Personal Protective Equipment Plan

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    Introduction

    This Personal Protective Equipment Plan is designed to help the St Cloud School District comply with the Occupational Safety and Health Administration (OSHA) Personal Protective Equipment standard (29 CFR 1910.132-138) as published in the Federal Register on April 6,1994. The standard applies to all St Cloud School District employees where there is a "reasonable probability" that injury can be prevented by the use of personal protective equipment.

    While the use of personal protective equipment is important, it is only a supplementary form of protection necessary where all hazards have not been controlled through other means such as engineering controls.

    Actual use of the Personal Protective Equipment (PPE) Plan is limited to Resource Training & Solutions and the St Cloud School District which it represents. The plan is intended to be non-site-specific and may need to be modified to adapt to specific conditions at each site or school district. In addition, the St Cloud School District is responsible for the implementation, enforcement and updating of their Personal Protective Equipment Plan.

    The plan must be reviewed and updated annually or whenever new work tasks or procedures affect occupational exposures or present new hazards. A Personal Protective Equipment Checklist is provided for in Appendix A.

     

    Plan Review and Updated Report

    Personal Protective Equipment Management Plan Update Report

    Program review and changes are documented below. Documented reviews indicate that the plan continues to meet the needs of the District, or has been modified to do so more effectively.

     

     Date  Updates/Notes  Reviewer
     3/31/16 Foot and leg protection section. - updated standard requirements for protective footwear.

    Head protection section - updated ANSI requirements and protective hat type and class.

    Eye and face protection - updated ANSI Z87.1 requirements and shade table 1,2 & 3 

    Arm and hand section - updated table for rubber protective equipment 

     Wayne Warzecha
         
         
         
         
         

     

    Overview of Standard

    Information in this Plan reflects OSHA's latest revisions to PPE standards (1910.132 through 1910.138) as published in the Federal Register Vol. 59, No. 66, pp. 16334-16364, April 6, 1994. The final rule also contains non-mandatory guidelines for a hazard assessment and a chart identifying the appropriate personal protective equipment for particular hazards.

    Personal protective equipment should not be used as a substitute for engineering, work practice, and/or administrative controls. Personal protective equipment should be used in conjunction with these controls to provide the St Cloud School District employees with a safe and healthy workplace. Personal protective equipment includes all clothing and other work accessories designed to create a barrier against workplace hazards. The basic element of any management program for personal protective equipment should be an in depth evaluation of the equipment needed to protect against the hazards at the workplace. Management must be dedicated to the safety and health of the St Cloud School District employees on the protective limitations of personal protective equipment, and on its proper use and maintenance.

    Using personal protective equipment requires hazard awareness and training on the part of the user. The St Cloud School district employees must be aware that the equipment does not eliminate the hazard. If the equipment fails, exposure may occur. To reduce the possibility of failure, equipment must be properly selected, fitted and maintained in a clean and serviceable condition.

    Selection of the proper personal protective equipment for a job is important. The St Cloud School District and its employees must understand the equipment's purpose and its limitations. The equipment must not be altered or removed even though an employee may find it uncomfortable. (Sometimes equipment may be uncomfortable simply because it does not fit properly.)

    This Plan discusses those types of equipment most commonly used for protection of the head, including eyes and ears, and the torso, arms, hands, and feet.

     

    Hazard Assessment

    The St Cloud School District is required to assess the workplace to determine if hazards that require the use of head, eye, face, hand, or foot protection are present or are likely to be present. If hazards or the likelihood of hazards are found, the St Cloud School District must select and have affected school district employees use proper personal protective equipment suitable for protection from these hazards.

    Typical operations or work activities were where head, eye, face, hand, or foot protection that may exist include, but are not limit to, the following:

    • Maintenance Activities
      • welding
      • power tool operations
    • Groundskeeping Activities
      • power lawn maintenance and snowblower equipment operations
      • lawn chemical application
    • Equipment Maintenance and Repair
    • Industrial Arts Shops
    • Chemistry Laboratory

    The St Cloud School District must certify in writing that a workplace hazard assessment has been performed. Defective or damaged personal protective equipment shall not be used.

     

    Personal Protective Equipment

    Head Protection

    Prevention of head injuries is an important factor in every safety program. A survey by the Bureau of Labor Statistics (BLS) of accidents and injuries noted that most workers who suffered impact injuries to the head were not wearing head protection. The majority of workers were injured while performing their normal jobs at their regular worksites. Head injuries are caused by falling or flying objects, or by bumping the head against a fixed object.

