Personal Protective Equipment. Wyandotte Reviewed: 12/13 Effective: 01/14 Supersedes: 12/12 Preparer: Owner: Approver: Site PPE Program Coordinator
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1 Procedure No.: WYN Page: 1 of 18 Preparer: Owner: Approver: PPE Program Coordinator PPE Program Coordinator EHS Hub Manager Revision History Revision Date Revision Number 12/ / / Added section Details of Change Added Revision History. Reformatted standard for P&PO requirements. Definition 2.4. updated for Corporate language. Added sections and to be consistent with Corporate standard. Updated for current procedure. Removed hyperlinks from section 6. Removed requirements in References provided back to WYN
2 Procedure No.: WYN Page: 2 of PURPOSE To set forth site requirements at the BASF Corporation Wyandotte, Michigan ( Wyandotte ) site necessary to comply with BC , Personal Protective Equipment and the State of Michigan s Regulations (Part 433 Rules). This procedure addresses requirements for: Workplace PPE hazard assessment. PPE selection, fit, use, cleaning, inspection, maintenance and storage. Employee training and communication of requirements. 2. DEFINITIONS 2.1. FLAME RESISTANT (FR) A term used to describe material that burns slowly or is self-extinguishing after removal of an external source of ignition. For garments used for arc flash protection, clothing must contain a label with information required by ASTM F1506, including a statement that the garment meets the F1506 performance specification, care instructions, fiber content and the Arc Rating NATURAL FIBER Fibers of cotton, silk, and wool not treated to be flame resistant PENETRATION Flow of chemical through zippers, stitched seams, pinholes or imperfections in protective equipment PERMEATION Process by which chemicals move through protective clothing material on a molecular level by adsorption, diffusion and desorption PERSONAL PROTECTIVE EQUIPMENT (PPE) Equipment worn to protect the eyes, face, head, hearing, lungs, body and extremities from injury or illness due to chemical exposure or physical hazards SITE PPE PROGRAM COORDINATOR The Coordinator shall be qualified by appropriate training or experience, which is commensurate with the complexity of the program elements they will oversee, to administer the PPE activities. The PPE Program Coordinator for Wyandotte is Derek Hetes, EHS Specialist III.
3 Procedure No.: WYN Page: 3 of SCOPE Applies to all personnel working at or visiting the Wyandotte site. 4. PROCEDURE 4.1. GENERAL REQUIREMENTS BASF will provide required PPE for use by employees. BASF employees working at remote locations shall only use PPE provided by BASF. Contracted employees will be provided required PPE by BASF Contractor management is responsible for providing the necessary PPE for use by their employees Vendors and visitors will be provided PPE upon entry into the site that is appropriate for the environment they are expected to encounter. For these cases, units will maintain an adequate supply of "visitor" type glasses and hardhats HAZARD ASSESSMENT A hazard assessment must be performed by each unit to determine the need for and proper selection of PPE. The hazard assessment is a written certification that identifies: The workplace evaluated. The person certifying that the evaluation has been performed. The date of the hazard assessment. The document as a certification of hazard assessment (MIOSHA Part 433 Rules R (2) A reassessment of hazards is necessary whenever there are changes in the workplace (e.g., new processes or different process materials) or changes in work practices, to determine the suitability of previously selected PPE or if additional PPE is required All units are to document their PPE Hazard Assessments using an approved site template (See Section 6. Related Documents).
4 Procedure No.: WYN Page: 4 of PPE SELECTION FACTORS Personal protective equipment shall be selected for the environment in which it is to be used, according to the following factors: Exposure potential to chemical and/or physical hazards Potential effects of exposure to the chemical and/or physical hazards Body region of potential exposure (hands, face, chest, arms, respiratory system) Permeation or penetration potential for the protective equipment Limitations caused by use of the PPE (reduction in sight, hearing, dexterity) Field conditions such as temperature, humidity and abrasion, cutting or tearing potential Anticipated use (single versus repetitive use and duration of use) Past experiences or incidents Regulatory requirements Service life and cost 4.5. GENERAL USE AND INSPECTION PRE-USE INSPECTION Each item of equipment or clothing must be inspected prior to use for defects such as missing or defective parts, imperfect seams, soil, tears, scratches, stiffness, distortion, discoloration, cracks, pinholes, etc PPE that does not pass inspection shall be immediately repaired (where appropriate), sent for repairs to comply with the original manufacturer s specifications, or discarded. If defective PPE is encountered, it should be reported immediately to supervision DONNING For protective clothing, all closures should be secured and checked. The fit of the PPE shall be evaluated for comfort and user movement.
