Environmental Health, Safety and Emergency Management

This section is provided as guidance for University managers, supervisors, and others responsible for determining the personal protective equipment (PPE) needed for a particular workplace operation, ensuring the use of PPE, and training PPE users in their areas in order to comply with NCOSHA requirements.

The scope of these requirements is limited to those occupational exposures or processes where head, eye, face, foot, hand, or skin hazards exist and the use of safety equipment such as gloves, hard hats, face shields, safety glasses, goggles, hearing protection, safety shoes, and voltage-protection hard hats are needed.

These requirements do not apply to respiratory protection, chemical protective clothing, fall protection equipment or to electrical protective devices such as rubber insulating gloves, shoes/boots, blankets, hoods, sleeves, and line hoses. These protective equipment items are covered in separate NCOSHA standards. However, these requirements do apply to voltage protection hard hats.

Personal protective equipment does not provide unlimited protection. Personal protective equipment should be used only when guards, engineering controls, administrative controls and safe work practices do not adequately eliminate the hazard.

Supervisors need to perform a walkaround survey to observe hazards that call for use of personal protective equipment (PPE). Hazard assessments can be conducted facility-wide, department-wide, by job task, or for each individual's exposure. The key to compliance is documenting the hazards, then reducing or eliminating the hazards; and where that's not completely feasible, provide and require the appropriate use of PPE.

Assessments document that:

• Identifies itself as a certification that the workplace has been evaluated.
• Specifies the department, area or workplace evaluated.
• Includes the signature of the person performing the evaluation.
• Includes the dates of the initial survey or date(s) of the reassessment of the PPE when changes occur.

Send a copy of the survey, along with documentation that the employee received and understood training on any selected PPE, to EHS&EM.

Surveys should include observations on the likelihood of injury or illness to occur from:

• Sources of motion, which includes machinery or processes where an injury could result from movement of tools, machine elements or particles, or movement of personnel that could result in collisions, blows, or tripping around stationary objects.
• Sources of high or freezing temperatures that could result in burns, eye injury, or ignition of personal protective equipment.
• Chemical exposures such as splashes, vapors, sprays or immersion that could cause illness or injury.
• Sources of dust that could cause a physical hazard to worker's eyes, or be inhaled or ingested by an employee.
• Sources of light (optical) radiation such as welding, brazing, cutting, or high intensity light sources, including sunlight.
• Sources of falling objects or possibility of dropping objects that could pose a compression or projectile hazard to a worker's head, face, hands, or feet.
• Sources of sharp objects, which might pierce the feet or cut the hands or body.
• Sources of rolling or pinching objects, which could crush the feet.
• Electrical hazards.
• Sources of excessive noise or vibration.
• Layout of workplace and location of co-workers.

For each of the above hazard sources, supervisors need to consider the possible occurrence of injury or illness to his/her employee(s) from each of the hazards surveyed in the workplace. Specific injury or illness factors to consider include:

• Types of possible injuries or illnesses (e.g. employee exposures to chemicals can result in skin rashes, other skin disorders).
• Risk levels (e.g. probable, possible, or unlikely to occur). (NOTE: Skin disorders are the number two cause of occupational illness, following ergonomics.)
• Seriousness (e.g. death; permanent impairment; serious injury or illness resulting from chronic and/or acute exposures; temporary injury or illness; or minor/treated injury or illness).

Reassessments need to be made when processes or equipment changes occur in the department/area or specific workplace. Contact the Environmental Health, Safety and Emergency Management Office (EHS&EM) to schedule a workplace Hazard Assessment in your area.

In the event hazards cannot be eliminated or abated and PPE is needed to prevent further employee injury or illness, it is the supervisor's responsibility to:

• Select appropriate PPE and require employees to use selected PPE.
• Inform employees about the selection decisions.
• Select PPE that fits (and will be used) by employees.
• Select certified PPE that complies with the appropriate ANSI standard. (NOTE: There is no ANSI standard for hand protection. Contact the EHS&EM Office if you have questions.)
• Ensure that PPE, including PPE owned by the employee, is maintained in a sanitary and reliable condition. Prohibit the use of defective, unsanitary or damaged PPE.
• Train employees in the following areas: when PPE is necessary for use; what PPE is necessary; how to properly wear PPE; and the proper care, maintenance, useful life and disposal of PPE. (NOTE: Be sure to include in-house replacement procedures for obtaining PPE.) Employees need to demonstrate an understanding of the training received and the ability to use PPE properly before being allowed to perform work requiring the use of PPE.
• Retrain employees when changes in the workplace or changes in the type of PPE used render previous training obsolete or when there is evidence that an employee does not understand the use and care of PPE.
• Certify in writing that the employee has received and understands the training. Keep a copy of the training record in the department and forward a copy to the EHS&EM Office.

Contact EHS&EM if you have questions concerning these requirements.