    Head protection, in the form of protective hats, must be able to resist penetration and absorb the shock of a blow. This is accomplished by making the shell of the hat material hard enough to resist the blow, and by utilizing a shock-absorbing lining composed of headband and crown straps to keep the shell away from the wearer's skull. Protective hats also are used to protect against electrical shock.

    Selection. Each type and class of head protector is intended to provide protection against specific hazardous conditions. An understanding of these conditions will help in selecting the right hat for the particular situation.

    Protective hats are made in the following types and classes:

    • Type I - helmets offer protection from blows to the top of the head
    • Type II - helmets offer protection from blows to both the top and sides of the head 

    For industrial purposes, three classes are recognized:

    •  Class G (General) Helmets - Class G helmets are proof tested at 2,200 volts.
    •  Class E (Electrical) Helmets - Class E helmets are proof tested at 20,000 volts.
    •  Class C (Conductive) Helmets - This class provides no electrical insulation

    Hats and caps under Class G are intended for protection against impact hazards. They are used in mining, construction, shipbuilding, tunneling, lumbering, and manufacturing.

    Class E utility service hats and caps protect the wearer's head from impact and penetration by falling or flying objects and from high-voltage shock and burn. They are used extensively by electrical workers.

    The safety hat or cap in Class C is designed specifically for lightweight comfort and impact protection. This class is usually manufactured from aluminum and offers no dielectric protection. Class C helmets are used in certain construction and manufacturing occupations, oil fields, refineries, and chemical plants where there is no danger from electrical hazards or corrosion. They also are used on occasions where there is a possibility of bumping the head against a fixed object.

    Materials used in helmets should be water-resistant and slow burning. Each helmet consists essentially of a shell and suspension. Ventilation is provided by a space between the headband and the shell. Each helmet should be accompanied by instructions explaining the proper method of adjusting and replacing the suspension and headband.

    The wearer should be able to identify the type of helmet by looking inside the shell for the manufacturer, ANSI designation and class. For example:

    Manufacturer's Name
    ANSI Z89.1-2009 (or later year)
    Class A

    Fit. Headbands are adjustable in 1/8-size increments. When the headband is adjusted to the right size, it provides sufficient clearance between the shell and the headband. The removable or replaceable type sweatband should cover at least the forehead portion of the headband. The shell should be of one-piece seamless construction and designed to resist the impact of a blow from falling material. The internal cradle of the headband and sweatband forms the suspension. Any part that comes into contact with the wearer's head must not be irritating to normal skin.

    Inspection and Maintenance. Manufacturers should be consulted with regard to paint or cleaning materials for their helmets because some paints and thinners may damage the shell and reduce protection by physically weakening it or negating electrical resistance.

    A common method of cleaning shells is dipping them for at least a minute in hot water (approximately 140°F) that contains a good detergent. Shells should then be scrubbed and rinsed in clear hot water.

    After rinsing, the shell should be carefully inspected for any signs of damage.

    All components, shells, suspensions, headbands, sweatbands, and any accessories should be visually inspected daily for signs of dents, cracks,.penetration, or any other damage that might reduce the degree of safety originally provided.

    Users are cautioned that if unusual conditions occur (such as higher or lower extreme temperatures than described in the standards), or if there are signs of abuse or mutilation of the helmet or any component, the margin of safety may be reduced. If damage is suspected, helmets should be replaced and representative samples tested in accordance with procedures contained in ANSI Z89.1-2009, ANSI Z89.1-2003 or ANSI Z89.1-1997.

    Helmets should not be stored or carried on the rear-window shelf of an automobile, since sunlight and extreme heat may adversely affect the degree of protection.

    Eye and Face Protection

    Eye and face protective equipment is required by OSHA where there is a reasonable probability of preventing injury when such equipment is used. The school district must provide a type of protector suitable for work to be performed, and employees must use the protectors. These stipulations also apply to supervisors and management personnel, and should apply to visitors while they are in hazardous areas.

    Suitable eye protectors must be provided where there is a potential for injury to the eyes or face from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, potentially injurious light radiation or a combination of these. Protectors must meet the following minimum requirements.

    • provide adequate protection against the particular hazards for which they are designed;
    • be reasonably comfortable when worn under the designated conditions;
    • fit snugly without interfering with the movements or vision of the wearer;
    • be durable;
    • be capable of being disinfected;
    • be easily cleanable;
    • and be kept clean and in good repair.

    Each protector shall be distinctly marked to facilitate identification of the manufacturer.

