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| Comprehensive PPE Hazard Assessment Guideline for Maintenance and Trades PPE Hazard Assessment Form and Guidance |
6.1 Introduction #
Controlling a hazard at its source is the best way to protect employees. When engineering, work practice, and administrative controls can’t protect employees, employers must provide personal protective equipment (PPE) to their employees and ensure its use. PPE is equipment worn to minimize exposure to a variety of hazards.
Employers and employees using PPE need to do the following:
- Understand the types of PPE.
- Know the basics of conducting a “hazard assessment” of the workplace.
- Select appropriate PPE for a variety of circumstances.
- Understand what kind of training is needed , the proper use and care of PPE
Reference Regulation: Personal Protective Equipment (MIOSHA General Industry Part 33)
6.2 Hazard Assessment and Selection #
A PPE hazard assessment must identify the sources of hazards an employees body may be exposed to during routine tasks
- PPE Assessments are to be completed in the workplace for routine tasks.
- The PPE Hazard Assessment Form, located in the “Documents” header for this program, is a form designed to: (a) determine if hazards are present or likely to be present in the workplace which may necessitate the use of PPE; and (b) select the correct PPE for the affected personnel based on the highest level of each hazard identified. The form should be completed by a competent person or supervisor.
- Competent Persons or supervisors shall conduct PPE assessments and update employees of changes.
- Once reviewed and approved, PPE Assessment forms shall be shared with employees in the department.
The following should be noted during a PPE Assessment:
- Potential Impact/motion; i.e., machinery or processes where any movement of tools, machine elements, or particles could exist
- Extreme temperatures that could result in burns, eye injury, or ignition of protective equipment, etc.
- Types of chemical exposures
- Hazardous atmospheres
- Hazardous radiation, i.e., welding, brazing, cutting, furnaces, heat treating, high intensity lights, etc.
- Falling objects or potential for dropping objects
- Sharp objects which might pierce the feet or cut hands
- Rolling or pinching objects which could crush the feet
- Layout of the workplace and location of co-workers
- Any electrical hazards
6.3 Selecting and Obtaining PPE #
- Select PPE which ensures a level of protection greater than the minimum required to protect employees from the hazards. PPE that fits well and is comfortable to wear will encourage employee use.
- Ensure the PPE Fit, If PPE does not fit properly, it can make the difference between being safely covered or dangerously exposed. It may not provide the level of protection desired and may discourage employee use.
- Reassess hazards when new equipment and/or processes introduce hazards that might require revised PPE strategies
- F&O employees can request Prescription Safety Glasses or Safety Shoes through the F&O Safety Intranet site, with some exceptions for bargained employees. Other departments can purchase protective footwear through Grainger on U-M Marketsite by using a shortcode. Other options for departments would be through employee reimbursement of appropriate footwear from retail stores. Prescription safety glasses can be requested using the EHS online request form.
- Any other required PPE will be provided to the employee by their supervisor.
6.4 Training #
- PPE training for newly hired employees will be conducted as part of safety orientation training and whenever new tasks are introduced that impact PPE selection and use.
- Supervisors are responsible for providing site and/or task-specific PPE training for each employee. The training shall include all of the following:
- When PPE is necessary
- What PPE is necessary.
- How to properly put on, take off, adjust and wear the PPE.
- The limitations of the PPE.
- Proper care, maintenance, useful life and disposal of PPE.
- Additional requirements when sharing PPE.
Employers should make sure that each employee demonstrates an understanding of the PPE training as well as the ability to properly wear and use PPE before they are allowed to perform work requiring the use of PPE. If an employer believes that a previously trained employee is not demonstrating the proper understanding and skill level in the use of PPE, that employee should receive retraining.
6.5 Maintenance and Inspection #
All PPE must be adequately cleaned and maintained. All PPE should be thoroughly inspected before each use by the intended user. PPE that is intended for use by more than one person, must be regularly cleaned and inspected, with such inspection being recorded for future reference. PPE with defects or other damage must be immediately removed from service and repaired or replaced.
6.6 Sharing PPE #
If shared PPE is used, the employer must make sure that employees disinfect shared protective equipment after each use. Protective eyewear with corrective lenses may not be shared.
