OSHA standards require that employers provide a workplace that is free from recognized hazards that are likely to cause death or serious physical harm to their employees. 29 CFR § 1903.1. One means of protecting workers is the use of Personal Protective Equipment (PPE). The use of PPE is covered under both the General Industry Standard, 29 CFR § 1910, and Construction Standard 29, CFR § 1926.
University Policy 4.12 provides that the University is to provide PPE as necessary to all faculty, staff and student employees, including part-time and/or temporary employees. Employees are required to utilize appropriately the PPE prescribed by the university
This PPE program is intended to be a university wide program for departments lacking their own departmental PPE program. This program is written to comply with OSHA standards and UNI Policy.
Departments are encouraged to develop their own PPE program to meet their unique operational needs. Any departmental program must meet OSHA standards, university policy and be approved and monitored by Environmental Health and Safety (EH&S). EH&S can provide assistance to any department looking to create its own PPE program.
The objective of the Personal Protective Equipment program is to protect employees from the risk of injury by creating a barrier against workplace hazards. Personal protective equipment is not a substitute for good engineering or administrative controls or good work practices, but should be used in conjunction with these controls to ensure the safety and health of employees. Personal protective equipment will be provided, used, and maintained when it has been determined that its use is required and that such use will lessen the likelihood of occupational injury and/or illness.
This program addresses eye, face, head, foot, and hand protection. A separate program exists for respiratory protection.
The UNI Personal Protective Equipment Program includes:
- Responsibilities of supervisors, employees, and EH&S
- Hazard assessment and PPE selection
- Employee training
- Recordkeeping requirements
Supervisors have the primary responsibility for implementation of the PPE Program in their work area. This involves:
- Conducting workplace hazard assessments to determine the presence of hazards which necessitate the use of PPE.
- Providing appropriate PPE and making it available to employees.
- Ensuring employees are trained on the proper use, care, and cleaning of PPE.
- Maintaining records on PPE assignments, hazard assessments and PPE training.
- Ensuring defective or damaged equipment is immediately replaced
- EH&S can assist supervisors as requested in meeting their responsibilities under this program.
The PPE user is responsible for following the requirements of the PPE Program:
- Wearing PPE as required.
- Attending required training sessions.
- Caring for, cleaning, and maintaining PPE as required.
- Informing the supervisor of the need to repair or replace PPE.
Environmental Health and Safety (EH&S)
EH&S is responsible for the development, implementation, and administration of the PPE Program. This involves:
- Assisting with periodic workplace reassessments as requested by supervisors or as determined by EH&S.
- Providing training and technical assistance to supervisors on the proper use, care, and cleaning of approved PPE.
- Providing guidance to the supervisor for the selection and purchase of approved PPE.
- Reviewing, updating, and evaluating the overall effectiveness of the PPE Program.
Hazard Assessment and Equipment Selection
Under 29 CFR 1910.132(d)(1) OSHA requires employers to conduct inspections of all workplaces to determine the need for PPE and to help in selecting the proper PPE for each task performed. For each work site, a certificate must be completed which lists the findings of the inspection and the specific protective equipment needed.
Traditional Classrooms, Office Spaces, Conference Rooms, Lounges, and Congregational Spaces
EH&S has conducted a hazard assessment for all traditional classrooms, office spaces, conference rooms, lounges, and congregational spaces on campus.
EH&S has determined that no PPE is required in these areas when they are being used as designed in normal conditions. On occasion tasks being completed in these areas may require PPE.
A copy of this certification has been provided, Certification of Hazard Assessment - Traditional Classrooms, Office Spaces, Conference Rooms, Lounges, and Congregational Spaces.
All Other Spaces
Each supervisor will conduct a walk-through survey of each work area to identify sources of hazards, including impact, penetration, compression, chemical, heat, dust, electrical sources, material handling, and light radiation. Each survey will be documented using a Certification of Hazard Assessment, which identifies the workplace surveyed, the person conducting the survey, findings of potential hazards, and date of the survey.
Once the hazards of a workplace have been identified, the supervisor will determine the suitability of the PPE presently available and as necessary select new or additional equipment which ensures a level of protection greater than the minimum required to protect the employees from the hazards.Care will be taken to recognize the possibility of multiple and simultaneous exposure to a variety of hazards. Adequate protection against the highest level of each of the hazards will be provided or recommended for purchase. EH&S is available to assist in these areas.
