PROTECTIVE CLOTHING FOR BREWERY WORKERS

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1 PROTECTIVE CLOTHING FOR BREWERY WORKERS Best Management Practice for the Selection of Protective Clothing for Brewery Workers Presented By David Currier & Reva Golden Safety Subcommittee

2 Agenda Hierarchy of Control OSHA and Regulatory Compliance Protection Head to Toe PPE Assessment FAQ The Real Life of Protection Summary 2

3 3

4 Personal Protective Equipment (PPE) is the last choice 4

5 OSHA & Regulatory Compliance 5

6 Federal vs. State Programs 6

7 OSHA General Duty Clause Shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees 7

8 OSHA PPE Standards 29 CFR 1910 Subpart I - Personal Protective Equipment General requirements Eye and face protection Respiratory Protection Head protection Foot protection Hand Protection Hearing Conservation 1910 Subpart I App B - Non-mandatory Compliance Guidelines for Hazard Assessment and Personal Protective Equipment Selection. 8

9 General Requirements Protective equipment, including personal protective equipment for eyes, face, head, and extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact The employer shall assess the workplace. 9

10 General Requirements - Payment. personal protective equipment (PPE), used to comply with this part, shall be provided by the employer at no cost to employees. The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE. The employer is not required to pay for employee-owned equipment. Where employees provide their own protective equipment, the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment. 10

11 General Requirements - Payment The employer is not required to pay for: Everyday ordinary clothing, such as long-sleeve shirts, long pants, street shoes, and normal work boots; Items, used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats; Ordinary sunglasses, and sunscreen; non-specialty safety-toe protective footwear (including steeltoe shoes or steel-toe boots), non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job-site. 11

12 Protection Head to Toe 12

13 Hearing Protection Protection against the effects of noise exposure shall be provided when the sound levels exceed... feasible administrative or engineering controls shall be utilized. If such controls fail to reduce sound levels personal protective equipment shall be provided and used to reduce sound levels Action level 85 dba Raised voice conversation at arm s length PEL 90 dba Noise Reduction Rating (NRR) Do not over protect 13

14 Eye and Face Protection The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation. ANSI Z87.1 Look for Z87+ or Z

15 Respiratory Protection In the control of those occupational diseases caused by breathing air contaminated with harmful agents (i.e. dusts, gases, or vapors ) The primary objective shall be to use feasible engineering controls (enclosure, general and local ventilation, and substitution of less toxic materials). When effective engineering controls are not feasible, or while they are being instituted, appropriate respirators shall be used pursuant to this section. 15

16 Respiratory Protection Medical surveillance and fit testing Training Atmospheric testing Storage and inspection Dust masks Mandatory Voluntary 16

17 Respiratory Protection Appendix D Voluntary Use Dust masks Workers may wear respirators to avoid exposures to hazards, even if the hazard does not exceed the permissible limits. If your employer provides respirators for your voluntary use, or if you provide your own respirator, you need to take certain precautions to be sure that the respirator itself does not present a hazard. Precautions: Read and heed all instructions provided by the manufacturer Choose respirators certified for use to protect against the contaminant of concern. Do not wear your respirator into atmospheres containing contaminants for which your respirator is not designed to protect against. For example, a respirator designed to filter dust particles will not protect you against gases, vapors, or very small solid particles of fumes or smoke. 17

18 Respiratory Protection When effective engineering controls are not feasible Dumping grain Sweeping out trailers Clean the mill room Dry hopping Most these tasks will fall under the voluntary use rules 18

19 Foot Protection The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, or when the use of protective footwear will protect the affected employee from an electrical hazard, such as a static-discharge or electric-shock hazard, that remains after the employer takes other necessary protective measures. Protective footwear must comply with : ASTM F , "Standard Specification for Performance Requirements for Protective Footwear," 19

20 Foot Protection 20

21 Hand Protection Employers shall select and require employees to use appropriate hand protection when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes. Chemicals Moving supplies/pallets Hot surfaces 21

22 Hand Protection Chemicals use glove manufactures compatibility charts Physical Hazards use cut resistance rating 22

23 PPE Assessment 23

24 Hierarchy Revisited Burden of protection on worker Will they use it properly? Will they use it at all? For PPE to be successful it must be: Selected properly (compatible to the hazard) Used properly Stored properly Renewed regularly 24

25 Hazard Assessment Selecting the right PPE for the right job Initial Survey/Brewery Walk-thru For each specific area o Mill Vs. Cellar. Vs Bottling Line Or each specific process o Multi-use space Identify/Categorize Hazard Sources Impact, penetration, compression, chemical, heat, harmful dust, light/radiation, loud noises Where s it gonna hurt? Head, Eyes/Face/Ears, Hands, Feet, Skin, Lungs 25

26 Motion Hazard Sources Motor-driven equipment, tools, machine elements Vehicles, forklifts, garage doors Is there movement of personnel that could result in collision with stationary objects? High Temperatures Steam lines, burners, ignition sources, kettle Skin burns, eye injury, or heat stress Process Chemicals What chemicals are you using? Can they splash? Are they creating vapors? Generation of Dust Grain handling, filtration, sweeping, drilling/sanding Light/Radiation Welding, brazing, cutting, furnaces, heat treating, high intensity lights 26

27 Hazard Sources (cont d) Falling Objects Working from heights, elevated platforms, warehousing/stacking Sharp Objects What may pierce through feet or cut hands Rolling/Pinching Usually on conveyor lines Keg/compressed cylinder handling Electrical Arcing and shock response Noise Are there any areas where you have to raise your voice? Workplace Layout 27

28 Organize and Analyze the Data Look at the hazards and determine what PPE is needed for each area or task General area PPE requirements Task specific PPE requirements May require additional analysis Just how serious is the hazard and what s the risk? It s dusty, but do I need a respirator? It s loud, but do I need earplugs? We need safety glasses but which ones? 28

29 Selection Guidelines Is the PPE really going to work? Gloves, Glasses, Respirator, Boots Fit Considerations Sizing options Adjustability Will it last forever? Storing Degradation Introducing new hazards 29

30 In Practice 30

31 Now that you ve: Training Identified the hazards and selected the proper PPE for each area/task You must train your employees! How to use, store, inspect, clean, maintain Equipment limitations Application incompatibilities Frequency of change out Signs of failure Breakthrough, symptoms of exposure 31

32 Real Life Examples Employer provides ear plugs Employees don t wear Doesn t consider sizes, comfort, or instruct on how to store/wear Employer provides dust mask for grain room One-size-fits all and poor change out schedule Kitchen has laminate gloves for cooking Brewers borrow and find out not good for PAA Wearing nitrile gloves when cleaning up after bottling Finding a piece of stray glass on the floor 32

33 Real Life Examples Employer buys female employee a pair of pink boots Generic rain galoshes don t protect against dropped keg Safety boot with tucked in pants or shorts Chemicals drip down and permeate socks Shoe staging areas 33

34 In Summary - PPE Personal Protective Equipment PPE can be a great tool for improving brewer safety Not the only tool Never the best solution The right PPE must be selected for the job Hazards must be assessed May require systematic and scientific analysis Limitations must be considered PPE must be used correctly Employees must be trained on use, storage, and maintenance 34

35 Brewery Safety Training On-Line Brewery Safety Training Code:

36 Questions & Answers 36

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