Hair enclosures shall not be reissued from one employee to another unless it has been thoroughly sanitized.
- Safety shoes and boots which are not worn over shoes and which are worn by more than one employee shall be maintained, cleaned, and sanitized inside and out before being issued to another employee
- If more than one employee wears a pair of gloves, the gloves shall be sanitized before reissuance.
6.7 PPE Protection and Selection #
PPE is not to be worn in offices, lunch rooms, break rooms, rest rooms, conference rooms, meeting rooms or other public access areas.
Eye and Face #
Employees can be exposed to a large number of hazards that pose danger to their eyes and face. MIOSHA requires employers to ensure that employees have appropriate eye or face protection if they are exposed to front and/or side impact hazards from:
- Flying objects and particles
- Molten metal
- Liquid chemicals
- Acids or caustic liquids
- Chemical gases or vapors
- Harmful contacts
- Exposures
- Electrical flash
- Injurious radiation
- Glare
- Any combination of these hazards
When selecting the most suitable eye and face protection for employees, the following elements should be taken into consideration:
- Ability to protect against specific workplace hazards.
- Should fit properly and be reasonably comfortable to wear.
- Should provide unrestricted vision and movement.
- Should be durable and cleanable.
- Should allow unrestricted functioning of any other required PPE.
The eye and face protection selected for employee use must clearly identify the manufacturer. Any new eye and face protective devices must comply with ANSI Z87.1-1989 or be at least as effective as this standard requires.
Lenses #
- Filter lenses The intense light associated with welding operations can cause serious and sometimes permanent eye damage if operators do not wear proper eye protection. The intensity of light or radiant energy produced by welding, cutting, or brazing operations varies according to a number of factors including the task producing the light, the electrode size, and arc current. Table 1 in Part 33 of the MIOSHA PPE standard shows the minimum protective shades for a variety of welding, cutting, and brazing operations.
- Clear lenses are impact-resisting and provide protection against flying objects. The use of tinted lenses for cosmetic purposes is not acceptable. Clear lenses must transmit not less than 89% of visible radiation. To wear a tinted lens that transmits less than 89%, a medical statement should be provided.
- Absorptive lenses of shades 1.7 through 3.0 are impact-resisting and provide protection against flying objects and glare or which are impact-resisting and provide protection against flying objects, and narrowband spectral transmittance of injurious radiation. Shaded lenses greater than 3.0 should be worn when employees are exposed to injurious radiation.
- Protective-corrective lenses are impact-resisting and either clear or absorptive, as specified for persons requiring visual correction.
- Filter lenses are impact resisting and provide protection against flying objects and narrow-band spectral transmittance of injurious radiation.
Face Protection #
Face protection shall be used where a hazard exists to the face due to flying objects or particles, molten metal, liquid chemicals, gases, vapors, or injurious light radiation. Face shields worn over safety glasses are required for certain processes as determined by the supervisor and/or the PPE hazard assessment . Face shields must always be worn over safety glasses or goggles, not instead of safety glasses or goggles. The use of face shields over safety glasses is required with processes involving high pressure (>30 PSI), pneumatic lines (>30 PSI), or machining operations.
Head Protection #
Hard Hats and bump caps are required to shield the head from the impact and penetration of falling objects, working in low clearance areas, and in some cases, electric shock and burns. Head protection should be worn whenever the potential exists for injuries to the head due to falling objects or when head clearance is restricted.
Employers must ensure that their employees wear hard hats if they are exposed to any of the following:
- Falling or flying objects
- Significant impact hazards
- Other harmful contacts or exposures
- Risk of injury from electrical shock
Bump caps may be provided when the only head hazards present are:
- low clearance hazards such as under machinery, in confined spaces, or beneath vehicle
- bump or scrape hazards such as overhead objects like pipes, shelving, or equipment
Types of hard hats #
- Class G hard hats provide impact and penetration resistance along with limited voltage protection (up to 2,200 volts).
- Class E hard hats provide the highest level of protection against electrical hazards, with high-voltage shock and burn protection (up to 20,000 volts). They also provide protection from impact and penetration hazards by flying/falling objects.
