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Personal Protective Equipment = "any equipment or apparatus intended to be worn or held to protect one against risks to health or safety"
PPE is perhaps the most boring of all the facets of health and safety. But personal protective equipment -- while it should be the last resort in the safety controls put in place by an employer -- is, on the other hand, also our own first, personal, line of defence against the hazards we come across at work.
When things go wrong, as they do -- when that bar of steel rolls off the forklift; when those fluids spray into your face; or when that prat up there drops that spanner from the scaffolding -- what stands between you and a trip to A&E is the PPE that you've been issued and that you should be wearing.
The issues covered here are those that many of you will have encountered: no PPE being provided; PPE being provided, but as a substitute for proper controls on hazards; being charged by your employer for PPE; having to share PPE with other people; the imposition of mandatory blanket PPE; and the problem of employees who won't use their PPE.
"A fundamental principle of the British (health and safety) system is that responsibility for health and safety lies with those who own, manage and work in industrial and commercial undertakings…They must assess the risks attached to their activity and take appropriate action. Workforce involvement and in particular the work of safety representatives has made an important contribution to raising standards of health and safety in the last 25 years." - HSE, 'Occupational Health and Safety in Great Britain'
The phrase in this quote from the HSE is italicised as it is a key phrase. What it says is absolutely true, and there's an abundance of evidence to prove it. The relevance here is that Safety Reps have responsibilities with regards to PPE; responsibilities to help insure a) that their workmates are properly protected; b) that employers are providing the necessary PPE; and c) that suitable risk assessments are being done. Safety reps are also involved, unfortunately, when it comes to encouraging other employees to use their PPE.
The Personal Protective Equipment Regulations 1992 This is the regulation that puts hard hats on your heads and safety boots on your feet. The Personal Protective Equipment Regulations came in as a European Directive in 1992 and was made part of British law. The primary provision of these regulations is that "personal protective equipment is to be supplied and used at work wherever there are risks to health and safety that cannot be adequately controlled in other ways." You can make yourself more familiar with the Regulations, which are on the Internet, or you can get a summary of them in a free booklet from the HSE. Links to these are listed above.
The Management of Health and Safety at Work Regulations 1992: Provision of personal protective equipment... 4.-- (1) Every employer shall ensure that suitable personal protective equipment is provided to his employees who may be exposed to a risk to their health or safety while at work except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective.
The PPE regulations were given added support by a section of the Management of Health and Safety Regulations, which also came into effect in 1992. Note the phrase "except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective."
The Equipment Let's have a look at some of the different ways of not getting hurt at work. This equipment is the sort that should be available to every employee, where the hazards of a job or a process have been identified.
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Hearing protection against noise… earmuffs or ear defenders, which completely cover the ear…earplugs, which are inserted into the ear… semi-inserts (also called canal-caps), which cover the entrance to the ear.
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Head protection: Hard hats for protection against objects falling from heights and swinging objects. • Bump caps, designed to protect from knocking against stationary objects. • Caps and hair-nets, to protect against entanglement.
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Eye protection: Safety spectacles. Similar to regular glasses but with a tougher lens. Can include side shields for additional protection. • Eye shields. Frame-less one piece moulded lens, often worn over normal prescription glasses. • Safety goggles. Made with flexible plastic frames and elastic headband. • Face shields. Heavier and bulkier than other types of eye protector. They protect the face, but do not fully enclose the eyes, so do not protect against dusts, mists or gases.
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Foot protection: Safety boots or shoes. Normally with steel toe-caps. Can also have other safety features (e.g. steel mid-soles, slip resistant soles, insulation against heat and cold) • Wellington boots; can be supplied with steel toe-caps • Anti-static and conductive footwear. Designed to protect against the build- up of static electricity.
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Hand and arm protection: For the hands and arms, there is a wide variety of gloves and gauntlets (leather, nitrile, latex, plastic coated, chain mail, etc.), many of which should be chosen specifically for the work involved. There are also a number of gloves available to protect one from hand-arm vibration, but the evidence of the effectiveness of these gloves is still being debated. • Barrier cream
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Body protection: Overalls, aprons and coveralls... • High visibility clothing • Harnesses for heights and confined spaces • Clothing for cold, heat and bad weather • Life jackets
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Respiratory protection: Two main types -- • Respirators that filter contaminated air or clean it as you breathe in • Respirators that supply clean air from an independent source
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Respiratory protection equipment will be needed for work with harmful dusts, and harmful fumes and vapours, found in paints and in chemicals used in manufacturing processes. You'll use it in welding, in work with harmful substances, work in areas where large amounts of dust are present, and in work that generates dust, like disc cutters and sanders. Masks should be used even by men working enclosed CNC machines, to prevent inhalation of coolant spray, and the machining of cast iron should call for dust masks in a risk assessment.
