Hygiene
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Course Learning Outcomes for Unit VIII
Upon completion of this unit, students should be able to:
7. Evaluate types of hazard controls. 7.1 Discuss the use of personal protective equipment (PPE) for controlling occupational hazards.
Reading Assignment
To access the following resources click the links below:
Occupational Safety and Health Administration. (n.d.). Personal protective equipment. Retrieved from https://www.osha.gov/SLTC/personalprotectiveequipment
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Personal protective equipment (Standard No. 1910.132). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9777
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Personal protective equipment (Standard No. 1910.134). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=12716&p_table=STANDARDS
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Personal protective equipment (Standard No. 1910.133). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9778&p_t ext_version=FALSE
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Personal protective equipment (Standard No. 1910.135). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9785
Occupational Safety and Health Administration. (1970). Safety and health regulations for contruction: Personal protective and life saving equipment (Standard No. 1926.100). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10663
Course/Unit Learning Outcomes
Learning Activity
7.1
Unit VIII Lesson Article: “Personal protective equipment” Article: “Occupational safety and health standards: Personal protective equipment (Standard No. 1910.132)” Article: “Occupational safety and health standards: Personal protective equipment (Standard No. 1910.133)” Article: “Occupational safety and health standards: Personal protective equipment (Standard No. 1910.134)” Article: “Occupational safety and health standards: Personal protective equipment (Standard No. 1910.135)” Article: “Safety and health regulations for contruction: Personal protective and life saving equipment (Standard No. 1926.100)” Unit VIII Essay
UNIT VIII STUDY GUIDE
Hazard Controls – Personal Protective Equipment
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Unit Lesson
The lowest level of control method in the Occupational Safety and Health Administration’s (OSHA’s) Hierarchy of Controls is personal protective equipment (PPE). OSHA lists PPE as the least effective control method and requires employers to reduce the risks associated with workplace hazards to an acceptable level before they use PPE as the primary control method.
The reason OSHA rates PPE as the least effective control method is very simple. PPE does nothing to reduce the level of the hazard in the workplace because it is not addressing the source of the problem; that only comes through elimination or substitution. Engineering controls reduce the level of the hazard in the workplace by diluting or removing airborne levels of chemicals, blocking noise at the source, or blocking radiation along the pathway of exposure. Some administrative controls also reduce the concentration of a hazard in the air (wet methods), while others reduce the amount of time an employee is exposed to the hazard. PPE does not remove the hazard from the work area, does not reduce the concentration of a hazard in the air, and does not reduce the amount of time an employee is exposed to a hazard. PPE is designed to reduce exposures to hazard by reducing the exposure at the exposure site (e.g., skin, lungs, or eyes).
One major problem with the use of PPE as a control method is that not all employees use it consistently. Manufacturers design PPE to be used in a specific manner, and the effectiveness of it is tested, typically in a laboratory setting under ideal conditions. Unfortunately, the PPE design is rarely used by employees under conditions that mimic the laboratory testing. This results in actual protection factors that are lower in the workplace than in the laboratory.
A good example of the lower effectiveness of PPE in the workplace is hearing protective devices such as earplugs. Earplugs are tested in a laboratory setting to determine a Noise Reduction Rating (NRR). Ideally, an NRR of 30 would mean that the earplugs would reduce the level of noise by 30 dBA. Because there are differences between the laboratory testing and real-world use, a value of 7 must be subtracted from the published NRR to account for differences. Therefore, the NRR of 30 would be reduced to 23. This would mean you would expect to reduce noise levels by 23 dBA at the employee’s ear. However, OSHA tells their compliance officers working in the field to cut the level in half (50%) when evaluating earplug ratings. This reduction is recommended because of the differences in inserting and wearing earplugs by individuals. Using this method, the NRR of 30 would be reduced to 11.5. The same problems exist for other PPE such as respirators and safety glasses.
Some PPE is more related to industrial hygiene hazards while others are more related to safety hazards. For example, respirators reduce exposures to chemical hazards, chemical protective gloves reduce dermal exposures, safety glasses reduce physical hazards from striking the eyes, and hard hats reduce the risk of hazards striking the head. In practice, PPE must be an integrated program providing protection from hazards associated with both industrial hygiene and safety. This will require cooperation between industrial hygienist and safety professionals at a facility. In some cases, one individual works as both the industrial hygienist and safety officer, making the process easier. In this unit, we will focus on PPE associated with industrial hygiene hazards. These include respirators, hearing protection, and chemically protective clothing.
