After visiting a handful of facilities, you develop a routine. Empty your pockets. Put on your steel-toed shoes. Pull loose hair back. Remove jewelry. Grab the hard hat, photo ID and a couple of business cards from your bag in the back seat of the car. Stop at the front desk and review the company’s safety video. Don whatever site-specific personal protective equipment (PPE) is required and/or provided by your host.
Because PPE is so, well, personal, it’s easy to see why many people perceive it as the primary line of defense against workplace safety hazards. The boxes and bins of ear plugs, safety glasses, booties and gloves are likely to be the first thing you see when you enter a production area. It’s a mainstay in those spiffy new safety vending machines that seem to be popping up everywhere. You see everyone in the facility wearing it, so it must be important, right?
Yes, PPE is important. When the correct types are chosen, worn and used, PPE absolutely helps to save lives and reduce the risk of injury or illness. But, in OSHA’s hierarchy of risk controls, PPE is actually the last line of defense against workplace safety risks. Four other forms of protection need to take precedence over choosing and using PPE. Here’s a look at how OSHA expects you to prioritize:
1. Elimination
When processes and procedures are being analyzed for risks, it is important to look for ways to eliminate the risk entirely. If you are able to eliminate a risk, you don’t need to create a process or procedure to avoid it.
Of control methods, eliminating a hazard is the most desirable and effective method of control. However, it is often the most difficult to implement – especially for processes that already exist at a facility
2. Substitution
Substitution means replacing the process or item that causes a hazard with one that does not. For example, replacing a solvent-based degreaser with a citrus-based degreaser is a substitution that reduces air emissions and is typically less harmful to employees and the environment. When considering substitution methods and products, it is important to review them thoroughly to ensure that they do not create new hazards.
3. Engineering Controls
Several workplace safety regulations, such as the ones listed below, require engineering controls as the first line of defense against hazards. Often, these controls can be worked into the design of the equipment or process. They can also take the form of barriers, guards or enclosures.
• Hazard Communication [29 CFR 1910.1200, 29 CFR 1926.59]
• Lockout/Tagout [29 CFR 1910.147]
• Respiratory Protection [29 CFR 1910.134]
• Confined Space Entry [29 CFR 1910.146]
• Blood borne Pathogens [29 CFR 1910.1030]
• Hearing Conservation [29 CFR 1910.95]
• Laboratory Chemical Hygiene [29 CFR 1910.1450]
Engineering controls are usually permanently installed. Because an employee’s safety does not rely on him/her remembering to do or wear something, they are considered the best option for managing safety hazards or risks.
4. Administrative Controls
Standard operating procedures and established safe work routines are two forms of administrative controls. Although they are not typically installed like engineering controls, administrative controls document processes that a company will follow to eliminate hazards and/or minimize employee exposure.
Administrative controls can also include what some might consider “creature comforts” like taking frequent breaks when working in extreme heat or cold and rotation of job functions. Although they may seem superfluous, these activities do serve a safety function. Scheduling downtime for preventative maintenance and performing routine inspections can also be directly tied to safety controls because they minimize the chance for malfunctions that could put employees at risk for injury or death.
5. PPE
When engineering and administrative controls aren’t enough to keep employees safe, the balance of the safety load falls on PPE. Although PPE is a form of protection, it presents its own challenges.
First: it has to fit correctly to be effective. A good example of this is respiratory protection. If you can’t get a good seal, it’s not going to work well. In some cases, the employee might be able to use a hood instead of a tight fitting face piece, but that’s a discussion for another day.
Second: it has to be worn. Yes, you can get a pair of safety glasses for less than two dollars – but if they’re not comfortable, they fog up when the weather is hot and no one wants to wear them. Spending a little bit more on a pair that feels better and doesn’t fog up is probably a good use of safety funds -even on a super tight budget. Same thing goes with ear plugs, safety shoes and all of the other things employees need to wear every day.
Third: it has to be removed from service when it has passed its prime. Nothing lasts forever – especially PPE. A frayed fall harness, safety shoes with smooth soles, glasses with severely scratched lenses and gloves with holes are all examples of PPE that needs to be replaced immediately.
Fourth: it has to be understood. Employees need to know about hazards in their workplace. They also need to really understand how to use and take care of any PPE that they’ve been issued so that it is truly effective and provides that last line of defense against a safety risk.
Eliminating hazards and substituting less hazardous products are not always possible. Retrofitting machines with engineering controls can be expensive. Administrative controls take time out of production schedules. Getting everyone to wear their PPE can be a pain. But, when these three elements come together, the chance of injuries, illnesses and death can be eliminated.
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