5 Procedure No.: WYN Page: 5 of Employees must wear properly sized PPE. Using alternative sizes will compromise the fit and permit harmful leakage; e.g., an improper sized hearing protector will permit noise penetration to the inner ear The manufacturer s instructions for donning PPE must always be followed to ensure proper fit FIELD USE While performing a work task, PPE shall be inspected periodically by the user. Particular attention must be paid to developing tears, punctures, discoloration, stiffness and weakening of material during use Personnel must follow appropriate work/rest schedules and keep adequately hydrated while working in full-body encapsulating chemical protective suits and Arc Rated flash suits Protective clothing and equipment that may contain residual contamination must not to be worn into offices, control rooms, lunchrooms, clean change rooms, etc., where the contamination can spread, exposing non-protected personnel DOFFING (REMOVAL) The main objective of the removal process is to avoid personal exposure to contaminants that may be on the surface of the PPE. PPE must be removed in a manner that prevents skin contact or inhalation of the contaminant, or contamination of personal clothing DECONTAMINATION AND DISPOSAL PPE decontamination and disposal procedures must be developed, as appropriate Contaminated equipment and clothing must be secured in drums or other containers and labeled properly.
6 Procedure No.: WYN Page: 6 of STORAGE PPE must be stored properly to prevent damage or malfunction from exposure to dust, moisture, sunlight, damaging chemicals, extreme temperatures, insects, sharp edges and impact EYE AND FACE PROTECTION GENERAL REQUIREMENTS AND SAFETY GLASSES The appropriate eye and face protection must be worn if there is potential for eye or facial injury from flying particles or windblown objects, molten materials, liquid chemicals, acid/caustic or other corrosive liquids, chemical gases or vapors, light radiation or electrical hazards Safety glasses with side shields will be the minimum eye protection worn in areas where there is potential for eye injury. Safety glasses with side shields must meet the specifications of the current version of US/ANSI Z Additional eye protection (e.g., goggles, full-face respirator, etc.) will be required when working in environments with exposure to gas, vapors or particulates exceeding an exposure limit (Ceiling limit, TWA, or STEL) Safety glasses must be worn properly and maintained in good, clean condition. Attachment to hard hats or other adaptation is prohibited Conductive safety glasses (e.g. metal frames) are not allowed when performing electrical work as defined in WYN Each Unit must provide non-prescription safety glasses available for BASF employees, temporary workers and visitors as necessary and cleaning tissues and/or cleaning stations as needed Tinted lenses on safety glasses excluding photochromatic lenses are prohibited for indoor use and may only be used in outdoor applications.
7 Procedure No.: WYN Page: 7 of PRESCRIPTION SAFETY GLASSES The following procedure applies to purchase/repair of prescription safety glasses: CONTACT LENSES Procedure 1 The employee downloads form off Wyandotte InfoWeb/ Forms page, completes and submits for authorization to N Diem, EHS Admin. (BASF allows one pair per year or following a prescription change.) 2 The employee takes form to designated provider and pays for examination, special fitting or any personal modification. The examination may occur at the eye specialist of the employee s choosing. 3 Appointments are to be made by the employee at their own convenience. 4 Repairs to prescription safety glasses for which BASF incurs costs will require approval. 5 Photochromatic or transition lenses ("photograys") are allowed; however, require a Supervisor s prior approval Contact lens use is prohibited on site except in office areas and as described below Soft contacts are allowed in Research and Application areas under the conditions outlined in Chapter 5 of the R&D Safety Manual Medical exception to the contact lens restriction in other areas is allowed on a case-by-case basis by joint opinion of the unit management, EHS, the Medical Department and the employee's physician Visitors to the manufacturing areas may be allowed to wear contact lenses depending on the nature, duration and location of the visit (ex. tour, etc.) at the unit s discretion Personnel wearing contact lenses should provide, and have available, saline solution for use at work when needed. They should also have eyeglasses available.
