Personal Protective Equipment Erin Cropsey OSHA Region V DIOSH Day
Introduction Hazards contributing to lack of PPE use in top ten most frequently cited 45% of fatalities each year due in part to lack of proper PPE In top ten list of most accessed standards It must fit, must actually protect, & remove defective equipment
Where to Start? Determining when to use PPE Hierarchy of Controls Factors to consider Industry-specific Hazard-specific
PPE Hazard Assessment Assessment of all jobs/tasks Determine associated hazards Process hazards Environment Chemical Biological Radiation Mechanical
Industry-Specific PPE General Industry Construction Maritime Agricultural
Applicable Standards General Industry 1910 Subpart I Construction 1926.28 1926 Subpart E Hazard Specific Standards Eg. Subpart G, Z, R, M, etc.
Fall Hazards Falls contributed to 35% of fatalities What type of work is being performed? What fall protection is needed Fall restraint system (6/28/04 Letter) Work positioning equipment Personal fall arrest system Steel erection
Electrical Hazards Hazards from flames or electric arcs If there is exposure, estimate incident energy Prohibit certain types of clothing Would FR clothing be necessary? Arc rating greater than the estimated incident energy
Faceshield Hazard-Specific PPE ANSI Z87.1 ANSI Z87.1+ Foot protection Head protection Hand protection
Head protection Potential for head injuries Specific type for electrical hazards Meet ANSI Z89.1
Type I Type II Classes of Hard Hats Electrical Classes Class G (General) Class E (Electrical) Class C (Conductive)
High-Visibility What type of work is being performed? When is the work being performed? Where is the work being performed? ANSI/ISEA 107-2004 Letters of Interpretation
Garment Classes Class 1 Class 2
Garment Classes Background material Class 3 Retroflective material Width of retroflective material Yards of retroflective material Photometric performance
Hand protection Required for use to prevent hazards from: Skin absorption Severe lacerations Severe abrasions Chemical burns Thermal burns Temperature extremes
Gloves for Chemical Exposure Evaluate durability Breakthrough period Follow manufacture s recommendation
Provides the highest permeation resistance to gas or water vapors; frequently used for ketones and esters (M.E.K., Acetone, and Acetates) Butyl
Protection against wide variety of solvents Nitrile harsh chemicals fats and petroleum products excellent resistance to cuts, snags, punctures and abrasions
Kevlar Protects against cuts and abrasion
Directives Combustible Dust 29 CFR 1910.132 29 CFR 1910.134 29 CFR 1910.272 General Duty Clause What would be considered adequate PPE?
Written Requirements At a minimum, assessment must include: Written certification Certifying official identified Date of last evaluation
Implementing Programs Implement required programs Written program Medical evaluations Fit testing Baseline audiograms
Training What When How Limitations Care, maintenance, life, & disposal Retraining
Training on Fall Protection Ensuring employees understand when to inspect equipment Ensuring employees understand how to inspect equipment Ensuring defective equipment is taken out of service
Hierarchy of Controls PPE Hazard Assessment Directives Industry Specific Directives Specific Standard General Standard Letters of Interpretation Programs Hazard Specific Letters of Interpretation Medical Training Training
Employer s Responsibilities Ensure employee wears PPE When the employee chooses to use their own PPE Employer payment of PPE 1910.132 1926.95
Payment of PPE Examples of required PPE for compliance with OSHA s standards 29 CFR 1910.134(c)(4), Respiratory Protection 29 CFR 1910.146(k)(2)(i), Permit-required Confined Spaces 29 CFR 1915.1026(g)(1), Chromium (VI) 29 CFR 1926.1127(i), Cadmium
Payment of PPE If the employer requires employees to keep PPE at the workplace (non-specialty) then the employer must pay for item(s)
Employers do not have to pay for: Non-specialty safety-toe protective footwear (steel-toe shoes/boots) Non-specialty prescription safety eyewear Sunglasses/sunscreen Sturdy work shoes Lineman's boots Ordinary cold weather gear (coats, parkas, cold weather gloves, winter boots) Logging boots required under Sec. 1910.266(d)(1)(v) Ordinary rain gear Back belts Long sleeve shirts and long pants Dust masks used under the voluntary use provisions in 1910.134.