    Each affected employee shall use equipment with filter lenses that have a shade number appropriate for the work being performed for protection from injurious light radiation (e.g., welding). The following is a listing of appropriate shade numbers for various operations.

    Table

    *As a rule of thumb, start with a shade that is too dark to see the weld zone (the darkest lens carries a value of 10). Then go to a lighter shade which gives sufficient view of the weld zone without going below the minimum. In oxy-fuel gas welding or cutting where the torch produces a high yellow light, it is desirable to use a filter lens that absorbs the yellow or sodium line in the visible light of the (spectrum) operation.

    **These values apply where the actual arc is clearly seen. Experience has shown that lighter filters may be used when the arc is hidden by the workpiece.

    Note: OSHA and the National Society to Prevent Blindness recommend that emergency eyewashes be placed in all hazardous locations. First-aid instructions should be posted close to potential danger spots since any delay to immediate aid or an early mistake in dealing with an eye injury can result in lasting damage.

    Selection. Each eye, face, or face-and-eye protector is designed for a particular hazard. In selecting the protector, consider the kind and degree of hazard, and select the protector accordingly. Where a choice of protectors is given, and the degree of protection required is not an important issue, worker comfort may be a deciding factor.

    Persons who use corrective spectacles and those who are required by OSHA to wear eye protection must wear face shields, goggles, or spectacles of one of the following types:

    • spectacles with protective lenses providing optical correction;
    • goggles of face shields worn over corrective spectacles without disturbing the adjustment of the spectacles; or
    • goggles that incorporate corrective lenses mounted behind the protective lenses.

    When limitations or precautions are indicated by the manufacturer, they should be communicated to the user and strictly observed.

    Over the years, many types and styles of eye and face-and-eye protective equipment have been developed to meet the demands for protection against a variety of hazards.

    Goggles come in a number of different styles: eyecups, flexible or cushioned goggles, plastic eyeshield goggles, and foundrymen's goggles.

    Goggles are manufactured in several styles for specific uses such as protecting against dusts and splashes, and in chipper's, welder's, and cutter's models.

    Safety spectacles require special frames. Combinations of normal street wear frames with safety lenses are not in compliance.

    Many hard hats and non-rigid helmets are designed with face and eye protective equipment.

    Design, construction, tests, and use of eye and face protection must comply with ANSI Z87.1-2003 or ANSI Z87.1-1989, American National Standard Practice for Occupational and Educational Eye and Face Protection.

    Fit. Fitting of goggles and safety spectacles should be done by someone skilled in the procedure. .Prescription safety spectacles should be fitted only by qualified optical personnel.

    Inspection and Maintenance. It is essential that the lenses of eye protectors be kept clean. Continuous vision through dirty lenses can cause eye strain which is often an excuse for not wearing the eye protectors. Daily inspection and cleaning of the eye protector with soap and hot water, or with a cleaning solution and tissue, is recommended.

    Inspection and Maintenance. It is essential that the lenses of eye protectors be kept clean. Continuous vision through dirty lenses can cause eye strain which is often an excuse for not wearing the eye protectors. Daily inspection and cleaning of the eye protector with soap and hot water, or with a cleaning solution and tissue, is recommended.

    Pitted lenses, like dirty lenses, can be a source of reduced vision. They should be replaced. Deeply scratched or excessively pitted lenses are apt to break more readily.

    Slack, worn-out, sweat-soaked, or twisted headbands do not hold the eye protector in proper position. Visual inspection can determine when the headband elasticity is reduced to a point below proper function.

    Goggles should be kept in a case when not in use. Spectacles, in particular, should be given the same care as one's glasses, since the frame, nose pads, and temples can be damaged by rough usage.

    Personal protective equipment that has been previously used should be disinfected before being issued to another employee. Also, when each employee is assigned protective equipment for extended periods, it is recommended that such equipment be cleaned and disinfected regularly.

    Several methods for disinfecting eye-protective equipment are acceptable. The most effective method is to disassemble the goggles or spectacles and thoroughly clean all parts with soap and warm water. Carefully rinse all traces of soap, and replace defective parts with new ones. Swab thoroughly or completely and immerse all parts for 10 minutes in a solution of germicidal deodorant fungicide. Remove parts from solution and suspend in a clean place for air drying at room temperature or with heated air. Do not rinse after removing parts from the solution because this will remove the germicidal residue which retains its effectiveness after drying.

    The dry parts or items should be placed in a clean, dust-proof container, such as a box, bag, or plastic envelope, to protect them until reissue.

