoid mobility or communication issues.

Safety professionals: please keep current with technological improvements in PPE that improve worker comfort without compromising worker safety.

As a worker, can you review hazard assessments and recommend alternative PPE solutions at your workplace?

As an employer, do you empower your workers (right to participate) to review hazard assessments and forward recommendations?

#safety #safetyculture #PPE

PHOTO CREDIT: Image powered by DALL-E 3 (Microsoft Copilot AI)

REFERENCES:

(1) Attenuation – (1) the reduction of the force, effect, or value of something. (2) the action of making [noise] weaker or less [harmful]. Oxford Dictionary online

(2) Occupational Safety & Health Administration [OSHA]. (2012). Regulations (Standards-29 CFR 1910.120 App C). Retrieved from https://www.osha.gov (halfway down web page)

(3) Practicability - availability and capability of being done after taking into consideration cost, existing technology, and logistics in light of overall project purposes. Law Insider online

(4) Dyke, Dianne E. G., (2023) Hazard Identification, Assessment, and Control (Chapter 9), Occupational Health & Safety: Theory, Strategy, & Industry Practice, 5th Edition (pp. 404-405) LexisNexis Canada