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The Hierarchy of Controls, Part Four: Personal Protective Equipment

The Hierarchy of Controls: Part Four

Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with.  Why?  Well, PPE is quick, easy, often less expensive than other options, and readily available.  What you might not realize, though, is that PPE is what OSHA considers to be a “last resort”.  When it comes to the Hierarchy, PPE is supposed to be used either a) while other controls are being implemented, b) in conjunction with other controls or c) when all other options have been exhausted.  In other words, a full body harness should not be your go-to fall protection solution. Yet, so many companies turn to PPE first.

Personal Protective Equipment really is exactly what the name implies: protection you use personally.  So, while a personal fall arrest system is considered PPE, a guardrail is not.  While a respirator is considered PPE, ventilation is not.  PPE includes most things required to be worn on the job, such as earplugs or other forms of hearing protection, hardhats, safety glasses or goggles, face shields, gloves, coveralls, steel or reinforced-toe boots, reflective vests, and so much more.  PPE is so prevalent among the workforce that you’d think injuries would be virtually non-existent, but they’re not.  Why?

Insufficient / Wrong PPE

PPE sometimes gets thrown at a hazard without really evaluating the situation.  Hearing protection is great, but does it do the necessary job?  Ear plugs are rated for noise reduction, so how do you know that grabbing that pack of earplugs out of the jar in the office will reduce the noise below acceptable levels?  Has a noise survey been performed?  If so, was the equipment selected based on that survey?  Or in terms of respiratory protection, has anybody determined what the dust in the air is composed of before deciding to buy a cheap box of dust masks?  Even if you know what the dust is made of, has anybody sampled to determine the levels to which your employees are being exposed?  PPE is not a game of guesswork, though it might seem that way if you were to wander into various workplaces throughout the United States.  Careful consideration needs to be taken to determine what PPE is appropriate to protect your employees from workplace hazards

PPE is Not Properly Cared For / Used

PPE is only as good as the user.  Safety glasses offer no eye protection if they are constantly left on top of the user’s hardhat.  A reflective vest offers no visibility if the user throws a coat over it when he or she is cold.  A respirator may do more harm than good if hazardous dust is allowed to accumulate on the inside of it and it is not properly cleaned.  A full body harness, rather than save your life, could cause serious internal damage and other bodily harm if it’s not worn properly.  Using PPE as a hazard control includes using it properly, maintaining it properly, and caring for it properly.  Harnesses are supposed to be kept hung in a cool, dry place, yet how many do you see lying around a jobsite or in the back of a truck exposed to sunlight (UV decay), rain, freezing temperatures, and more?  When that harness fails, is it because it was the wrong equipment?  No.  It wasn’t properly cared for.  Respirators should have change out schedules depending on the filters you are using and exposures your employees have.  Does your plan have one?  If not, how do your employees know when to get new cartridges.  Do they know to get new cartridges?  And can a user even use equipment properly if they don’t know if it should even be used in the first place?  Are your employees inspecting their PPE or are they just pulling it out of the toolbox and going to work?  How will they know if something has gone wrong if you do not have them doing inspections?  You can’t throw PPE at a problem and expect it’s going to help without the proper preparations.

Training

Which brings us to our next point: training.  How do you expect your employees to know how to properly inspect, use and care for their equipment?  If you don’t train them, there’s a good chance they may barely be able to figure out how to put a harness on, let alone how to put it on properly.  If you don’t train them, they could be using a respirator with cartridges that have broken through, but they have no idea because the hazard is not one they can smell or taste.  They may be using ear plugs that should do the trick, but have been inserted improperly.  You can’t assume people will just know what to do.  Not only is training a good idea, but it’s required by OSHA.  Take the time necessary to ensure your employees are able to keep themselves safe.  You don’t need to do an eight-hour training to show employees how to wear earplugs, but you do need to do some training. 
The Hierarchy of Controls is a phrase used often in the safety and industrial hygiene world.  If you weren’t familiar with it before this series, hopefully now you’re better informed.  Of course, now that you know what it is, there’s still a lot of work to do: you still need to investigate your hazards, you still need to determine what the best possible control is, you still need to design and implement that control, and you still need to train your employees.  A breakdown at any step could cause failure.  And, when human lives are at stake, failure is unacceptable. 

 


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This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

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http://www.signaturesafety.net

John Braun has been in the EHS field for more than 14 years. He achieved his CHST in 2005 and his CSP in 2010. Though he focuses on construction, his background includes manufacturing, recycling, and warehousing facilities as well. John holds a Bachelor's degree in English from The College of NJ.

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