    Ear Protection

    Exposure to high noise levels can cause hearing loss or impairment. It can create physical and psychological stress. There is no cure for noise-induced hearing loss, so the prevention of excessive noise exposure is the only way to avoid hearing damage. Specifically designed protection is required, depending on the type of noise encountered and the auditory condition of employee.

    Preformed or molded earplugs should be individually fitted by a professional. Waxed cotton, foam, or fiberglass-wool earplugs are self-forming. When properly inserted, they work as well as most molded earplugs.

    Some earplugs are disposable, to be used one time and then thrown away. The nondisposable type should be cleaned after each use for proper protection. Plain cotton is ineffective as protection against hazardous noise.

    Earmuffs need to make a perfect seal around the ear to be effective. Glasses, long sideburns, long hair, and facial movements, such as chewing, can reduce protection. Special equipment is available for use with glasses or beards.

    For more specific information on ear protection see the St Cloud School District's Hearing Conservation Plan.

    Respiratory Protection

    Respirators shall be provided by the St Cloud School District when such equipment is necessary to protect the health of the employee. The St Cloud School District shall provide the respirators which are applicable and suitable for the purposes intended.

    Respirators shall be used in the following circumstances:

    • where exposure levels exceed the applicable limits [e.g., OSHA permissible exposure limit (PEL)], during the time period necessary to install or implement feasible engineering and work practice controls;
    • in those maintenance and repair activities and during those brief or intermittent operations where exposures exceed the applicable limits (e.g., PEL) and engineering and work practice controls are not feasible or are not required;
    • in a regulated area, where the employer has implemented all feasible engineering and work practice controls and such controls are not sufficient to reduce exposures to or below the applicable limits (PEL); and
    • in emergencies.

    For more specific information on respiratory protection see the St Cloud School District's Respiratory Protection Plan.

    Torso Protection

    Many hazards can threaten the torso: heat, splashes from hot metals and liquids, impacts, cuts, acids, and radiation. A variety of protective clothing is available: vests, jackets, aprons, coveralls, and full body suits.

    Selection. Wool and specially treated cotton are two natural fibers that are fire-resistant and comfortable since they adapt well to changing workplace temperatures.

    Duck, a closely woven cotton fabric, is good for light-duty protective clothing. It can protect against cuts and bruises on jobs where employees handle heavy, sharp, or rough material.

    Heat-resistant material, such as leather, is often used in protective clothing to guard against dry heat and flame. Rubber and rubberized fabrics, neoprene, and plastics give protection against some acids and chemicals.

    It is important to refer to the manufacturers' selection guides for the effectiveness of specific materials against specific chemicals.

    Disposable suits of plastic-like or other similar synthetic material are particularly important for protection from dusty materials or materials that can splash. If the substance is extremely toxic, a completely enclosed chemical suit may be necessary. The clothing should be inspected to ensure proper fit and function for continued protection.

    Arm and Hand Protection

    Examples of injuries to arms and hands are burns, cuts, electrical shock, amputation, and absorption of chemicals. There is a wide assortment of gloves, hand pads, sleeves, and wristlets for protection against various hazardous situations.

    The St Cloud School District needs to determine what hand protection their employees need. The work activities of the school district employees should be studied to determine the degree of dexterity required, the duration, frequency, and degree of exposure to hazards and the physical stresses that will be applied.

    Also, it is important to know the performance characteristics of gloves relative to the specific hazard anticipated (e.g., exposure to chemicals, heat, or flames). Gloves' performance characteristics should be assessed by using standard test procedures.

    Before purchasing gloves, the St Cloud School District should request documentation from the manufacturer that the gloves meet the appropriate test standard(s) for the hazard(s) anticipated.

    The protective gloves should be selected to fit the job. The St Cloud School District may need to use gloves, such as wire mesh, leather, and canvas that have been tested and provide insulation from burns and cuts. The St Cloud School District should become acquainted with the limitations of the clothing used.

    Certain occupations require special protection. For example, electricians need special protection from shocks and burns. Rubber is considered the best material for insulating gloves and sleeves from these hazards. Rubber protective equipment for electrical workers must conform to the requirements established in ASTM as specified in the following table.

    ASTM Standards

    Selection. A number of factors need to be taken into account when choosing a glove for a particular application. In the initial selection process, the following are of primary importance.