Respiratory protection is probably the PPE most commonly associated with industrial hygiene. Respiratory protection is often used (and misused) in occupational settings. There are two main ways employers misuse respiratory protection.
A factory worker wears protective gear while welding a pipe together for assembly. Image by Hortlander, is licensed under CC BY 2.0 (Hortlander, 2011)
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First, they use respirators for protection as the primary control method without trying to reduce the risk associated with a hazard using the Hierarchy of Controls. This can be a costly mistake. With a hazard present at levels that require respiratory protection, employees can be harmed if they do not wear the respirator properly or if someone enters the area without donning a respirator. This is why OSHA requires the employer to use the control methods in the Hierarchy of Controls to reduce the risk associated with a hazard as low as possible before using respiratory protection as the primary control method. OSHA requires employers to have a written hazard assessment/risk assessment whenever respiratory protection is used.
The other common mistake that employers make concerning respirators is just the opposite of the first one discussed above. They plan to implement control methods to reduce risks associated with hazards to a level where respiratory protection would no longer be needed; however, they forget to (or choose not to) use respirators during the interim when the controls are being implemented. Some of the control methods may take weeks, months, or even years to implement, and employees will be exposed to unacceptable levels of the hazard during that interim, with potentially harmful effects. OSHA requires respiratory protection to be used in the interim when controls are being implemented if it is required to protect employees from exposures to hazardous levels.
Implementing and maintaining a respiratory protection plan can be complicated and expensive depending on the size of the operation, the number of employees required to use respiratory protection, and the types of respirators to be used. The respiratory protection standard 29 CFR 1910.134, which is one of your required readings in this unit, summarizes the requirements for an OSHA-acceptable program. Note the difference between required use and voluntary use. Voluntary use of respirators requires a much less detailed program than required use.
Chemically protective clothing is used to reduce dermal exposures to chemicals. This is especially important for chemicals that can cause serious harm through the dermal route. Chemically protective clothing includes gloves, boots, aprons, sleeves, and ensembles as defined by the EPA. For compounds with established OSHA PELs, these chemicals are marked with a skin notation in the OSHA tables. The most important task in selecting the appropriate chemically protective clothing is determining if the material in the chemically protective clothing is compatible with the chemical hazard in the workplace.
If the material in the chemically protective clothing is not compatible with the chemical hazard in the workplace, breakthrough (and dermal exposure) can occur in a matter of minutes. For example, if employees using methyl ethyl ketone wear gloves made from natural rubber, breakthrough will occur after only about 5 minutes. If the employees wear gloves made from a laminate film, breakthrough will not occur for over 480 minutes. How to choose the correct material for chemically protective clothing is an important function of the industrial hygiene. Most manufacturers publish a chart that shows the compatibility of their product with common chemicals used in occupational settings.
In some cases, chemically protective clothing and respiratory protection are used in combination to protect employees. The most commonly used examples are those defined by the EPA (n.d.). There are four basic levels of ensembles (labeled A through D) under the EPA definitions. Each level combines a self-contained breathing apparatus (SCBA) with a completely enclosed chemical and vapor protective suit. Level A is used when the highest level of respiratory protection is required, and the chemical(s) can cause serious harm through dermal exposure. Level A is used for emergency spill response. Level B is used when the highest level of respiratory protection is required, and the chemical cannot cause serious harm through dermal exposure. Level C is used when some respiratory protection is required, and the chemical cannot cause serious harm through dermal exposure. Level D is used when no respiratory protection is required, and the chemical cannot cause serious harm through dermal exposure. There are many variables when choosing the level of protection. OSHA Standard 29 CFR 1910.134 lays out what conditions require the use of a specific
Tennessee-1 Disaster Medical Assistance Team member Jayson (“Jay”) Jones provides medical care to search and rescue personnel recovering victims from the rubble of a 2010 earthquake in Haiti. (National Institute for Occupational Safety and Health, 2013)
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Hearing protection is another type of PPE commonly used in occupational settings. OSHA Standard 29 CFR 1910.95 contains OSHA’s general requirements for the use of PPE in controlling noise exposures. There are two basic types of hearing protection: earplugs and earmuffs. Earplugs insert into the auditory canal, and
earmuffs go over the ears and the auditory canal. Earplugs are more commonly used in occupational settings. Where noise levels are extremely high, double hearing protection of both earplugs and earmuffs may be a solution. As with other PPE, the effectiveness of hearing protection varies from manufacturer to manufacturer and model to model.
