Personal Protective Equipment
Assessment Comes First
Under 1910.132 the employer must assess workplace hazards, certify that assessment in writing (identifying the workplace evaluated, the person certifying, and the date), select appropriate PPE, communicate the selection decisions, train employees, and require the PPE to be worn. PPE sits at the bottom of the hierarchy of controls - after elimination, substitution, engineering controls, and administrative controls.
Who Pays, and What Training Covers
The employer pays for required PPE, with narrow exceptions: non-specialty safety-toe footwear and non-specialty prescription safety eyewear that the employee is allowed to take off-site, everyday clothing, and items the employee chooses to wear. Training must address when PPE is necessary, what PPE is required, how to don, doff, adjust, and wear it, its limitations, and its care, maintenance, useful life, and disposal. Retraining is required when workplace changes make prior training obsolete or when an employee shows he or she does not understand.
Requirements by Body Part
Eye and face protection (1910.133) must meet Z87.1; head protection (1910.135) Z89.1; foot protection (1910.136) Z41. Respiratory protection (1910.134) requires a written program, a medical evaluation before fit testing or use, annual fit testing, annual training, and a user seal check each time the respirator is worn. Hearing protection under 1910.95 kicks in with a hearing conservation program at the 85 dBA TWA action level; the PEL is 90 dBA TWA over 8 hours.
Traps and a Rule of Thumb
Traps: assuming employees pay for hard hats or respirators; delivering training without a documented hazard assessment; fit testing before the medical evaluation; substituting a bump cap for a hard hat.
Rule of thumb: assess, select, train, use, maintain - and the employer pays.