Question: As an employer, I understand that I need to provide personal protective equipment (PPE) for my workers to protect them from hazards. However, I believe the workers are abusing PPE use. We currently have PPE vending machines where employees place their badge number into the machine and get equipment. Some employees are using multiple pairs of safety glasses per day. The money we spend on PPE is higher than ever, and I think it’s because workers are using too much. We seem to be caught between the obligation to provide PPE and how to control the usage of it. Do you have any suggestions?
Answer: This is a problem that many companies face. While you are required to provide certain types of PPE at no cost to employees, it is very easy for workers to take advantage. Fortunately, the Occupational Safety and Health Administration (OSHA) offers guidance on what to do in this situation:
The employer must pay for replacement PPE, except when the employee has lost or intentionally damaged the PPE [1910.132(h)(5)].
I don’t think this will be the case, but if your employees can show that they need multiple pairs of safety glasses (or other items) per day because their glasses become damaged as a direct result of the work they are doing — not because they lost them, intentionally tossed them on the ground or didn’t take care of them — then you’d need to provide them with the amount of PPE they need.
If they actually do need this much PPE, you should consider reviewing processes and looking for an engineering or administrative control to limit how much PPE they need. Or you might need a different style of safety glasses or other PPE. If your workers are truly going through multiple pairs a day, the style they have may not fit the task.
Has this issue been addressed in training? Are the employees aware that you (the employer) aren’t responsible for purchasing PPE that is lost or intentionally damaged? If not, make it part of a toolbox talk or part of your next safety training.
Many companies with this issue have a written policy that states that the employee has to pay for lost and intentionally damaged PPE. The policy also states how the PPE is to be paid for (payroll deduction, physical bill mailed to them, etc.). You might want to consider developing a similar policy. If your workers are unionized, include the union representative in the discussion and any policy development. Many times, union reps aren’t aware of this part of the regulation.
You should also keep track of who is using what and how much. This will help you determine if it is an isolated event with certain employees or widespread throughout your company. The representative who stocks your vending machines should be able to tell you each employee’s PPE usage.
If it’s an individual or small group of workers who are using too much, you can pull them aside and explain that while OSHA requires their employer to provide PPE, the employer does not have to pay for replacements when it is intentionally lost or damaged. Also provide them with a “sample bill” of what their cost will be if they continue with their current PPE usage and have them acknowledge in writing that they are aware of this. If they continue to be forgetful, bill them for overages.
Alternatively, you might be able to set up your vending machine to only allow a certain number of products to be dispensed per person. So if you can generally expect people to go through a pair of safety glasses every month or two months, their badge could set a specific amount they get in a certain time period. Add a note to the machine that says “If your card doesn’t work see (name),” and that person can review PPE usage with the employee.
Note of caution: Depending upon your company’s safety culture, when confronted about PPE usage, some workers may take the “I just won’t wear any PPE” attitude. This, of course, will need to be something that is closely monitored by supervisors to ensure that everyone is properly protected.