I. General Requirements
The Personal Protective Equipment (PPE) Program provides College employees with the necessary information to identify work situations that require the use of PPE and to properly select and use PPE. This information is important to help ensure the safety and health of all employees at Mount Holyoke College and is mandated by OSHA Regulation 29 CFR Part 1910.132.
PPE includes all clothing and work accessories designed to protect employees from workplace hazards. PPE should not be used as a substitute for engineering, work practices, and administrative controls. PPE should be used in conjunction with permanent protective measures, such as engineered guards, substitutions of less hazardous chemicals, and prudent work practices. Respiratory protection is covered under separate program.
The primary responsibility for this program rests with the Departments, with the Office of Environmental Health and Safety providing oversight and technical assistance.
II. Hazard Assessment
A hazard assessment is a formalization of what is done whenever personal protective equipment is selected based on the hazards of the job. When conducting a hazard assessment, a task is investigated and the hazards and the potential hazards associated with that task are determined. This allows selection of personal protective equipment that will protect the employee from the identified hazards.
During the hazard assessment of each task the workplace is inspected looking for the following types of hazards:
- Impact - objects that could result in impact either by hitting something (e.g., head on pipe), or being hit by something (e.g., flying particles).
- Penetration - sharp objects that may penetrate the surface of the body (e.g., stepping on a nail, cutting a finger).
- Compression – body part rolled over by, or between something (e.g., foot under a hand truck).
- Chemical - exposures, including airborne or skin contact, that would have the potential for splash on the skin or eyes, or the potential to breathe vapors or mists.
- Heat/Cold - high or low temperature that could result in burns, eye injury, ignition of equipment, heat/cold stress, frostbite, lack of coordination, etc.
- Harmful dust- dust or particulates that can be inhaled or cause a physical hazard.
- Light radiation – damage to skin or eyes from radiation source (e.g., welding, arc lamps, heat treating, lasers, growth lights).
- Other hazards - Any other identified potential hazard including electrical hazards.
When these hazards could cause injury to employees, personal protective equipment must be selected to reduce the injury potential. The hazard assessment should also consider the history of injury and the seriousness of the potential injury.
A Personal Protective Equipment Hazard Assessment from must be completed by the supervisor and certified by the supervisor or other department manager. This form is available in the Employee Safety Programs section of the Office of Environmental Health and Safety web site.
III. PPE Selection
Upon completion of the hazard assessment, the supervisor must identify the appropriate PPE for the activity and record it with appropriate use instructions on the assessment form.
Personal Protective Equipment (PPE) includes all clothing and work accessories designed to protect employees from workplace hazards. Protective equipment should not replace engineering, administrative, or procedural controls for safety. It should be used in conjunction with these controls. Employees must wear protective equipment as required and when instructed by a supervisor.
For each hazard identified, select personal protective equipment that will protect the employee by creating a barrier against workplace hazards. Consider the likelihood of an accident and the seriousness of a potential accident. Personal protective equipment must be selected to protect against any hazard that is likely to occur or has a serious injury impact if it does occur. It is important that employees become familiar with the potential hazards, the type of protective equipment that is available, and the level of protection that is provided by that equipment, i.e., splash protection, impact protection, etc. For chemical use, the MSDS should be referred to for the manufacturer’s recommendation.
The personal protective equipment selected must fit the employee it is intended to protect. Make certain that employees have the correct size of protective equipment. Whenever possible, select adjustable personal protective equipment. Employee input in the selection process is critical. Employees will more likely wear personal protective equipment that fits properly and is comfortable. Damaged or defective protective equipment shall be immediately taken out of service to be repaired or replaced.
Upon completion of the hazard assessment, employees must be trained and demonstrate understanding of:
- When PPE is necessary;
- What type is necessary;
- How it is to be worn;
- What its limitations are; and,
- Proper care, maintenance, useful life, and disposal.
For new employees training is generally done at the same time as Chemical Hazard Communication training. For other employees, refresher training is done by the supervisor when a new task is introduced and assessment completed, an existing assessment is significantly modified, a new type of PPE is introduced, the employee does not exhibit the requisite understanding and skill to effectively use PPE.
V. Program Evaluation
As an ongoing evaluation of the Program, the Director of Environmental Health and Safety reviews all injury investigation reports to determine if failure to wear adequate PPE contributed to the injury and follows-up with the supervisor regarding required reassessment of PPE requirements, additional training, or disciplinary action. Departments review existing assessments on a regular basis to ensure that they remain adequate and reflect actual work practices.