Neal Bolton

By Neal Bolton

Personal protective equipment (PPE) includes hardhats, goggles, gloves, earplugs, vests, respirators, and other devices intended to protect workers from injuries or illnesses.

There are many types of PPE—so many that the selection and use of appropriate PPE can be confusing, even overwhelming, sometimes to the point that the issue of PPE is avoided entirely.

But not to worry: Avoidance is a common means of dealing with something overwhelming or traumatic. Psychologists call this denial. Let’s not go there.

Proper selection and use of PPE is a vital part of any health and safety program, and it begins by identifying specific workplace risks. Employers are in fact required to perform an assessment of the workplace and identify any risks or hazards that may require PPE. OSHA refers to this process as a "hazard assessment."

When performing a hazard assessment, you should look for potential sources of injury. Examples might include falling objects, chemicals, harmful dust, potential fall zones, and unsafe or improperly guarded machines or equipment. What we’re looking for here are situations or environments that could cause illness or injury. And while you’re looking around, don’t forget to look back. Injuries and illnesses that have occurred in the past can help identify risks that could threaten workers in the future.

For information on how to conduct a hazard assessment, go to OSHA’s Web site at www.osha.gov and download publication number 3151 entitled Personal Protective Equipment.

According to this document, "In general, employers are responsible for:

• Performing a ‘hazard assessment’ of the workplace to identify and control physical and health hazards.
• Identifying and providing appropriate PPE for employees.
• Training employees in use and care of the PPE.
• Maintaining PPE, including replacing worn or damaged PPE.
• Periodically reviewing, updating and evaluating the effectiveness of the PPE program."

Similarly, "In general, employees should:

• Properly wear PPE,
• Care for, clean and maintain PPE, and
• Inform a supervisor of the need to repair or replace PPE."

What you’ll find as you review OSHA’s requirements is that not all PPE items are required all the time. There is latitude for employers to use judgment and common sense, and that’s a good thing—provided of course that they do. Safety-conscious managers know that the best way to deal with specific risks is on a case-by-case basis, and then to select PPE that is appropriate to the situation at hand.

Consider, for example, the various attitudes toward hardhats.

Hardhats are required whenever falling or flying objects could cause head injury. Hardhats are also required whenever workers could come into contact with electrical conductors. Does this mean that all landfills, transfer stations, and hauling companies must require workers to wear hardhats? Not necessarily.

Many solid waste workers wear hardhats. Others do not because, in some cases, the risk is low enough that employers have decided that hardhats aren’t necessary.

In some "tail wag the dog" situations, hardhat policies are not enforced simply because it is unpopular with the workers. In those cases, employers have given up and gone along with the idea that their workers are hardheaded enough to "self protect."

During your next safety meeting, I challenge you to divide your crew into two groups. Ask one group to identify situations where hardhats would not be necessary. Ask the other group to refute the first group and list potential risks for each of those supposedly safe situations. I bet they’ll find plenty.

I find it interesting that the older I get, the more cautious I become. And while I must admit that in my younger days I seldom wore a hardhat, I now find it difficult to imagine any situation that could not pose a potential threat and where wearing a hardhat would not make good sense. Of course, some might say that leaning toward hardhats is due to a lack of hair, but it’s not (denial).

Who’s right in this debate between hardheads and hardhats? Well, it’s not a question of who’s right or who’s wrong. It’s a matter of safety. In other words, based on a particular situation, should wearing hardhats be a policy? That’s up to you.

These same types of issues can arise around any other type of PPE. Managers and supervisors typically have the duty of knowing or determining what’s required and then making it happen.

The bottom line is this: When it comes to safety, responsibility and authority go hand in hand. As a manager you have the authority and responsibility to develop and enforce safety policies. So do it.

If you don’t have a policy on PPE, develop one. If you have one, enforce it.

In general, the best PPE policies establish some basic rules that may include

• hardhats for all employees;
• leather boots for all employees;
• hearing protection for employees who work in noisy environments; and
• leather gloves for selected employees.

A good plan would also include some guidelines for identifying other hazards and implementing PPE requirements to guard against them. This can be a balancing act. Some polices are too vague. Others go beyond the realm of basic requirements to a point where there is no room for common sense, simply in an effort to avoid liability.

When developing a PPE plan, keep in mind the primary goal of protecting workers and set your policy accordingly.

Neal Bolton is a consultant specializing in landfill operations and management.

MSW - May/June 2005