All personal protective clothing and equipment will be of safe design and construction for the work to be performed and shall be maintained in a sanitary and reliable condition. Only those items of protective clothing and equipment that meet NIOSH (National Institute for Occupational Safety and Health), ASTM (American Society of Testing and Materials) or ANSI (American National Standards Institute) standards will be procured or accepted for use. Newly purchased PPE must conform to the updated standards which have been incorporated into the OSHA PPE regulations, as follows:
- Eye and Face Protection - ANSI Z87.1-1989
- Head Protection - ANSI Z89.1-2009
- Foot Protection – ASTM F-2412-2005
- Hand Protection - There are no ANSI standards for gloves, however, selection must be based on the performance characteristics of the glove in relation to the tasks to be performed.
Careful consideration will be given to comfort and fit of PPE in order to ensure that it will be used. Protective devices are generally available in a variety of sizes. Care should be taken to ensure that the right size is selected.
Eye and Face Protection
29 CFR 1910.133 requires that all persons who may be in eye hazard areas wear protective eyewear. This includes employees, visitors, contractors, or others passing through an identified eye hazard area. To provide protection for these personnel, supervisors of such areas shall procure a sufficient quantity of goggles and/or plastic eye protectors which afford the maximum amount of protection possible. If these personnel wear personal glasses, they shall be provided with a suitable eye protector to wear over them.
Suitable protectors shall be used when employees are exposed to hazards from flying particles, molten metal, acids or caustic liquids, chemical liquids, gases, or vapors, bioaerosols, or potentially injurious light radiation.
- Wearers of contact lenses must also wear appropriate eye and face protection devices in a hazardous environment.
- Side protectors shall be used when there is a hazard from flying objects.
- Goggles and face shields shall be used when there is a hazard from chemical splash.
- Face shields shall only be worn over primary eye protection (safety glasses or goggles).
- For employees who wear prescription lenses, eye protectors shall either incorporate the prescription in the design or fit properly over the prescription lenses.
- Protectors shall be marked to identify the manufacturer.
- Equipment fitted with appropriate filter lenses shall be used to protect against light radiation. Tinted and shaded lenses are not filter lenses unless they are marked or identified as such.
Prescription Safety Eyewear
OSHA regulations require that each affected employee who wears prescription lenses while engaged in operations that involve eye hazards shall wear eye protection that incorporates the prescription in its design, or shall wear eye protection that can be worn over the prescription lenses (i.e. goggles, face shields) without disturbing the proper position of the prescription lenses or the protective lenses. Personnel requiring prescription safety glasses must contact their Administrative Office to have their request for prescription safety glasses evaluated and processed.
Emergency Eyewash Facilities
Emergency eyewash facilities will be provided in all areas where the eyes of any employee may be exposed to corrosive or caustic materials. All such emergency facilities will be located where they are easily accessible in an emergency.
29 CFR 1910.135 requires that head protection will be furnished to, and used by, all employees engaged in activities where there may be hazards from falling or fixed objects.
29 CFR 1910.136 says safety shoes shall be required as necessary for all full-time, part-time, temporary employees and students identified as needing foot protection. This type of protection shall be required if the work necessitates lifting or carrying dense, rigid articles or equipment; operating machinery that presents a hazard of foot injury; or constantly traversing areas where such activities take place.
All safety footwear shall comply with ANSI Z41 PT 1999, “American National Standard for Personal Protection-Protective Footwear.” Safety shoes must be kept in good condition and replaced when worn beyond repair.
29 CFR 1910.138 requires suitable gloves be worn when hazards from chemicals, cuts, lacerations, abrasions, punctures, burns, biologicals, and harmful temperature extremes are present. Glove selection shall be based on performance characteristics of the gloves, conditions, durations of use, and hazards present. One type of glove will not work in all situations.
Cleaning and Maintenance
It is important that all PPE be kept clean and properly maintained. Cleaning is particularly important for eye and face protection where dirty or fogged lenses could impair vision. PPE should be inspected, cleaned, and maintained at regular intervals so that the PPE provides the requisite protection. Personal protective equipment shall not be shared between employees until it has been properly cleaned and sanitized. PPE will be distributed for individual use whenever possible.
It is also important to ensure that contaminated PPE which cannot be decontaminated is disposed of in a manner that protects employees from exposure to hazards.
29 CFR 1910.132(f) requires any worker required to wear PPE shall receive training in the proper use and care of PPE. Periodic retraining shall be offered to both the employees and supervisors, as needed. The training shall include, but not necessarily be limited to, the following subjects:
- When PPE is necessary to be worn.
- What PPE is necessary
- How to properly don, doff, adjust, and wear PPE.
- The limitations of the PPE.
- The proper care, maintenance, useful life and disposal of the PPE.
After the training, the employees shall demonstrate that they understand the components of the PPE Program and how to use PPE properly, or they shall be retrained.
29 CFR 1910.132(d)(2) requires written records be kept of the Hazardous Assessment Certification Form. Original records shall be kept by the department for at least three years. Copies of the records should be sent to EH&S.