Personal Protective Equipment

Personal Protective Equipment (PPE) Program Summary

This program provides information regarding hazard exposures where engineering and administrative controls do no provide sufficient risk reduction. The proper selection and use of personal protective equipment, such as safety glasses, hand hats, gloves, hearing protection, etc. is covered.

Departments should designate a personal protective equipment coordinator(s) to implement requirements of this program. This is typically assigned to supervisors, priniciple investigators, or designated safety representatives depending on organizational structure and oversight.

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Responsibilities

PPE Coordinators

PPE coordinators should take the required training specified by the program (i.e. PPE Awareness and Hazard Assessments) prior to fulfilling the responsibilities indicated below.

PPE coordinators designated by the department will perform the following tasks once they have received training from Environmental Health & Safety:

• Conduct hazard assessments in accordance with the requirements outlined in this program.
• Evaluate the hazards identified to determine if engineering or administrative controls can be implemented to eliminate or reduce the hazard to a safe level. Guidance on hazard control is provided in this program. Environmental Health & Safety should be consulted for certain controls, such as respiratory or hearing protection, ventilation systems, etc.
• Select and have each affected employee use appropriate protective equipment if hazards cannot be properly controlled. The department must assure that all PPE meets regulatory requirements as defined in this program, and is of a safe design and construction for the work to be performed.
• Assure that employee-owned equipment, where provided by the employee, is approved and adequate for the hazardous condition, and that this equipment is properly maintained and inspected as required by this program or the manufacturer.
• Assure that damaged or defective PPE is removed from service and not used.
• Assure that employees assigned and required to use PPE are properly trained and informed regarding the hazards and proper use, storage, care, inspection, and maintenance of such equipment. New employees should receive training from the supervisor/PPE coordinator prior to being assigned tasks requiring the use of PPE.
• Maintain documentation for hazard assessments and PPE training. Documents must be made available to Environmental Health & Safety or other regulatory authorities upon request. 
• Review existing Hazard Assessments on a periodic basis to ensure PPE assignments remain valid and personnel are trained and informed.
• Reassess the workplace when new hazards are introduced, or when processes are changed or added.

Employees and Students

Employees and students are responsible for following the requirements of this program. Expectations include:

• Attend required training sessions on assigned PPE provided by the Supervisor or PPE Coordinator.
• Wear assigned PPE as required.
• Properly clean, inspect, maintain, and care for PPE as required.
• Inform the PPE Coordinator of the need for repair or replacement of PPE.

Environmental, Health and Safety (EHS)

Environmental Health & Safety responsibilities for this program include:

• Developing, implementing, and administering the program.
• Training PPE coordinators on all aspects of the program requirements.
• Serving as a technical resource to departments and PPE coordinators, including for hazard evaluations and control reviews.
• Providing guidance on the selection, care, inspection, and use of PPE.
• Maintaining centralized records of PPE coordinator training and related inspections.
• Evaluating the overall effectiveness of the program on a periodic basis and making appropriate changes as needed to assure the safety of personnel.
• Maintaining the university Respiratory Protection and Hearing Conservation programs, and evaluating workplace exposures to hazards that would require the use of respirators, hearing protection, or laser eyewear.
• Maintaining the University Chemical Hygiene Plan for laboratory operations.

Contractors

Contractors must comply with all local, state, and federal safety requirements, and must assure that all of their employees performing work on Virginia Tech property have been suitably trained and are provided appropriate personal protective equipment. Contractors must also comply with the requirements outlined in Virginia Tech's Safety Requirements for Contractors and Subcontractors.

Visitors

Visitors to Virginia Tech property, who may be exposed to certain hazards, must wear appropriate PPE. It is the responsibility of the person(s) hosting the visitors to enforce this aspect. PPE used by visitors, whether provided by the visitor or the host department, must meet at a minimum the requirements established for Virginia Tech employees.

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Training

Personal Protective Equipment (PPE) Awareness

Personnel who use PPE must be trained on the proper use, maintenance, storage, and limitations of the equipment, including manufacturer's instructions, where applicable.

Personal Protective Equipment (PPE) Coordinator

The designated PPE Coordinator (or supervisor) must complete PPE Awareness and Hazard Assessment training in order to identify hazards where PPE may be necessary, select the appropriate PPE for the hazard(s), and complete the necessary documentation, i.e. Hazard Assessment Form.

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Hazard Assessments

Employers are required by OSHA to certify in writing that they have assessed the work area to determine if hazards that required the use of personal protective equipment (PPE) are present or likely. A Hazard Assessment Form, has been developed to help departments meet this requirement. Hazard Assessment training is available online to provide guidance and understanding of what hazards to look for, and how to complete the form.

