Section 3 Personal Protective Equipment (PPE) Program

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1 International Environmental Health and Safety (IEHS) Section 3 Personal Protective Equipment (PPE) Program 3.1 Objective The PPE Program has been developed for IEHS and other project employees working on site, under contract to IEHS, who in the course of their work will be exposed to hazards requiring the use of PPE including, but not limited to the following: Hard hats Safety glasses, goggles, face shields High visibility vests Protective gloves Hearing protection Protective footwear Personal fall arrest equipment Respirators The following information provides direction and guidance to Site Safety Team with implementation of IEHS s PPE Program. 3.2 Roles and Responsibilities Competent Person The competent person is responsible for establishing appropriate PPE levels and providing PPE to their companies employees. Subcontractors will determine who will serve as their competent person and provide the required level of PPE for their employees. The competent person will also: Assist the Site Safety Team in reviewing and approving all IEHS and subcontractor PPE utilization. Performing program audits and inspections in conjunction with on-site IEHS subcontractor site H&S representatives or their designees. Copyright ISM 2013

2 3.3 General Requirements PPE includes different types of protective equipment and clothing, such as gloves, safety glasses/goggles, safety shoes/boots, shoe/boot covers, hard hats, coveralls, and respirators. In general, the following PPE is the minimum required on all IEHS project sites: ANSI-rated hard hats ANSI-rated safety glasses with side shields ANSI-rated steel- or safety-toed boots which, at a minimum, cover the ankle ANSI rated, high-visibility reflective vests or outerwear. All body areas (except for face, neck, ears and arms from 4 over shoulder sleeve to top of glove) must be covered by clothing and additional PPE as required by PTP (welding/arc gauging leathers, gloves, knee pads, etc.) PPE will be provided, used, and maintained in a sanitary and reliable condition for hazards involving processes or the environment to protect body parts from inhalation, absorption, or physical contact. At no time will defective or damaged PPE be used by IEHS employees. IEHS Employer will provide initial and replacement PPE to its affected employees at no cost to the employee. To ensure compliance with applicable regulations, only IEHS-issued or approved PPE will be used. Job Safety and Environmental Assessment Selecting the correct type of PPE for the nature and extent of known or potential site hazards is critical. In an effort to comply with the OSHA s PPE standard, IEHS s PTP Program addresses required PPE for each job function and task. The PTP is developed from identified H&S hazards and an initial risk analysis. The PTP must be reviewed and approved by both the work supervisor and Site Safety Team or subcontractor H&S representative daily prior to site work commencing. The following is a brief outline of basic PPE and examples of potentially hazardous conditions where each item is required to be used: Hard Hats Hard hats are required at all times while on the project site, except when in a control room, trailer or fully enclosed cab of motor vehicles. Hard hats subjected to an impact due to a falling object must be inspected for damage prior to re-use. Damaged hard hats will be taken out of service and a replacement provided by the Site Safety Team. 3-2 Copyright ISM 2013

3 Safety Glasses/Goggles/Face Shield Safety glasses protect the eyes from flying particles, such as metal and abrasive particles generated during grinding, chipping, and blasting operations. Safety goggles provide additional protection from chemical splashes in places where corrosive and other liquid chemicals are being dispensed, handled, transported, or used. Face shields also provide additional protection for the eyes and face when used with safety glasses or goggles. Safety eyewear should be free of scratches and cracks. Defective or damaged eyewear should be taken out of service until it can be repaired or replaced. The Site Safety Team will provide non-prescription safety eyewear when deemed necessary. Safety glasses (visibly marked ANSI Z87.1) with rigid side shields are the minimum level of eye protection to be worn whenever eye/face PPE is required. Double layer eye/face protection (face shield and goggles or safety glasses) is required whenever there is a potential of a projectile injury (placing concrete through a high pressure hose, grinding, cutting with chopsaw, jackhammering, chipping cutting concrete (dry or wet) or using high pressure air for cleaning purposes). Goggles shall be maintained in a serviceable condition and replaced when needed. Instruct workers to have a co-worker assist them and to use care when removing eye/face protection, hard hats and other PPE. After PPE is removed, the worker s hands and face shall be thoroughly washed to remove metal grindings and other material from the forehead, face, eyelashes, eyebrows, eyelids and hands. During burning operations, employees shall wear safety glasses with No. 5 or darker lens and a face shield. Protective Footwear Employees are required to wear steel- or safety-toe, cut and slip resistant boots with a defined, notched heel (not greater than 2 ) which extends high enough to cover the employee s ankle. 3-3 Copyright ISM 2013