Employers must pay for Metatarsal foot protection Boots for longshoremen working logs Rubber boots with steel toes Shoe covers, toe caps & metatarsal guards. Non-prescription eye protection Prescription eyewear inserts/lenses for full face respirators Prescription eyewear inserts/lenses for welding and diving helmets Goggles and face shields Laser safety goggles Fire fighting PPE (helmet, gloves, boots, proximity suits, full gear) Hard hat Hearing protection Welding PPE Items used to protect from infectious agents (aprons, lab coats, goggles, disposable gloves, shoe covers, etc) Gloves used for protection from dermatitis, severe cuts/abrasions
Employers must pay for Rubber sleeves Aluminized gloves Chemical resistant gloves & clothing Barrier creams (unless used solely for weather-related protection) Rubber insulating gloves Mesh cut proof gloves Mesh or leather aprons SCBA, atmosphere-supplying respirators (escape only) Respiratory protection Fall protection. Ladder safety device belts Climbing ensembles used by linemen (e.g., belts and climbing hooks) Window cleaners safety straps Personal flotation devices (life jacket) Chemical protective suits Reflective work vests Bump caps
Methods of payment Acceptable methods of payment: Employer purchase and distribution Allowances Vouchers Employer reimbursement to employees
Resources Laws & Rulemaking https://www.osha.gov/comp-links.html Standards http://www.osha.gov/pls/oshaweb/owasrch.search_for m?p_doc_type=standards&p_toc_level=1&p_key value=1910 FAQs http://www.osha.gov/html/comp-links-faq.html
Resources High-Visibility Quick Reference http://www.firenews.net/pdf/3m_quickreference.pdf Directives http://www.osha.gov/pls/oshaweb/owasrch.search_for m?p_doc_type=directives&p_toc_level=0&p_keyv alue= Letters of Interpretation http://www.osha.gov/pls/oshaweb/owasrch.search_for m?p_doc_type=interpretations&p_toc_level=0 &p_keyvalue=
NFPA70E 2012 Personal Protective Equipment
Protective Clothing Topics Evaluating Workplace Hazards Protecting Your Employees Work clothing and FR apparel standards NFPA 70E, 2012 Science vs. Real World Managing Your Clothing Assets Apparel selection criteria Rent vs. buy Home wash vs. industrial laundry
Evaluating Workplace Hazards Hazard Assessment Goals
Hazard Assessment Goals Identification of hazards presenting unacceptable risk to employee health, safety and productivity. Selection of practical and feasible control strategies that minimize employee exposures and optimize employee comfort. Identifying and controlling workplace hazards involves both hard data and a savvy understanding of soft issues
Hazard Assessment Practices Many methods, tools and resources exist to help in completion of hazard recognition phase, including: Standards / OSHA regulations review Review of records / files Literature review Walk-around surveys Staff interviews
Protecting Your Employees Standards / Regulations
General Standards Applicable to Protective Apparel OSHA s General Duty Clause Employer has the responsibility to provide a place of employment free from recognized hazards Consider the risks Address those risks Develop an action plan Consumer Products Safety Commission s Requirements for Clothing Textiles, Title 16 C.F.R. Part 1610 Purpose of general wearing apparel flammability standards is to keep dangerously flammable textiles and garments made of these textiles out of commerce Ease of ignition Flame spread time
Title 16 C.F.R. Part 1610 Regulation establishes three classes of flammability based on the time of flame spread: Class 1: Normal Flammability (4+ seconds) Class 2: Intermediate Flammability (4 to 7 seconds) Class 3: Rapid, Intense Burning (- 4 seconds) Not suitable for clothing Daily-wear sold in U.S. is required to meet Class 1 or 2 requirements.