8 Procedure No.: WYN Page: 8 of Contact lenses may not be handled nor solutions applied in areas where contact with chemical or physical hazards may be possible Any accident/incident report involving an eye injury must note if the person was wearing contact lenses at the time of the incident BASF will not be responsible for the replacement of lost or damaged contact lenses for any reason Personnel who wear contact lenses shall be trained in the requirements of this section. This training must be provided initially before wearing in hazardous locations or upon employment, and periodically thereafter GOGGLES/FACE SHIELDS/PROTECTIVE HOODS Appropriate protection for splash, spray, heat, or other special hazards for the eyes and face must be worn, based on the written hazard assessment Eye and face protection (chemical goggles and shield) shall be worn when there is a potential for splashing or spraying of corrosive or skin-absorbing toxic chemicals into the eyes or face Chemical goggles must meet requirements for impact protection required by the current version of US/ANSI Z87.1. Primary eye protection need not be worn under protective hoods or full-face respiratory devices that meet requirements for impact protection Face shields or protective hoods that do not meet impact standards, must be used only in conjunction with safety glasses that do meet standards for protection against impact When chemical goggles are in use for eye protection, the headband of the goggles must be placed directly on the head and not retained on a hard hat or other retention device, unless the device to which they are attached is secured to the head.
9 Procedure No.: WYN Page: 9 of Safety glasses or goggles that meet impact requirements shall always be used with Arc Rated flash suit hoods worn for selected electrical tasks. Safety glasses or goggles meeting US/ANSI Z87.1 impact protection requirements shall always be worn under the Arc Rated face shield or hood WELDING PROTECTION Personnel engaged in welding-type operations, where light radiation may cause injury to the eyes, must use eye protection with lenses that have the appropriate shade number for the work being performed. Personnel adjacent to the welding operations, such as helpers that could also be affected by the light radiation, must also wear eye protection with the appropriate shade number Personnel performing welding-type operations must wear a welding helmet to shield the face from light radiation and impact. If the welding helmet does not meet impact requirements, safety glasses or goggles that do meet impact requirements must be worn under the helmet RESPIRATORY PROTECTION Units at the Wyandotte site with respirator users are required to have a written program that complies with the following: Provisions of Section 4.7. of BC , Personal Protective Equipment, and Requirements contained in WYN , Respiratory Protection Standard (see Section 6. Related Documents) HEAD PROTECTION GENERAL REQUIREMENTS Hardhats shall be worn in areas, based upon the hazard assessment, when there is reasonable potential for injury to the head from falling objects and/or electrical shock. Unit management will designate those areas or activities requiring hard hats.
10 Procedure No.: WYN Page: 10 of The minimum head protection shall be a Type 1, G hardhat. Type 1 reduces the force of a blow to only the top of the head. G classification provides general electrical protection; good for low voltage conductors Use of bump caps is prohibited on site Hardhats shall be worn as intended, with the brim toward the front unless necessary because of interference with other protective equipment; e.g., welding hoods Hardhats shall be inspected regularly for proper suspension, cracks or other imperfections and replaced when required. Avoid excessive stickers and never paint hard hats as this may disguise imperfections. Do not store in direct sunlight as this can deteriorate the material. Hard hats shall not be altered by drilling holes, cutting or other methods that may compromise the integrity of the head protection Hardhats that become damaged or have defective parts must be replaced immediately SELECTION All hardhats must meet the specifications of the current version of US/ANSI Z89.1. Hardhats constructed of aluminum alloy shall not be used MOTORCYCLE HEAD PROTECTION 4.9. FOOT PROTECTION Motorcycle operators must wear DOT-approved helmets. Industrial hard hats are not to be worn to meet this requirement GENERAL REQUIREMENTS Protective footwear must be worn in areas where there is danger of foot injury due to falling or rolling objects, penetration of the sole or electrical hazards. The material of construction must be appropriate for the hazards of the work area. The heel must be the full width of the shoe. Tapered or elevated heels are not permitted.