4 Ear Plugs Generally, ear plugs are used when exposures are fairly constant (i.e., during operations near noisy engines or equipment running constantly). Ear plugs typically have a noise reduction rating (NRR) of 29 or less. Ear plugs are the most commonly used hearing protection due to their affordability and ease of use. Ear plugs may also be required to protect against foreign bodies entering the ear canal. Ear Muffs Ear muffs are advised in situations where intermittent and higher-decibel exposures are present (i.e., jackhammer work, power-actuated tool use). Ear muffs generally have an NRR of Ear muffs are provided where work procedures with specific, high impact sound exposures are common. Site Safety Team will provide ear muffs to IEHS employees exposed to this level of noise. Note: Subcontractors shall provide hearing protection appropriate to their employees based on their employees work exposures. Earmuffs: NRR Derating Manufacturers will offer the NRR as tested for their PPE. This number should not be used as is. NRR are not tested in actual work situations; therefore, the National Institute of Safety and Health (NIOSH) recommends that the labeled NRRs be derated as follows: Foam earplugs and custom molded earplugs: All other earplugs including semi-inserts: Subtract 25 percent from the manufacturer s labeled NRR Subtract 50 percent from the manufacturer s labeled NRR Subtract 70 percent from the manufacturer s labeled NRR For example, measure noise exposure levels in dba with a sound level meter or noise dosimeter, the effective A-weighted ENL (exposed noise level) is: ENL = dba - (derated NRR -7) When the noise exposure level in octave bands is known, the noise exposure level in dbc is calculated and then the ENL is: ENL = dbc - derated NRR 3-4 Copyright ISM 2013

5 Gloves Gloves protect hands from injury due to abrasive surfaces, heat, or contact with chemical substances that can cause chemical burns or skin absorption. Glove types selected are based on the type(s) of substance present and the task performed. As required by the PTP program, each job function and task required for a project must be evaluated to identify the hazards associated with executing the scope of the work. Gloves shall be worn by IEHS employees working on site who are engaged in project tasks that are determined to have potential hand exposures to physical, chemical, and/or biological hazards. The selection and use of gloves for protection against physical, chemical, and/or biological hazards are based on the following criteria: Physical Employees involved in tasks that could potentially expose them to abrasion, laceration, contusion, and/or heat hazards shall be protected through the use of thick leather gloves. In addition, employees involved with project tasks that are determined to have a high laceration hazard (such as sheet metal forming) shall be protected through the use of cut-proof/cut-resistant gloves. Chemical Employees involved in tasks that have been identified as chemical hazards shall be protected through the use of chemical-resistant gloves. Biological Employees involved in tasks that have been identified as having microorganism hazards shall be protected through the use of latex gloves. OSHA Bloodborne Pathogens final rule mandates wearing gloves in specified circumstances to reduce the risk of exposure to bloodborne pathogens. In addition, the following procedures from the Centers for Disease Control and Prevention (CDC) shall be utilized: Wash hands thoroughly and promptly after contact with blood, body fluids, secretions, excretions, equipment, and potentially contaminated articles. Wearing gloves does not replace the need for hand washing. Gloves may have small, non-apparent defects or may be torn during use, and hands can become contaminated during removal of gloves. Gloves must be changed between contacts, and hands should be washed after gloves are removed. 3-5 Copyright ISM 2013

6 Respirators Respirators are to be selected, used, and maintained in accordance with IEHS s Respiratory Protection Program. Fall Protection Equipment Fall protection devices and equipment shall be provided and used whenever unprotected work above six feet is to be done. Refer to IEHS s Fall Protection Program for details pertaining to types of equipment and situations for their use. 3.4 Training All IEHS employees will receive training during site-specific orientation regarding IEHS s requirements involving the hazards associated with all work. In addition, all employees will be trained regarding how PPE usage correlates with their work duties. Before performing work requiring the use of selected PPE, each affected IEHS employee will be trained to understand at a minimum the following: When PPE is necessary; 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. Retraining of an employee is required when changes make previous training obsolete; changes in types of PPE occur; or when the employee demonstrates lack of use, improper use, or insufficient skill or understanding of PPE. Employees who are required to wear fall protection or respiratory protection shall receive sitespecific training above and beyond the general site-specific orientation. This training will be provided or coordinated by the Site Safety Team. 3.5 Audits and Inspections Weekly inspections/audits of PPE utilization and compliance with established guidelines will be conducted by the Site Safety Team, listed competent person(s), subcontractor s H&S representative or their designees, as outlined in IEHS s H&S Inspection/Audit Program. These inspections/audits shall be documented in the project files and deficiencies shall have timely corrective action measures defined. The auditor will be responsible for ensuring that corrective measures are met within the established time frame and must report any non-compliance to the 3-6 Copyright ISM 2013

7 PM for immediate follow up including, but not limited to, disciplinary action as outlined within IEHS s H&S Discipline Program for the affected individuals. All PPE shall be visually inspected daily by the user prior to use. This inspection is not required to be documented; however, potential defects in PPE shall be brought to the competent person s attention and the equipment shall be removed from service until it can be determined if it is safe to use. Unsafe equipment will be removed from service, destroyed, and replacement equipment will be provided to the employee. 3.6 Documentation All PPE training, implementation audits, equipment inspections and subcontractors documentation of the same shall be maintained by the Site Safety Team in the project file on site throughout the life of the contract and transmitted to the project files for storage when the work has been completed. Records of non-compliance (personal and company) shall be maintained in the associated employee s or subcontractor s files for the duration of the project. 3-7 Copyright ISM 2013