Standards Specific to Industry 29 CFR 1910.269 The employer shall ensure that each employee who is exposed to the hazards of flames or electric arc does not wear clothing that, when exposed to flames or electric arcs, could increase the extent of the injury that would be sustained by the employee. Flame resistance: ASTM D 6413 Protection from flash fire: NFPA 2112 Protection from molten substances: ASTM F 955-03 Insuring electrical safety: NFPA 70E ASTM F 1506 NESC
ASTM D 6413 - Flame Resistance Vertical flame test records: AFTERFLAME: number of seconds there is visible flame upon removal of the source After flame must average 2.0 seconds maximum AFTERGLOW: number of seconds there is visible glow, upon removal of the source After glow must average 5.0 seconds maximum CHAR LENGTH: measurement of fabric destroyed by flame. Char length must average 6.0 inches maximum
NFPA 2112 - Protection of Industrial Personnel Against Flash Fire If potential for flash fire is determined to exist, flame resistant apparel must be used that passes ASTM F1930
ASTM F955-03 - Evaluating Heat Transfer upon Contact with Molten After impact: Visual examination: Substances Charring, Shrinkage, Metal adherence, & Perforation Calorimeter temperature rise Amount of heat transferred through the fabric or layers of fabric is recorded
National Electric Safety Code (NESC ) Definition: for Utilities The NESC determines the ground rules to be used by persons while in installation, operation, or maintenance of electric supply and communication lines and associated equipment The NESC is not law It s considered a voluntary consensus standard Note: OSHA references the NESC when enforcing electrical safety in the utility market.
NFPA 70E - Standard for Electrical NFPA 70E overview: Safety Incident Energy Analysis Hazard Risk Categories (HRC) ASTM F 1506 requires: Thread, findings and closures must not contribute to injury in an arc event. Testing for Flame resistance after 25 laundry cycles, (home wash) or dry cleanings, in accordance with ASTM D 6413. Arc rating must appear on clothing labels
NFPA 70E 2112 Standard for Electrical Safety Next Revision Cycle Proposals and comment period conducted in 2010 Approval at the annual meeting in June.
Overview of Proposals 540 proposals received. 44% rejected The balance was: Accepted Accepted in principle Accepted in Part
General Direction More specific line item requirements. Lowering of acceptable levels of risk. Not much change to higher risk/ higher energy tasks. Change at the low energy end. PPE required Emphasis on FR quality.
New Requirements Requires documentation of meetings between host employers and contractors. Adds the regular supervision clause in 1910.269 for all employers. The employer shall determine, through regular supervision and or through inspections conducted on at least an annual basis that each employee is complying with the safety-related work practices required by this standard. Mandatory retraining every 3 years.
Work Permit Expanded situations where Energized Work Permit is required. When working within the Limited Approach Boundary or the arc flash boundary of exposed energized electrical conductors and circuit parts that are not placed in an electrically safe work condition work to be performed shall be considered energized electrical work and shall be performed by written permit only.
AED Training - Annual Employees responsible for taking action in case of emergency shall be trained in methods of release of victims from contact with exposed energized electrical conductors or circuit parts. Employees shall be regularly instructed in methods of first aid and emergency procedures, such as approved methods of resuscitation. Training of employees in approved methods of resuscitation, including cardiopulmonary resuscitation and automatic external defibrillator (AED) use, shall be certified by the employer annually.
Equipment Labeling Electrical equipment such as switchboards, panel boards, industrial control panels, meter socket enclosures, and motor control centers that are in other than dwelling units, that and are likely to require examination, adjustment, servicing, or maintenance while energized shall be field marked with a label containing all the following information: (1) At least one of the following: a. Available incident energy and the corresponding working distance. b. Minimum arc rating of clothing. c. Required level of PPE. d. Highest Hazard/Risk Category (HRC) for the equipment. (2) Nominal system voltage (3) Arc flash boundary Exception: Labels applied prior to September 30, 2011 are acceptable if they contain the available incident energy or required level of PPE. The method of calculating and data to support the information for the label shall be documented.