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PPE Issues for Employees and Safety Reps:
• PPE But No Hazard Controls • Charges for PPE • Shared PPE • Mandatory Blanket PPE • Employees Not Using PPE
PPE But No Hazard Controls In health and safety, the hierarchy of risk control dictates that we take a number of steps to control the risks from identified hazards. In order of preference, we should first attempt to eliminate a hazard altogether. Then, try to reduce the hazard, isolate it, or, when those have failed, try to control it. The easiest way to remember this hierarchy is with the phrase "Eric PD". E - Eliminate R - Reduce I - Isolate C - Control
P - PPE D - Discipline
PPE comes fifth in this hierarchy, after all other attempts at controlling risks. Discipline can be thought of as training and "company rules". PPE is the last resort, because PPE only protects the person wearing it. Measures to control the risks at source protect everyone in the workplace. It goes without saying that PPE is essential, and in most cases, employers make PPE available. Problems arise when PPE is issued before other attempts are made to control the hazards that PPE has been issued for. PPE is used when the identified risks of a job or process cannot be adequately reduced by other means. That is, when attempts to eliminate, reduce, isolate or control the risks of a job have gone as far as they can, and further personal protection is required.
The core element of the Management of Health and Safety at Work regulations is the stipulation that employers must conduct risk assessments to evaluate hazards and implement action that will eradicate or diminish the risks arising from those hazards. The Personal Protective Equipment Regulations compliments the Management of Health and Safety at Work regulations by insisting that the need for PPE is to be determined by risk assessment.
This is where Safety Reps can help us all, because Safety Reps should be consulted about risk assessments, they should be able to see risk assessments and question them, and in the best circumstances, they should be working with their employers to formulate risk assessments.
A safety rep should ensure that his employer is conducting risk assessments for all the tasks in their workplace. Then the safety rep -- and his or her workmates -- should see that these considerations have been given to the risk assessment for a job, to ensure that the risk assessment is "suitable and sufficient". Where an assessment calls for PPE, a safety rep should be looking to see that the assessment initially attempts to control risks by means other than PPE.
Key Considerations in Risk Assessment: • Identify all the hazards of the work being done • Assess the risks for which control measures are required • Control risks by means other than PPE • Assess the requirements for personal protection needed to control residual risk • Determine the type of PPE and the performance level required • Select suitable PPE ensuring compatibility of different items
In drawing up an assessment, thought has to be given to the requirements for PPE that are needed for residual risks, for which there are no controls. For instance, while a lathe may have a guard around the revolving chuck, there is always the risk of particles of metal flying beyond the guard. The need is there for an operator to be wearing safety glasses. An operator cannot stand behind a Perspex screen, because he needs to be able to operate the machine with his hands, and lean in close to his work.
You also need to consider the type of PPE and how well it will function. Safety glasses, for example, come in various standards, and there is only one standard that is suitable for the kind of impact that is possible from a piece of metal flying out of a machine.
Finally, a good assessment needs to ensure that each item of PPE being used for a job is compatible with any other PPE that's been decided on. Without this compatibility, it's possible to have someone trying to wear safety glasses that won't fit over a dust mask. Obviously, you can't wear a hard hat over a set of over-the-head ear defenders. So, a little thought has to go into making the right choices for compatibility. These last three items for consideration are not just handy tips, but are requirements of the Personal Protective Equipment Regulations.
Remember that The Management of Health and Safety at Work Regulations states: "Every employer shall ensure that suitable personal protective equipment is provided to his employees… except where and to the extent that such risk has been adequately controlled by other means which are equally or more effective."
Many employers are happy to comply with the first part of this requirement, but seem to completely lose sight of the last part of it. Safety Reps have to be on their guard with an employer who is generous with PPE, while not having done all he can in introducing proper controls.