The effectiveness of hearing protection devices is measured using the NRR. The NRR was established by the EPA in 1979 with testing performed in accordance with American National Standards Institute (ANSI) standard S3.19-1974. Several problems have developed related to the NRR. First, employers typically have a difficult time understanding how to use it. Many employers simply choose the hearing protection device with the highest NRR; however, different employees will have
different experiences with the fit of an earplug, which can reduce effectiveness. Comfort must also be taken into account when choosing a hearing protection device. For this reason, some employers will give their employees two or more choices. To address these issues, ANSI recently released a new standard for testing hearing protectors (ANSI, 2016).
Hearing protection is one variable in an effective hearing conservation program. OSHA Standard 29 CFR 1910.95 contains a summary of the requirements for an effective OSHA-compliant hearing conservation program.
References
American National Standards Institute (ANSI). (2015). Methods for measuring the real-ear attenuation of hearing protectors. Retrieved from https://wwwn.cdc.gov/PPEInfo/Standards/Info/ANSI/ASAS1262016
Environmental Protection Agency. (n.d.). Personal protective equipment. Retrieved from https://www.epa.gov/emergency-response/personal-protective-equipment
Hortlander. (2011, April 15). Welder [Photograph]. Retrieved from https://www.flickr.com/photos/hortlander/6245707871/in/photolist-avUTmt-J4XQfP-7eG6LX-2L9DGq- xThfp-7k9tC-9js4cs-rtnCr5-4ZCmcj-JhD7-9sB2uq-5Y1ccQ-5XW4tM-5Y1c5A-5GVFt3-crr7A-5Y1cLw- 5XVVPt-sqVqY-5Y1cEJ-5Y1bKh-5XVVGa-5Y1cQ1-5XVY1v-5E6cZE-5ZUMF2-fDJDyc-JfUfW-d
National Institute for Occupational Safety and Health. (2007). PPE for spraying truck bed liners [Photograph]. Retrieved from https://www.flickr.com/photos/niosh/8867470001/in/album-72157633509527694/
This photo shows the personal protective equipment (PPE) needed when spraying truck bed liners. (National Institute for Occupational Safety and Health, 2007)
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National Institute for Occupational Safety and Health. (2013). Medical care [Photograph]. Retrieved from https://www.flickr.com/photos/niosh/8743414931/in/photolist-aCJ32L-ejChDi-f6gjgU-ejHWDd-ejHXdh- 4Ndh3K-fEsPqU-qbsUS4-oHanWm-k2hgaV-wHBuFu-vbFSEo-KmcPQM-KSJMm4-Ky7SBd
Suggested Reading
To access the following resources, click the links below:
OSHA published a checklist that can be very helpful for establishing an effective PPE program. The following link will connect you to that checklist.
OSHA Office of Training and Education. (n.d.). PPE assessment. Retrieved from https://www.osha.gov/dte/library/ppe_assessment/ppe_assessment.html
OSHA will periodically publish fact sheets on topics to summarize requirements for employers in a concise manner. The following link is to OSHA’s fact sheet on PPE.
Occupational Safety and Health Administration. (2006). Personal protective equipment [Fact sheet]. Retrieved from https://www.osha.gov/OshDoc/data_General_Facts/ppe-factsheet.pdf
OSHA published a pocket guide specifically discussing protection against noise hazards in construction.
Occupational Safety and Health Administration. (2011). Worker safety series: Protecting yourself from noise in construction [Pocket guide]. Retrieved from https://www.osha.gov/Publications/3498noise-in- construction-pocket-guide.pdf
OSHA requires the use of PPE to protect the feet whenever there is the potential for objects to fall on or roll over the feet and cause harm. OSHA regulates PPE for the feet in 29 C.F.R. 1910.136 (general industry) and 29 CFR 1926.96 (construction).
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Personal protective equipment (Standard No. 1910.136). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9786
Occupational Safety and Health Administration. (1970.). Safety and health regulations for construction: Personal portective and life saving equipment (Standard No. 1926.96). Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10659&p_table=STANDARDS