Conducting the Hazard Assessment

• Look at how your personnel are similar, or different, with respect to their work, their location, and their hazard exposures. If all personnel have similar exposures due to the type of work performed or the location of their work area, they may be evaluated as a group. If there are some personnel who have significantly different exposures, they may require a separate assessment. Mark the appropriate box on the Hazard Assessment Form and fill in the required information for locations, position numbers and titles.
• Perform a walk-through of the area or observe personnel performing tasks. Look for existing or potential hazards and enter them on the Hazard Assessment Form by checking "Yes" for exposure to a body part and describing what the hazard exposure is in general terms in the space provided. Interview employees or review accident data, if necessary, to help identify hazards. Also look for general hazards, such as:
  • Moving equipment/parts/processes/personnel that could result in collision, compression, or impact.
  • Potential for objects to fall or drop from above onto an employee.
  • Exposure to chemicals or potentially harmful dusts, mists, or fumes.
  • Rolling or pinching objects or machinery processes that could crush body parts, catch hair, or snag loose clothing.
  • Electrical hazards from equipment, wiring, or utilities.
  • Presence or use of sharp objects that could cut or pierce the body.
  • Hot or cold surfaces that could cause burns or freezing.
  • Light (optical) radiation from welding, cutting, brazing, lasers, or other sources.
  • Use of tools or equipment that may generate flying debris, harmful dusts, vibration, repetitive motion, or noise.
  • Processes involving mixing or pouring of hazardous liquids.
  • Work area layout or spacing that may create hazardous conditions, for example, chemical storage near electrical panels or welding/cutting in high-traffic areas.
  • Material handling involving pushing, pulling, or lifting on a regular basis.
• For each hazard identified and entered on the Hazard Assessment Form, indicate whether it will be controlled through engineering or administrative controls, or specify what type of PPE is required. The next section will help you evaluate these options.

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Hazard Controls

PPE Coordinators should consider the feasibility of eliminating hazards in the workplace, and implementing engineering and administrative controls whenever possible. If the risk is not eliminated or reduced to an acceptable level, PPE must be selected.  Some common examples of each type of control are provided below.

Elimination

Elimination of the hazard means that the hazard no longer exists in the workplace and therefore potential exposure to the hazard is also completely eliminated. Always consider elimination of the hazard first.

• On-demand supply instead of on-site storage
• Maintenance-free batteries
• Purchase premixed products

Substitution

Substitution of a hazard is when an alternative tool, material, or process is used instead of the more hazardous one and the exposure risk is eliminated. The substitute may pose some risk to other hazards, and should be evaluated to determine if controls are necessary.

• Dipping/brushing instead of spraying
• Bolting together instead of welding
• Hacksaw use instead of grinding
• Wet processes instead of dry processes
• Using non-hazardous chemicals
• Using less hazardous radioactive substances (ex. P-33 instead of P-32)
• Soap and water instead of solvents
• Automation instead of manual equipment

Engineering Controls

Engineering controls remove exposure to the hazard in a workplace, or use a barrier to virtually eliminate worker exposure to a hazard. The hazard is controlled on a relatively permanent basis. Engineering controls are the most desirable and effective type of hazard control, but may not always be feasible due to time and money constraints. 

Isolation

• Control rooms or restricted access areas
• Guarding
  • Machinery guards
  • Fall protection/guardrail systems/parapet walls on roofs
• Barriers/shielding (ex. welding shields, plastic for P-32 radiation sources)
• Locking out hazardous energy sources

Design

• Proper access (ex. stairways, ramps)
• Height (ex. hazard located above employee access, typically 8 feet)
• Impervious work surfaces
• Seamless flooring
• Safety interlocks on equipment
• Automatic shutoff

Work Area Layout

• Separating non-compatible work tasks
• Routing high-traffic paths away from hazardous areas
• Minimize size of radioactive work areas
• Segregating radioactive work

Ventilation

• Increase air flow
• Use fume hoods for mixing
• Local exhaust ventilation
• Filtration (ex. HEPA-filtered Biosafety cabinets, charcoal filtering for radioactive substances such as I-125)

Administrative Controls

Administrative controls alter the way a procedure or task is performed and rely on employee actions/behaviors to control the hazard. The hazard and/or employee exposure is reduced to a safer level but still may require the use of PPE.

