Q: When it comes to personal protective equipment compliance, what is one key to reducing OSHA violations and citations?
A: Many of the PLANET member questions about workplace safety that regularly filter down for my immediate attention involve personal protective equipment (PPE). It should not be a surprise since OSHA’s No. 1 most-often cited violation for the landscape and horticultural services industry group was, and continues to be, noncompliance with personal protective equipment.
Several questions related to PPE regulations include the following:
- Who is responsible for providing PPE for your employees?
- What PPE is required for your workers at various job sites?
- Who in your organization should ensure PPE compliance on the job site?
Let’s deal with each of these questions individually.
1. The responsible party for supplying PPE to employees is the employer. OSHA’s most recent rulemaking in 2007 clarified the provision by stating that the employer must purchase and provide PPE for employees who are exposed to recognized and identified workplace hazards that could result in fatal and disabling injuries and illnesses.
Work locations covered by the regulations would include the firm’s maintenance and storage areas, landscape construction sites, grounds maintenance areas and other work site hazards that have been clearly identified. If equipment used by your firm is known to generate high noise levels, management should measure the noise, document it, incorporate it into written policies and training programs and provide PPE.
2. The PPE required for a worker’s use at a firm’s work site should be identified prior to exposing workers to the hazards. Any number of machines, tools, chemicals and work site environment issues impact worker exposure. Many powered machines, such as mowers, leaf blowers and chainsaws are capable of generating excessive noise that could result in permanent hearing loss. Management should be aware of this potential hazard before workers are exposed. According to OSHA regulations, the provision of PPE such as earplugs or ear muffs for hearing protection is mandated when noise levels exceed the 85 decibel level based on an eight-hour workday.
A key consideration for selecting hearing protection involves the NRR (noise reduction rating) designation on the hearing protection packaging. For example, let’s say that management has determined that workers operating leaf blowers during spring and fall clean-ups are exposed to 95 decibels. To get below the desired 85 decibel OSHA threshold level, hearing protection with an NRR of 22 would bring the exposure down to 73 from the original 95 in this example. This assumes that the worker has properly inserted the earplugs or is wearing the assigned ear muffs correctly. The crew manager who supervises these workers plays an important role for enforcing the PPE policies on hearing protection for their firm.
More examples of crew members using PPE are mowing, leaf blowing and chainsaw work. Eye protection is needed for these tasks. Debris, both large and small, can be a real hazard to workers who are not wearing eye protection that meets the ANSI Z-87 standard for impact, peripheral and ultraviolet light protection. Once again the crew manager plays an important role in ensuring that crew members are wearing approved eyewear and not stylish sunglasses that may look good but don’t provide the necessary protection.
Workplace environmental issues that are just as important are; hazards related to steep and slippery slopes, retaining walls and other drop-offs that could result in mowing equipment overturns, and proximity to residential and commercial properties where the public is potentially exposed.
3. Ensuring that PPE policies are being followed is a management function. It begins with senior management who have purchased and distributed the PPE on a timely basis; always set a good example by visiting work sites wearing the required PPE. Also, crew managers need to properly wear the required PPE during all work site visits. Finally, workers need to buy into the PPE program and fully understand the benefits of protecting themselves from workplace hazards.
PPE also includes reflective vests that are designed to protect your valuable human resources when working near high-traffic areas. Vests come in numerous colors and designs, and managers should consult OSHA’s regulations found at osha.gov on this PPE.
Dr. Sam Steel–Safety Consultant, PLANET; Senior Research Associate, Penn State University
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