Are You in Compliance with the OSHA PPE Hazard Assessment Requirements?
The Occupational Safety and Health Administration (OSHA) requires, in 29 CFR 1910.132(d)*, that all employers assess their workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer must:
- 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; and,
- Select PPE that properly fits each affected employee.
The employer must verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated, the person certifying that the evaluation has been performed, the date(s) of the hazard assessment, and that identifies the document as a certification of a hazard assessment. OSHA 29 CFR 1910.132 Appendix B provides guidance on how to perform the PPE hazard assessment.
Based on APTIM’s experience, approximately half of small and medium size industrial businesses are not aware of this requirement and have not performed the hazard assessment, which leads to an OSHA violation and subsequent citation. The hazard assessments are required for each distinct job or task. For example, separate assessments are required for welding, painting, each unique type of woodworking equipment (saws, drills, lathes, etc.), electrical work, use of forklift trucks, etc.
Many companies combine the PPE hazard assessment with a job hazard analysis (JHA), also called a job safety analysis (JSA). The JHA/JSA identifies the hazards associated with a particular job or task, determines what controls can be taken to eliminate the hazards, the PPE necessary in the interim while the controls are being implemented or if the hazards cannot be eliminated, and any safety and health training necessary for safely performing the job/task.
The following is an example of a JHA/JSA for a few tasks for an Alloy Reclaim Operator at a chemical processing plant.
The information above was provided on a form named a “Job Hazard Analysis (JHA) and Personal Protective Equipment (PPE) Hazard Assessment”. This form included a place for the name and signature of the person performing the assessment and the date of the assessment, which will comply with the OSHA requirement for identifying the document as a certification of a PPE hazard assessment. This form includes a checklist for various types of hazards for the particular job, such as general (slip, trip, falls, falling objects, rotating equipment, etc.), eye, hearing, respiratory, chemical, environmental (temperature extremes, confined spaces, etc.), electrical, material handling, fire, and ergonomic. The form also provided a space to list the PPE for each task. For example, the PPE required for the two tasks listed above were nitrile gloves, long-sleeved lab coats, shoe covers, safety glasses, and potentially respirators depending on the results of the employee exposure monitoring for lead and cadmium.
For more information on PPE hazard assessments or JHA/JSA, contact Harry Pullum, CIH, CSP, CIAQP, at firstname.lastname@example.org.
*This requirement is applicable for all states but may be a different regulation number in some states that have their own approved OSHA program. For example, the California OSHA (Cal-OSHA) regulation number is T8 CCR 3380(f).
APTIM. Expect the Extraordinary.