Housekeeping

• Regular cleaning of work area
• Dry, clean floors
• Proper storage of tools, materials, chemicals, radioactive substances
• Proper spill response
• Surplus old machinery/equipment
• Vacuum instead of sweeping

Training

• Hazard recognition (general and hazard-specific)
• Hazard controls (general and hazard-specific)
• Safe work practices
• Safe operating procedures
• Emergency procedures
• Manufacturer's instructions (owner/operator manuals)

Exposure Reduction

• Perform hazardous tasks less frequently
• Rotate employees in hazardous areas (not permitted for respiratory hazards)
• Minimize on-hand stock of hazardous materials
• Minimize waste products by recycling or redistribution
  • Ex. donate chemicals to university surplus
• Decrease time/increase distance (radiation or noise exposures)

Preventative Maintenance

• Regular inspections on machinery, equipment, systems
• Routine/periodic servicing and maintenance

Exposure Monitoring

• Quarterly review of personal radiation doses
• Investigation at 10% and 25% of occupational exposure limits (radiation)
• Identify radiation contaminated areas

Safe Work Practices and Procedures

• Identify and develop for hazardous processes
• Perform radiological hazard analysis
• Label equipment as radioactive
• Container labeling (chemical, radioactive, biohazardous)

Personal Protective Equipment (PPE)

When hazards cannot be eliminated or engineering and administrative controls do not reduce the exposure to an acceptable level, personal protective equipment (PPE) must be considered. PPE must be selected and assigned to personnel in accordance with the PPE Program requirments.

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PPE Selection

Once you have determined the potential hazards for each area of the body by entering the hazards onto the Hazard Assessment Form, use the information provided in the appendices to help select the appropriate type of PPE. For some types of PPE, such as hearing protection and respiratory protection, you must go through Environmental Health & Safety for proper selection and fit. For others, such as fall protection or the use of voltage-rated equipment, additional training is required by Environmental Health & Safety to adequately address related hazards and/or to meet regulatory requirements.

The PPE must be fitted to the user. PPE that fits poorly will not provide the necessary protection, and the employee is less likely to wear the device if it does not fit comfortably. Protective devices are generally available in a variety of sizes. Care should be taken to ensure the right size is selected for each individual wearer.

Adjustments must be made on an individual basis for a comfortable fit that will maintain the protective device in the proper position. If the PPE is not adjustable by design, you should not make any alterations to it! This voids the manufacturer's warranty and compromises the protective qualities of the equipment.

Employees must be given instructions on the care and use of PPE assigned to them. It is very important that the end users be made aware of all warnings and limitations of their PPE. PPE coordinators are assigned the task of training employees on the PPE assigned. Guidelines are provided in the appendices but are not a substitution for the manufacturer's instructions, which are included with the PPE when purchased.

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Appendices

Appendix A - Eye and Face Protection

Appendix B - Head protection

Appendix C - Foot and leg protection

Appendix D - Hand and Arm Protection

Appendix E - Protective Clothing/Bodywear

Appendix F - Fall Protection

Appendix G - Hearing Protection

Appendex H - Respiratory Protection

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Definitions

ANSI: American National Standards Institute - coordinates the development and use of voluntary consensus standards in the United States, and represents the needs and views of U. S. stakeholders in standardization forums around the globe.

ASTM: American Society of Testing Materials - one of the largest voluntary standards developing organizations in the world - a trusted source for technical standards for materials, products, systems, and services.

Competent person: a person capable of identifying safety hazards and authorized to take prompt corrective action.

NFPA: National Fire Protection Association - a nonprofit organization formed to reduce the worldwide burden of fire and other hazards on the quality of life by providing and advocating consensus codes and standards, research, training, and education.

NIOSH: National Institute for Occupational Safety and Health - the federal agency responsible for conducting research and making recommendations for the prevention of work-related injuries and illnesses. NIOSH is part of the Center for Disease Control and Prevention (CDC) in the Department of Health and Human Services.

OSHA: Occupational Safety and Health Administration - formed by the federal government to assure the safety and health of America's workers by setting and enforcing standards; providing training, outreach, and education; establishing partnerships; and encouraging continual improvement in workplace safety and health.

Qualified Person: One who has received training appropriate for the tasks to be performed, and has demonstrated the necessary skills and techniques to perform his or her work safely.

SDS: Safety Data Sheet - A summary sheet provided by the manufacturer of a chemical or other potentially hazardous product. The MSDS explains the hazards of the material and the precautions that must be taken to prevent fires, explosions, or harmful health effects.

TWA: Time-weighted average - (in reference to noise exposure) the sound level which, if constant over an eight-hour exposure, would result in the same noise dose as is measured.

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Documents

Contact Information

Robin McCall-Miller, Occupational Safety Program Manager

Phone: 540-231-2341
Email: rmmiller@vt.edu