The Selection of PPE
Selection ：Match PPE to the hazards
Before you select your PPE, first decide if PPE is the proper and only solution. As OSHA points out in the compliance guidance to this regulation, you shouldn’t rely on PPE devices alone to provide protection against hazards, but PPE should be used in conjunction with guards, engineering controls and sound manufacturing practices.
Ask the following questions:
• Can the hazard be removed by substitution or elimination of an ingredient or task?
• Can the hazard be mitigated by guards or redesign of the equipment?
• Can work practices, procedures or administrative controls be put in place to abate the problem?
This approach of mitigating the need for PPE is becoming more the rule than a suggestion with OSHA. In the recently passed Chromium VI regulations, OSHA requires use of engineering controls and work practices, where feasible, to abate the hazards, instead of immediately relying on PPE to protect against hazards.
Even with the implementation of engineering controls, work practices and administrative controls, the need for PPE is still likely. Respirators are highly prescribed. There is clear guidance and requirements for eyewear, gloves and footwear. However, the process of selecting PPE clothing requires considerable skill because it is the least specified set of regulations under the OSHA PPE standards.
Rules and guidance for selecting protective clothing are more general due to the broad range of potential hazards that protective clothing addresses, including heat, flame, arc, and exposures to toxic solids, vapors, liquids, aerosols and bloodborne pathogens. Even when PPE is discussed in regulations dealing with hazards such as asbestos, lead, hazardous waste and emergency operations, fire brigades, electrical workers and bloodborne pathogens, the specific requirements and selection guidance are vague.
With chemical and biological protective clothing, the fundamental decisions are fabric, seams and design. These are governed by questions such as:
• What is the probability of actual contact?
• What is the likely amount of contact?
• What is the expected duration of contact?
• From what direction is the contact likely?
When focused on the primary chemical or biological hazards, the selection process must also consider other hazards such as flammable or explosive atmospheres, hot or cold temperatures, physical hazards, punctures, abrasions, pinch or grab/snag hazards, slipping, falling and visibility â€” in terms of both seeing and being seen.
OSHA requires that PPE be provided, used and maintained in a sanitary and reliable manner. This leads to a decision between disposable, limited-use or reusable options. In the case of chemical and biological protective clothing, “sanitary and reliable” can be interpreted as knowing that the item has been decontaminated sufficiently to remove the hazard and not damaged by the prior exposure or decontamination process.