11 Procedure No.: WYN Page: 11 of Visitors who spend limited time in the plant areas, are not required to wear safety shoes, however, open-toed shoes, sandals, high heels, or cloth-top shoes are prohibited Canvas shoes, open-toed shoes, or sandals are prohibited in laboratories. Shoes that cover the whole foot shall be worn and they must be made of a material that prevents rapid penetration of chemicals Contractors must wear appropriate leather, work shoes as minimum foot protection. Shoe selection depends on work requirements (i.e. Iron workers require shoes suitable for walking on steel beams) BASF employees working in manufacturing units will be furnished with one pair of safety shoes and $40.00 off on two additional pairs each year Shoe forms can be obtained from Wyandotte Infoweb and must be signed by the Supervisor Unit management shall determine if Electrostatic Discharge (ESD) shoes are required Employees requiring specially constructed shoes must contact EHS SELECTION All protective footwear issued must meet the specifications of the current version of ASTM F HAND PROTECTION AND CHEMICAL PROTECTIVE CLOTHING GENERAL REQUIREMENTS Hand safety is a key focus at the Wyandotte facility. All employees and visitors are expected to practice good judgment with respect to hand hazard recognition when on site including the carrying of cotton gloves for use with handrails or other work surfaces. All employees are encouraged to take appropriate action if they spot an unsafe condition as long as
12 Procedure No.: WYN Page: 12 of 18 those actions are in accordance with unit specific PPE requirements. Visitors to a unit shall be instructed not to touch or operate any equipment or handle chemical containers unless proper gloves are worn in accordance with unit specific PPE requirements Hand and body protection shall be selected and used when there is a potential for exposure to such hazards as: Skin absorption of harmful substances Substances that are known skin sensitizers Cuts, lacerations, abrasions, or punctures Chemical or thermal burns Harmful temperature extremes Electrical Hazards The PPE hazard assessment will be used to determine when hand and body protection is required. Each unit shall use an effective means to communicate the hand and body protection requirements for respective job tasks requiring such protection. (See Section 6. Related Documents) Latex gloves shall not be used, except where there is no other material of construction that is suitable to protect against the hazard. The use of latex gloves on site shall be reviewed and approved by EHS. A unit must meet the following requirements, in order, to implement latex glove use: Provide reduced protein, powder-free NRL gloves. Provide affected employees with training about latex irritations and allergies, as well as appropriate housekeeping and hygiene practices. Alert employees using NRL gloves to report signs and symptoms immediately, if they occur. Utilize protective measures to minimize skin contact with the latex material; e.g., using a double layer of gloves with the NRL glove on the outside Protective clothing must be worn as designed by the manufacturer; i.e., all zippers and flaps closed and design must not be altered.
13 Procedure No.: WYN Page: 13 of SELECTION Selection of appropriate hand and body protection must be based upon: Manufacturer's recommendation Breakthrough time Permeation rate Degradation and physical durability requirements Comfort and ergonomic considerations Dexterity and tactility requirements Decontamination (re-usable v. disposable) Value CHEMICAL PROTECTIVE SUITS INSPECTION, MAINTENANCE AND STORAGE FOR EMERGENCY RESPONSE USE Level A encapsulating suits must be inspected and have an inflation test upon receipt, after each use that it is not disposed of and at a minimum annually thereafter The exhaust valve diaphragm on Level A suits must be inspected after each use and at a minimum once per year. The diaphragm shall be replaced at least every two years from date of manufacture All other chemical protective suits shall be inspected prior to use, after each use that it is not disposed of and, at a minimum, annually thereafter. Documentation, as applicable, shall be maintained on all Level A suits including inspections, pressure tests, diaphragm inspections and diaphragm replacements using a unique identifier for each suit All chemical protective suits intended for use during emergency response incidents shall be maintained in a ready to use status and designated for emergency use only Clothing must be stored properly to prevent damage or malfunction from exposure to dust, moisture, sunlight, damaging chemicals, extreme temperatures, insects, sharp edges and impact.
14 Procedure No.: WYN Page: 14 of HEARING PROTECTION Units at the Wyandotte site with employees who are required to participate in a Hearing Conservation Program shall comply with the following: Provisions of Section of BC , Personal Protective Equipment, and Requirements contained in WYN , Hearing Conservation Program (See Section 6. Related Documents) PROTECTIVE CLOTHING FOR ELECTRICAL TASKS Units at the Wyandotte site with employees who are required to wear protective clothing and equipment for performing electrical tasks shall comply with the following: Provisions of Section of BC , Personal Protective Equipment, and Requirements contained in WYN , Electrical Hot Work (See Section 6. Related Documents) CLOTHING FOR FLASH FIRE PROTECTION GENERAL REQUIREMENTS Each unit shall use the hazard assessment process to evaluate the work environment to determine the requirement for personnel to wear flame-resistant garments Factors in determining if flame-resistant garments are required shall include, but not be limited to, the following: Proximity of the work to be performed to a hazard presenting a flash fire hazard The presence of flammable materials (vapors or dust) in the environment during process operations The potential for the task being performed to increase the possibility of a flammable release Operating conditions of the process The presence of engineering controls designed to reduce exposure to flammable materials present during normal operations Accident history