    • The toxic properties of the chemical or chemicals. In particular, the ability of the chemical to cause local effects on the skin and/or to pass through the skin and cause systemic effects should be known.
    • The work activities being undertaken. These must be studied and account for the degree of dexterity required, the duration, frequency and degree of chemical exposure and the physical stresses which will be applied. 
    • The performance characteristics of the gloves. These should be assessed using standard test procedures. Characteristics to be considered include chemical, puncture, tear and abrasion resistance.

    Foot and Leg Protection

    Most of the workers who suffered foot injuries were not wearing protective footwear. The typical foot injury was caused by objects falling fewer than 4 feet and the median weight was about 65 pounds. Again, most workers were injured while performing their normal job activities at their worksites.

    For protection of feet and legs from falling or rolling objects, sharp objects, molten metal, hot surfaces, and wet slippery surfaces, the St Cloud School District employees should use appropriate footguards, safety shoes, or boots and leggings. Leggings protect the lower leg and feet from molten metal or welding sparks. Safety snaps permit their rapid removal.

    Aluminum alloy, fiberglass, or galvanized steel footguards can be worn over usual work shoes, although they may present the possibility of catching on something and causing workers to trip. Heat-resistant soled shoes protect against hot surfaces like those found in the roofing, paving, and hot metal industries.

    Safety shoes should be sturdy and have an impact-resistant toe. In some shoes, metal insoles protect against puncture wounds. Additional protection, such as metatarsal guards, may be found in some types of footwear. Safety shoes come in a variety of styles and materials, such as leather and rubber boots and oxfords.

    Safety footwear is classified according to its ability to meet minimum requirements for both compression and impact tests. These requirements and testing procedures may be found in ANSI or ASTM standards. Protective footwear must comply with one of the three:

    ASTM F-2412-2005, "Standard Test Methods for Foot Protection," and ASTM F-2413-2005, "Standard Specification for Performance Requirements for Protective Footwear.

    ANSI Z41-1999, "American National Standard for Personal Protection -- Protective Footwear,"

    ANSI Z41-1991, "American National Standard for Personal Protection -- Protective Footwear,"

     

    Fall Protection

     

    Other Related Issues

    A Coast Guard-approved life jacket or buoyant work vest should be used if there is danger of falling into water while working, such as during swimming pool maintenance. For emergency rescue operations, ring buoys with at least enough line to reach across the pool must be provided.

    The St Cloud School District employees working at night who might be struck by moving vehicles need suits or vests designed to reflect light.

     

    Program Surveillance

    To have an effective safety program, one manager must be responsible for its coordination. The St Cloud School District supervisors must be convinced of the hazard and must be held accountable for the employees' use of personal protective equipment. A safety program for new employees is a necessary part of any orientation program. An ongoing safety program should be used to motivate employees to continue to use protective gear.

    The use of correct personal protective equipment coupled with a good training program can give the worker a large measure of safety where other controls are inadequate or not feasible.

    Personal protective equipment can be effective only if the equipment is selected based on its intended use, employees are trained in its use, and the equipment is properly tested, maintained, and worn.

    In the final analysis, the best protection comes from an interested management and work force committed to sound work practices.

     

    Training

    Before doing work requiring use of personal protective equipment, the St Cloud School District employees must be trained to know when personal protective equipment is necessary; what type is necessary: how it is to be worn; and what its limitations are, as well as know its proper care, maintenance, useful life, and disposal. In many cases more than one type of personal protective equipment will provide adequate protection. In those instances St Cloud School District employees should be given a choice.

    The St Cloud School District is required to certify in writing that training has been carried out and that St Cloud School District employees understand it. Each written certification shall contain the name of each employee trained, the date(s) of training, and identify the subject of the certification.

    Refer to the Personal Protective Equipment Training Log in Appendix B.

     

    Appendix A: PPE Compliance Checklist

    The following checklist serves as a quick reference for an individual School District to evaluate their level of compliance with the OSHA PPE Standards (1910.132 through 1910.138).

    • Written PPE Program 
    • Personnel Responsibilities Assigned 
    • Labor-Management Safety Committee Established 
    • Hazard Identification and Analysis Conducted 
    • Controls or Corrective Measures are In Place 
    • Training of Employees 
    • Establish Measurement Criteria to Evaluate Program Effectiveness

    Note: This checklist is not intended to be comprehensive in nature. Each School District should refer to their individual Personal Protective Equipment Plan which further outlines compliance requirements.

     

    Appendix B: PPE Training Log

     

    Appendix C: OSHA PPE Standards

    1910 Subpart I - Personal Protective Equipment