Is Your PPE Program Making Your Workplace Less Safe?
Be prepared. That’s the Boy Scouts’ motto. It’s better to pack too much than to be without something you need – probably advice you’ve heard more than once in your life. And it’s sound advice, right? You wouldn’t want to be stranded on the side of the road without a spare tire in your car or have your power go out and not have any candles.
But is there such a thing as being too prepared? Sure, in some cases. Hoarding thousands of dollars worth of canned food in case of the Apocalypse might be overkill, as would carrying an entire First Aid kit around in your purse. But when it comes to safety, there’s no such thing as being too prepared, right? Wrong. When it comes to Personal Protective Equipment (PPE), having too much – especially to protect against hazards that you’re unlikely to encounter – could actually make you less safe.
The Hierarchy of Controls
The Occupational Safety and Health Administration (OSHA) developed a Hierarchy of Controls (also referred to as the Hierarchy of Hazard Controls and Hierarchy of Safety Controls), which sets out the steps employers should take to protect employees from workplace hazards. The Hierarchy starts with the most effective measure – eliminate the hazard completely – and ends with the least effective – PPE.
Surprised to see PPE at the bottom? It makes sense if you think about it – PPE is your last line of defense. The other controls are all designed to find some way around the hazard or to eliminate it completely – only when there is no way to avoid or eliminate the hazard do you start to look for ways to protect against it.
Elimination & Substitution
Elimination and substitution involve removing the hazard completely so it is no longer a threat. An example of eliminating a hazard would be moving a task that required working in an area high off the floor to ground level, eliminating the fall hazard. An example of a substitution would be replacing a hazardous chemical with a non-toxic one.
While these hazard controls are the most effective (as they remove the hazard completely), they are typically the most difficult to implement. In some cases, especially for an existing process, the elimination or substitution of a hazard can be quite expensive, especially if it involves purchasing new machinery.
Isolation & Engineering Controls
Isolation and engineering controls are designed to obviate hazards at the source, providing protection before the hazard reaches the worker. Both isolation and engineering controls involve isolating the hazard from workers – isolation is the preferred method if the hazard can be isolated and if not, an engineering control, such as a guard on a table saw, can be developed to protect workers.
Instituting an engineering control may seem far more expensive than PPE in the short-term, but it is a long-term solution and generally produces cost-savings vs. PPE over the life of the control.
Administrative Controls & PPE
Administrative controls and PPE should be considered when none of the other controls will work for the hazard you are trying to protect against. Generally, these controls are the most cost-effective, but are also the least effective at providing protection. Administrative controls include items such as signage that advises about hazards and job rotation, which is helpful in protecting against hazards caused by repetitive tasks. PPE is the protection of choice if there is no way to eliminate or isolate the hazard.
Choosing the Right Amount of PPE
When it comes to safety, you want to consider every possible hazard that you or your employees could encounter and ensure that the proper precautions are taken to protect against those hazards. However, you don’t want to sacrifice comfort or your employees’ ability to their job to protect against a threat that is unlikely to occur. The words “standard issue” are often synonymous with misuse of PPE. There is no ‘one-size-fits-all’ when it comes to PPE and preparing for the worst case scenario can not only lead you to choose the wrong PPE, but also may discourage your employees from wearing it if it interferes with their ability to perform their job.
An oil and gas company assigned all of their employees ‘standard issue’ safety gloves. The company thought it was easier to select one glove that protected against worst-case scenarios than to individually choose gloves for each position. The standard issue gloves were great for those working right amongst the drilling machinery – they were robust (read: bulky), providing excellent impact protection, which is key for employees on the front lines. However, for other employees, especially those not working directly with drilling machines, but who needed to perform dexterous tasks, the gloves proved to be too bulky. The result was that most employees were actually taking their gloves OFF to perform their job, leaving workers with no protection. Also, the gloves needed to protect against worst-case hazards were high-end and much more expensive than other gloves better suited to workers not directly involved in drilling. By trying to save money with a one-size-fits-all PPE strategy, not only did the company endanger their employees but also ended up spending much more money than they would have by evaluating each position and selecting appropriate PPE.
Evaluating Hazards Using the Hierarchy of Controls
If you aren’t sure whether your employees are too protected, take the time to evaluate what hazards you’re protecting against and whether there are better options. Include your employees in the process and evaluate which hazards can be eliminated, substituted, or isolated. For those that remain, do some research into whether or not engineering controls exists; if not, look into creating your own. For those hazards requiring PPE, make sure you have the right PPE and that only those employees who need protection are wearing it.
Evaluating hazards and using the Hierarchy of Controls to eliminate or protect against those hazards takes time and effort to do correctly. But the end result is not only a safer workplace, but also long-term cost savings for you.