- Class C protective hats provide limited voltage protection (firefighters service helmets with full brim.)
Hair enclosures #
Where there is a danger of hair entanglement in moving machinery or equipment, or where there is exposure to means of ignition, a hat, cap, or net shall be used. Hair enclosures shall be reasonably comfortable, completely enclose all loose hair, and be adjustable to accommodate all head sizes. Materials shall be fast dyed, non-irritating to the skin, and capable of withstanding frequent cleaning.
Foot and Toe Protection #
The minimum level of protective footwear required in work areas with hazardous materials or processes is a closed toe shoe. No sandals, flip flops, etc. are allowed.
Additional protective footwear is required when employees work in areas where there is a danger of foot injuries due to falling and rolling objects, objects piercing the sole, and where employees’ feet are exposed to electrical hazards. Protective footwear can be obtained by the department through a local safety shoe vendor.
Examples of situations in which an employee should wear foot and/or toe protection include:
- When heavy objects such as barrels or tools might roll onto or fall on the employee’s feet.
- Working with sharp objects such as nails or spikes that could pierce the soles or uppers of ordinary shoes.
- Working on or around hot, wet or slippery surfaces.
- Working when electrical hazards are present.
Types of Foot, Leg and Toe Protection #
- Safety shoes have impact-resistant toes and heat-resistant soles that protect the feet against hot work surfaces common in roofing, paving, and hot metal industries. The metal insoles of some safety shoes protect against puncture wounds. Safety shoes may also be designed to be electrically conductive to prevent buildup of static electricity or non-conductive to protect workers from workplace electrical hazards.
- Leggings protect the lower legs and feet from heat hazards such as molten metal or welding sparks.
- Metatarsal guards protect the instep from impact and compression.
- Toe guards fit over the toes of regular shoes to protect the toes from impact and compression hazards.
Hand Protection #
Protective gloves are required to prevent: skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; harmful temperature extremes
Types of protective gloves
There are many types of gloves available today to protect against a wide variety of hazards. The following are examples of some factors that may influence the selection of protective gloves for a workplace:
- Types of chemicals handled
- Nature of contact (total immersion, splash, etc.)
- Duration of contact
- Area requiring protection (hand only, forearm, arm)
- Grip requirements (dry, wet, oily)
- Thermal protection
- Size and comfort
- Abrasion/resistance requirements
Gloves are designed for many types of workplace hazards. In general, gloves fall into four groups:
- Leather, canvas, or metal mesh gloves
- Fabric and coated fabric gloves
- Chemical–and liquid–resistant gloves
- Insulating rubber gloves
It is important to select the appropriate glove for a particular application and to determine how long the glove can be worn, and whether it can be reused. Glove manufacturers have developed recommendations for the proper selection and use of chemically-protective gloves. The EHS glove selection page provides guidance on glove selection for certain classes of chemicals and common physical hazards.
- No single material can protect against all chemical, physical (e.g., cuts, abrasions, burns, temperature extremes) or biological hazards. It is critical to select the correct glove for the hazard.
- See the EHS Glove Selection web page for links to various glove manufacturers’ information for selecting gloves for chemical use.
Protective Clothing #
Protective clothing is required when handling chemical, biological or radiological materials. Protective Clothing must be laundered by a commercial company. Home laundering is not allowed.
Clothing that is grossly contaminated by over use or because of a spill should not be turned in for laundering if the contaminants include heavy metals, nanomaterials, NFPA health hazard 4 chemicals, biologically hazardous materials, or flammable solvents. In such a case, the clothing will be disposed of as hazardous waste.
Skin Protection Other Than Gloves #
Skin protection should be worn when there is a possibility of chemical splashes to the body, when the atmosphere may contain contaminants that could damage the skin or be absorbed by the skin, or when contaminants could remain on the street clothes of an employee.
Falls and Falling Object Protection #
This section does not apply to portable ladders, entertainment stages, rail station platforms, powered platforms, aerial lifts and employees inspecting, investigating or assessing workplace conditions or work to be performed prior to the start of work or after all work has been completed; unless fall protection systems or equipment have been installed and are available for workers to use.