Does your employer issue masks for protection from a chemical, without giving consideration to changing the way the job is done, or to finding a less hazardous substitute for the chemical? All your welders may have welding masks -- but do they work behind welding screens, so that other employees and visitors aren't 'flashed' by the hazardously intense light from a welding arc? Is Local Exhaust Ventilation installed, to carry welding fumes away from the immediate work area and out of the workshop?
Charges for PPE Under the general requirements of the Health and Safety at Work Act, employees cannot be charged for either the provision or the maintenance of PPE. No ifs, ands or buts. Employees cannot even be charged for the laundering of uniforms or boiler suits. If any employees wear prescription glasses or contact lenses, their safety glasses will have to be by prescription as well, and they cannot be charged those.
Shared PPE Shared PPE? Is anyone being expected to share PPE with other people at work? Apparently, it does happen. The first 'P' in PPE stands for Personal. So -- what part of the word 'personal' does this employer have trouble understanding?
The Health and Safety (Miscellaneous Amendments) Regulations 2002 has amended the Personal Protective Equipment Regulations to say: "(4) Where it is necessary to ensure that personal protective equipment is hygienic and otherwise free of risk to health, every employer and every self-employed person shall ensure that personal protective equipment provided under this regulation is provided to a person for use only by him."
If you have a situation like that, that's the Regulation to draw to your employer's attention.
Mandatory Blanket PPE This is a policy concept that is spreading, causing quite a few problems on job sites, and a fair amount of controversy amongst health and safety professionals. This is where your employer issues everyone with a bundle of PPE and makes it obligatory to wear it all the time, wherever you are in the workplace or on a site.
One view credits such employers with being conscientiously pro-active. Another view is that it amounts to little more than lazy health and safety management, because PPE is being widely distributed and used as the first resort, instead of spending the necessary time and money to carry out proper risk assessments and establish good risk controls.
If a policy of mandatory blanket PPE is being established at your workplace, try to ensure that you are properly consulted about it, as is your right as a Safety Rep. It is an issue that should be brought before the safety committee. Where you might have objections to the scheme, raise them at the committee. Ask why it is being brought in, particularly if you know that there are gaps in the risk assessment system. Raise the possibility of attempting to reduce hazards in the workplace by other means, reminding the committee that PPE is the last resort.
Where you believe it is valid, point out the potential for the introduction of new hazards. Are people having to wear goggles or safety glasses in the rain? Are ear defenders preventing people from hearing reversing vehicles? Are the wrong type of gloves impairing someone's dexterity and adding to the potential for an accident?
Get your questions put into the minutes of the safety committee meeting, and ask to have it 'minuted' that in your opinion the company is by-passing the recognised hierarchy of controls, and in doing so, could actually find itself in breach of the law. Express the opinion and try to get it in writing, so that there is evidence of it for the future.
The eradication of hazards, proper training and supervision beats PPE every time. PPE has its place -- very much so -- but it should be used for the purpose it was intended.
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Employees Not Using PPE It's one thing to be thoughtlessly forced to wear PPE that is uncomfortable, makes a job more difficult, or introduces new hazards. It is quite another for someone to flaunt their total disregard for their own safety and that of people around them.
Some of our colleagues don't like "rules"…They have a sense of rebellion, a sense of individuality -- which is a healthy thing. But rebellion, or individuality, when it infringes other people's rights, or puts other people in danger, is not healthy for any of us. The people who got health and safety laws put into place in Britain, and through those laws got PPE for everyone -- they were rebels. It wasn't some wonderful government of do-gooders who one day just decided that we should have some rights at work -- it was working people just like you, who argued, organised and went on strike, and got killed, in the struggle to get laws put into place to protect us, and to give us a voice, through our unions and through our safety representatives. And fortunately, for us, those rebels beat the 'system' -- they won. The laws to make work safer for all of us are in place, and we should take advantage of them.
PPE is our right, a right that other working people fought to get for us, one that a lot of people throughout the world wish they had. In the United States, in 1999, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) finally proposed a rule requiring employers to pay for protective clothing, face shields, gloves and other equipment used by U.S. workers. But before the proposal became a standard Mr. Bush was elected to office. Since then, the U.S. Department of Labor has neglected to enact the standard. Many workers in America's most dangerous industries, including meatpacking, poultry, and construction, who have high rates of injury, are still forced by their employers to pay for their own safety gear. According to OSHA's own figures, 400,000 workers have been injured and 50 have died owing to the lack of the PPE rule. Since only 14% of U.S. workers belong to a union, we can imagine they'll be waiting a lot longer for PPE that they don't have to buy for themselves.
