Are You in Compliance with OSHA Hazard Assessment Requirements for PPE?

A lot of effort goes into maintaining the safety of your employees. Undoubtedly, all the effort is worthwhile because a safe company is also a successful one. By keeping your company’s workplace injury and accident-free, productivity can proceed without interruptions, quality can be emphasized, and no incident response-related expenses or costs are incurred. However, maintaining a healthy and safe work environment is not just the right thing to do, it is also the law. 

PPE Hazard Assessment Compliance

Per the Occupational Safety and Health Administration (OSHA) standard, 29 Code of Federal Regulations (CFR) 1910.132(d)(1), the employer must assess the workplace to determine if hazards are present or likely to be present that necessitate the use of personal protective equipment (PPE).

If such hazards are present or are likely to be present, the employer must proceed with the following:

  • Select, and have each affected employee use the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment

  • Communicate selection decisions to each affected employee

  • Select PPE that properly fits each affected employee

Employers often provide PPE to employees without first conducting a hazard assessment, assuming everything will be fine. Unfortunately, it is not that simple. The hazards must be identified, and the appropriate PPE must be determined for each hazard based on its effectiveness in protecting the employee. Also, the PPE must fit accordingly, and the employee must be trained on its proper use, maintenance, and storage.

Employee training on PPE must include:

  • When PPE is necessary

  • What PPE is necessary

  • How to properly don, doff, adjust, and wear PPE

  • The limitations of the PPE

  • The proper care, maintenance, useful life, and disposal of the PPE 

Who should perform the hazard assessment?

Performing hazard assessments on all operations within a facility can be both challenging and time-consuming. This is especially the case with larger facilities that have complex operations. Hazard assessments should be completed by an experienced safety professional who is knowledgeable and familiar with all the means to protect the eyes, head, hands, feet, face, body, hearing, and breathing. No room for error should exist because employees rely on these assessments to keep them safe.

What are the written certification requirements?

OSHA requires employers to verify that the required workplace hazard assessment has been performed through a written certification that identifies the following:

  • Workplace evaluated

  • The person certifying that the evaluation has been performed

  • Date(s) of the hazard assessment

  • Document as a certification of hazard assessment

Is PPE enough to protect employees?

PPE should be looked at as a last option for protecting employees. There are other controls that must be looked at first as a solution. It is never a best practice to just automatically wear PPE without first trying to accomplish the following:

  1. Eliminate the hazard

  2. Substitute for something less hazardous or non-hazardous (if applicable)

  3. Install engineering controls

  4. Implement administrative controls

After first identifying the operational hazards, the safety professional conducting the hazard assessment should determine the appropriate PPE and provide standard step-by-step procedures for safe operation. The level of risk for each step should also be evaluated, and recommendations for hazard elimination and substitution, as well as engineering and administrative controls, where applicable, should be implemented.


KERAMIDA can provide you with peace of mind and an effective means of complying with this regulatory requirement. Take the first step in scheduling a workplace hazard assessment by submitting our quick response form or calling (800) 508-8034 to speak with one of our experienced safety professionals today.


Author

Andrew Tirmenstein
Senior Project Manager, Risk, Health and Safety Services
ISO 45001 & ISO 14001 Auditor
KERAMIDA Inc.

Contact Andrew at atirmenstein@keramida.com.