The preferred method of fall protection in all situations is a guardrail system. When a guardrail system is not used a personal fall arrest system (PFAS) must be used.
Each employee on a walking-working surface with an unprotected side or edge shall be protected from falling by guardrail systems or personal fall protection when performing;
- Construction work 6 feet (1.83m) or more above lower levels
- All other work tasks that are 4 feet (1.2 m) or more above a lower level.
Unprotected sides and edges include but are not limited to: hoist areas, holes (skylights, hatchways, chutes etc.), dockboards, runways, stairways, wall openings and roofs.
As part of a Fall Arrest Rescue Plan, all work using fall arrest shall have at minimum, two employees on site within visual or audible contact with a means to contact emergency services. Fall protection will be used in accordance with the Walking-Working Surfaces Program in the CSP.
Harnesses, connecting devices, anchor points, and rescue plans used in personal fall arrest systems, work positioning systems, and travel restraint systems must meet the requirements of MIOSHA Part 2. Walking-Working Surfaces, 1910.140. Body belts are not to be used as part of a personal fall arrest system.
Training for Fall Protection #
Before any employee is exposed to a fall hazard, the department must provide training for each employee who uses personal fall protection. A qualified person must train each employee in at least the following topics:
- The nature of the fall hazards in the work area and how to recognize them.
- The use of hierarchy of controls to select most effective methods of fall protection.
- The procedures to be followed to minimize those hazards.
- The correct procedures for installing, inspecting, operating, maintaining, and disassembling the personal fall protection systems.
- The correct use of personal fall protection systems and equipment including, but not limited to, proper hook-up, anchoring, and tie-off techniques, and methods of equipment inspection and storage, as specified by the manufacturer.
- The proper care, inspection, storage, and use of fall protection systems and equipment.
- Retraining
- The department must retrain an employee when the supervisor has reason to believe the employee does not have the understanding and skills related to fall and equipment hazards noted above.
Respiratory Protection #
More specific information and requirements for respiratory protection are listed in the Respiratory Protection Program of the CSP.
Hearing Protection #
More specific information and requirements for hearing protection are listed in the Hearing Conservation Program in the CSP.
Electrical Protection #
Electrical PPE will be used and conform to the requirements of the Electrical Safety Program in the CSP.
6.8 Other Protective Equipment #
Floatation #
Staff working over or NEAR unguarded water hazards where there is a danger of drowning, shall be provided with US Coast Guard approved life jackets or vests. Life jackets or vests shall be inspected for defects by a competent person before each use. Defective units shall not be used. A ring buoy with not less than 90 feet of safety line shall be available for rescue operations. The distance between ring buoys shall not be more than 200 feet. Where the water hazard is large and deep, at least one lifesaving boat, equipped with an effective method of propulsion, will be available for water rescue. In situations where water hazards are guarded with guard rails, life jackets or vests are not required, however means of rescue (e.g., ring buoys, rescue boat, rescue personnel, etc.) may still be required.
Visibility #
Staff working in roads, or in close proximity to mobile equipment, shall be provided with an appropriate ANSI rated Class 2 high visibility vest. Work in roads must also conform to State regulations for traffic control. For more information on the requirements for visibility PPE and traffic control, contact EHS.
6.9 Site Specific PPE Requirements #
Construction Sites #
Employees and contractors entering onto a construction site shall don the following PPE and work attire prior to entering the site. The PPE and work attire shall be worn for the full duration of the work period/visit until the project is complete:
- Hard Hat
- Safety Glasses
- Sleeved Shirt
- Full Length Pants
- Sturdy Work Shoe or Boot
When entering a construction site that is under the control of an outside contractor, employees will be expected to comply with any contractor PPE policies that exceed this PPE Safety Program.
Laboratories #
Employees and contractors entering into a laboratory shall don the following PPE and work attire prior to entering the lab. The PPE and work attire shall be worn for the full duration of the work period/visit until the project is complete.
- All PPE listed on the lab door sign
- Safety Glasses
- Sleeved Shirt
- Full Length Pants
- Closed-toe Shoes
- Special entry requirements for a given area must also be followed. (e.g. animal housing areas, cleanrooms, etc.