Very occasionally, an employee will have a legitimate medical reason that prevents them from using standard PPE. Ear infections, for example, will preclude the use of in-ear hearing defenders. Employees can also refuse to wear PPE if it puts their safety at risk. (PPE of the wrong size could put one at risk because of it's poor fit). Employees in such cases should ask a manager or the firm's safety representative for PPE of the correct size.
When employees simply won't use PPE, though, they create several problems: • They are violating company policy. Section 10 of the Personal Protective Equipment at Work Regulations 1992 states that "every employer shall take all reasonable steps to ensure that any personal protective equipment provided to his employees... is properly used." So the employer has a legal duty to ensure that PPE is used, and this is reflected in the company's policy. Discipline procedures could be initiated. • They are violating health and safety regulations. Employees also have a legal duty under Section 10 to use equipment provided for them as instructed. The Management of Health and Safety at Work Regulations also dictate that employees must use any equipment or substance in accordance with any training or instruction given by the employer. The legal position here is that the failure of employees to comply with the requirements of health and safety law could lead to dismissal under misconduct. • If they are injured at work and prescribed PPE was not in use, a claim for compensation will fail or a judge will reduce the amount of compensation payable, due to the employee's contributory negligence.
While it is never up to you as a Safety Rep to act as a policeman for management, you may find yourself in the awkward position of having to encourage co-operation with company policy. You may have to deal with colleagues whose attitude is one of 'two fingers to the boss', or who think they prove their manliness by daring the forces of nature and the fickle finger of fate.
If you decide to 'poke your nose in', you might try a little reverse psychology. There's nothing 'manly' about being driven to A&E by the first-aider. Being injured in a game of rugby is one thing -- daring a machine to hurt you, and losing, impresses no one. There's nothing manly about having your bum wiped by a nurse while you're laying in a hospital bed, because you thought it was "wuss" to wear a hi-vis vest.
In consultation with management or through your safety committee, consider: • Has there been enough information and training for employees, to stress the importance of PPE and to teach them how to use it? • Is it possible to have better supervision on site to enforce the wearing of PPE? • Is there adequate and appropriate signage on site where PPE should be worn? • Is adequate storage provided for workers to store their PPE on site? (a legal requirement) • Is there a periodic safety rep/management inspection on which PPE-wearing can be ticked? • Has anyone asked employees why they are not wearing PPE?
Don't Give the Finger to PPE! A good friend of mine was working on his car two years ago and he wasn't wearing any gloves. (Well, you don't, do ya?) He cleaned up and he scraped some black grease out from under his nails. A few weeks later, he noticed that a nail was separating from the skin beneath it. He went to the doctor, and the doctor cut the nail, to let it grow back. Instead, this growth appeared:
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The doctor removed the growth. And it came back. The doctor removed it a second time. (And that couldn't have been very pleasant! The finger was painful to use, and my friend is an electrician, so that finger was always in use!) And then -- you guessed it -- it came back for a third time. A year had passed since the work on the car.
He was sent to various specialists and finally saw one specialist who referred him to an RAF consultant for a second opinion. It was then confirmed that the growth was cancerous, but fortunately, not the type that spreads. He was then booked in for an operation. If the growth was not attached to bone, the nail would be taken off and a skin graft would be applied to the end of his finger. If the growth was on the bone, he would have to lose the first joint of his finger. In the operation, the growth was dug away and the bone was scraped. A wedge of flesh was then cut from the foreman and grafted into place on the end of the finger.
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This is the finger just after the bandages were removed, with the skin graft in place. My friend was off work for three weeks after the surgery, and of course he has to take good care of this finger, and it is constantly painful. The position at present is that the biopsy results were not clear -- abnormal cells were still present at the edge of the incision. He has yet another appointment with a plastic surgeon, and if the surgeon is not happy with what he sees, the tip of the finger will be removed.
All this, for not having worn a pair of thin gloves that would have kept the grease out of his nails.
Please -- Use your PPE and encourage your workmates to always use theirs!
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