15 Procedure No.: WYN Page: 15 of SELECTION FALL PROTECTION Guidance for evaluating the need for flame resistant clothing to protect personnel from potential flash fires is provided in the BASF Flash Fire FRC Assessment Tool, based on NFPA 2113, Standard on Selection, Care, Use, and Maintenance of Flame-Resistant Garments for Protection of Industrial Personnel Against Flash Fire and the American Chemistry Council s, A Manager s Guide for Assessing Flame-Resistant Clothing (See Section 6. Related Documents) Units at the Wyandotte site with employees who are required to wear fall protection shall comply with the following: Requirements contained in WYN , ELEVATED WORKING SURFACES (see Section 6. Related Documents) UNIT REQUIREMENTS When PPE is required, each unit must develop and maintain standard procedures to address the general PPE requirements for routine operations and also the PPE for specific environments (including emergency situations) Each operating unit with employees who are required to wear PPE must address the following elements: PPE hazard assessment certification. Procedures that communicate the appropriate PPE to be used by employees and when it is to be used. (See Section 6. Related Documents for a site approved template which provides a means to communicate PPE requirements to employees.) The unit program coordinator has the responsibility to review and revise the unit written procedures, as necessary, when process changes occur that render current PPE inadequate or incomplete Any significant changes in PPE requirements necessitated due to use of new chemical that is a corrosive, skin absorbable or has a published Immediately Dangerous to Life and Health (IDLH) concentration below
16 Procedure No.: WYN Page: 16 of TRAINING 100 ppm must be made in consultation with the PPE Program Coordinator INITIAL TRAINING Employees must receive training prior to being assigned work involving the use of PPE. PPE training must include instruction on the following: When PPE is necessary What PPE is necessary How to properly don, doff, adjust, wear, and inspect PPE Function and limitations of the PPE, including conditions that affect PPE effectiveness Procedures for proper care, maintenance, useful life and disposal or decontamination (where applicable) The site policy on the use of contact lenses DEMONSTRATION OF UNDERSTANDING GENERAL REQUIREMENTS A. Each affected employee required to wear PPE must demonstrate an understanding of the training before being allowed to perform work requiring the use of PPE. The demonstration may include showing competency or a written evaluation WRITTEN CERTIFICATION A. The unit must verify that each affected employee who is required to wear PPE has received and understood the necessary training through a written certification upon initial assignment or whenever conditions of Section are met. All units are to document their written certifications using an approved site template (See Section 6. Related Documents). Note: Annual recertification is not required. MBO records or safety meeting minutes are sufficient for periodic refresher
17 Procedure No.: WYN Page: 17 of 18 training documentation not due to conditions in Section VOLUNTARY USE OF PPE A. If personnel choose to use PPE for a task that does not require its use, the user must be fully trained on the proper use of the PPE provided to them and the limitations of the respective PPE RETRAINING A. Retraining is required whenever: Changes in workplace conditions or types of PPE to be used render previous training obsolete, or It is evident that the employee has not retained the understanding or skill required to use the PPE properly RECORDKEEPING 5. RESPONSIBILITIES GENERAL REQUIREMENTS Each unit will maintain procedures to address the requirements of the PPE program, including PPE Hazard Assessments and documentation for communicating PPE requirements for respective job tasks and use situations to employees Each unit will maintain written certifications for PPE training provided to employees initially upon assignment indicating that the training was received and understood by the employee Subsequent training may be documented in electronic formats such as the Learning Management System or other appropriate means SITE PROGRAM PPE PROGRAM COORDINATOR Responsible for interpreting this procedure, and Ensuring the Unit Coordinators are informed of its requirements.
18 Procedure No.: WYN Page: 18 of UNIT COORDINATORS Responsible for unit implementation and compliance with this procedure UNIT MANAGER Responsible for ensuring unit compliance with site and corporate requirements, and Assigning a Unit Coordinator(s) to oversee implementation. 6. RELATED DOCUMENTS 6.1. STATE OF MICHIGAN S PERSONAL PROTECTIVE EQUIPMENT REGULATIONS (PART 433 RULES) 6.2. BC PERSONAL PROTECTIVE EQUIPMENT 6.3. BC HEARING CONSERVATION PROGRAM 6.4. WYN RESPIRATORY PROTECTION STANDARD 6.5. WYN ELECTRICAL HOT WORK 6.6. WYN ELEVATED WORKING SURFACES 6.7. BASF FLASH FIRE FRC EVALUATION TOOL 6.8. HAZARD ASSESSMENT FOR PERSONAL PROTECTIVE EQUIPMENT CERTIFICATION 6.9. PPE COMMUNICATIONS GRID WRITTEN PPE TRAINING CERTIFICATION TEMPLATES
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