Other New Requirements Hearing protection required for all work inside arc flash boundary. Requires balaclava for all category 2 work. Added arc flash requirements for DC Hazards. Revised Battery Section. New tables and revised tables. New and revised annexes.
Next Steps Approved at annual NFPA Meeting Published September, 2011 Implementation
Science vs. Real World Testing is done in a controlled environment
Science vs. Real World Organizations must view the specific needs/goals unique to their environment Remember the testing done is not real world Molten Splash, Electric Arc, Flash Fire each event is unique.
Managing your Protective Clothing Assets A guide to selection of product and process
Apparel Selection Criteria Protection value Cost effectiveness Initial cost Life cycle cost Appearance Ease of care Wearer comfort
Cost Effectiveness Initial Cost Vs Life Cycle Cost Garment A Initial Cost, $25.00 Average Life Cycle, 1.5 years Total Cost/unit over 3 years, $50.00 Garment B Initial Cost, $45.00 Average Life Cycle, 3 years Total Cost/unit over 3 years, $45.00 Cost savings over 3 years with 200 employees @ 5 shirts ea. = $5,000!
Treated FR Fabrics Current popular options: FR Cotton Magid, A.R.C. Westex, INDURA ITEX, Banox Certified Breathable 100% Cotton FR Cotton Blends (88/12) Magid, A.R.C. Westex, INDURA UltraSoft ITEX, Banwear Durable 88% Cotton / 12% High Tenacity Nylon
Inherently FR Fabrics Current popular options DuPont Nomex Staple in the Refineries Long Life Cycle DuPont Protera Comfortable Durable Moderately priced TenCate Tecasafe Plus Comfortable / Breathable Durable Long Life Cycle
New Innovative Fabric Solutions XISPAL
PERMANENT PERFORMANCE won t wash or wear out Flame resistant Wicks moisture Dries significantly faster than cotton Skin temperature regulation Soft, natural fiber hand for superior comfort Superior durability UV ratings ranging from 16-48UPF
Inherently flame resistant Lightweight fabric Excellent wicking properties Proven fire barrier protection at over 5,000 F (no burn through for over 36 seconds). Resistant to sparks & extreme high-heat splatters.
XISPAL 841 RS Flame resistant to molten aluminum Flame resistant to molten iron Arc flash resistant, HRC 2 Inherent FR properties Industrial laundry friendly Shrinkage control @ < 3% All tests done after 50 IL cycles
Rent vs. Buy Traditional Rental Programs Direct Purchase Programs Managed Apparel Programs N.O.G Lease and wash
Rental Programs No upfront costs Garment replacement included in contract Mending included in the contract Insurance that the garment will be cleaned according to the Manufacturer s guidelines Typically, 3 to 5 year commitment required Under wash?
Direct Purchase Programs Complete control of change out to new garment Home washing, employee must take ownership of the wash process Flexibility No contract required No under wash Custom logo enhanced image Up front cost
Home Wash vs. Managed Programs N.O.G. (Not Our Goods) Direct purchase with a laundry service added Lease and Wash Leasing contract for the protective apparel from the industrial laundry company Wash program attached to the leasing contract
Questions For You To Consider Regarding FR Clothing Who will clean and repair the garments? Do they have necessary laundry instructions? Do they use appropriate FR thread and FR fabrics for repair? What is your policy concerning underwear and FR underwear? Do you prohibit polyester, nylon, & polypropylene synthetics? Do you require that FR clothing always be worn as the outermost layer?
Questions To Ask Your FR Garment & PPE Supplier What is your traceability procedure? What are your care & maintenance instructions? What industry standards do your garments & PPE meet? Do you have garments available to address all of the known hazards my employee s will face? What assistance do you provide after the sale?
Steps to Establishing your PPE Program Evaluate your environment Identify all hazards Apply standards Select required PPE Review and select your care policy/program. Train your workforce to meet your goals
Questions? Craig Howell Director of Clothing Sales Phone: (773) 289-9596 Cell Phone: (248) 719-0407 Email: CraigHowell@MagidGlove.com
Thank You