Purpose and Scope
To formalize a Departmental policy regarding the selection and use of personal protective equipment. This Standard Operating Procedure (SOP) will assist PFD to comply with the provisions outlined in the Occupational Safety and Health Administration (OSHA) Personal Protective Equipment (PPE) standard, 29CFR, Subpart 1. PPE alone should not be relied on to provide protection against hazards, but should be used in conjunction with engineering controls. The four areas covered under this SOP are: (1) eye and face protection; (2) head protection; (3) foot protection; and (4) hand protection.
Policy
The Physical Facilities Department of Miami University is firmly committed to provide each employee a safe and healthy work environment. To meet this commitment, the following mandatory SOP has been established by PFD in accordance with the requirements of Ohio's Public Employment Risk Reduction Program (PERRP).
Responsibilities
Supervisors and affected employees have primary responsibility to ensure that their employees are properly protected and trained in the use of PPE. Assessments shall be performed using sound judgment and appropriate expertise to determine the extent and degree of hazard created by specific tasks. Steps for determining hazard potential are outlined later in this SOP. Any employee who willfully violates or disregards provisions of this policy may be subject to disciplinary action as specified by University policy.
The Environmental Health and Safety Office (EHSO) shall be responsible for providing assistance to supervisors in performance of safety assessment and providing recommendations for appropriate PPE selection.
Procedures
Safety Assessment Procedure: To assist PFD in conducting the safety assessment, the attached form, which outlines task, hazard, and appropriate PPE, shall be used. The following steps shall be used to determine PPE needs:
- Identify Hazard: The first step in the safety assessment process involves a walk-through survey of the areas in question. The purpose is to identify sources of hazards to workers. Supervisors shall identify the type and nature of hazards, which may be present as a result of a particular task. The hazards categories to be considered include:
- Compression (roll-over)
- Penetration
- Impact
- Chemical
- Biological
- Heat
- Electrical
- Dust
- Light (optical) radiation
The supervisor's observations during the walk-through survey should include the following: (a) sources of motion; (b) sources of high temperature; (c) types of chemical exposure; (d) sources of light radiation; (e) sources of falling objects; (f) sources of sharp objects; (g) sources of rolling or pinching objects; (h) layout of the workplace; and (i) any electrical hazards. In addition, injury/illness data should be reviewed.
- Determine risk: The second step in the safety assessment process involves the analysis of data gathered during the survey of the workplace. Using the outlined variables applied to the Risk Assessment Matrix (figure 1), a determination of actual risk can be applied to the task. Probability: Use the following to help determine the likelihood of a mishap occurring, based on hazard exposure:
- Frequent - Occurs often or repeatedly and is continously experienced
- Likely - Occurs several times or on a predictable basis
- Occasional - Will occur but not on a predictable basis
- Seldom - May or may not occur but can be expected to occur at some point in time
- Unlikely - Probability is extremely low. The event will not occur or occurs very rarely
- Severity - The anticipated outcome of the mishap can be measured using the following:
- Catastrophic - Death
- Critical - Severe injury or occupational illness
- Moderate - Minor injury or illness
- Negligible - Less than minor injury or illness
Selection of PPE: Once the supervisor has identified and documented the hazard, the appropriate PPE must be selected. The Environmental Health and Safety Offices will make final determination of the appropriate types of PPE. The type of PPE selected must ensure a level of protection greater than the minimum required to protect employees from the hazards. The PPE selected will be documented on the same form used during the safety assessment.
Figure 1, Risk Assessment Matrix
Based on the Risk Assessment Matrix, personal protective equipment would be required when Risk Levels are extremely high, high, or medium. In the case of foot protection, safety shoes will be provided when risk levels are extremely high or high. Toe-caps will be provided when risk levels are in the medium category. Toe-caps will be available in the Tool Room or in the shop.
Training: The OSHA standard requires that the employer provide annual training to each employee who is required to wear PPE during the course of his or her work activities. The Environmental Health and Safety Offices can perform this training. Specifically, 29 CFR 1910.132 (f) contains the following minimum training requirements:
- When is PPE necessary
- What PPE is necessary
- How to properly don, doff, adjust, and wear PPE
- The limitations of PPE
- The proper care, maintenance, useful life and disposal of PPE
In addition, the affected employee must demonstrate an understanding of the above-mentioned training, and the ability to use PPE properly, before being allowed to perform work requiring the use of PPE. To verify that each worker has received and understands this training a written certification is required to be maintained by the employer. Employees must be retrained when there is reason to believe that the employee does not have the understanding and skill required in the initial training. Circumstances where retraining is required include changes in work place, changes in type of PPE used, or inadequacies in an affected employee’s knowledge or use of assigned PPE.
Use and Care: Employees are required to provide care and maintenance of PPE. Equipment shall not be worn for activities away from work, other than to and from work (i.e., safety shoes).
Issue and Replacement of Equipment: Before any employee is allowed to engage in activities requiring the use of PPE, the employee shall be provided equipment in good repair and free from defects. Additionally, the employee shall attend the aforementioned training and be knowledgeable of the contents of this SOP.
PPE will be replaced or repaired on an “as needed” basis as determined by the manager or supervisor of the shop. Shoes will not be replaced more frequently than once per calendar year, except in the case of documented on-the-job damage or deterioration. Managers and supervisors will ensure that replacement is made in a timely manner.
Related Documents, Forms, and Tools
Attachment: Safety Assessment
Revision History