Presented by NATA SafetyNet guest blogger, Eric Lugger, Director of Safety, Landmark Aviation
So what is it you have learned and forgotten about PPE and the OSHA 1910 Standards requirements? Here is a short memory jogger. Two solutions must be considered before PPE may be used as a solution to a hazard.
The first solution is to attempt to engineer “out” the injury hazard. This requirement is the responsibility of the designer of equipment and task accomplishment and mostly achieved by the employer when selecting equipment safest to perform the job. The other solution that must be attempted before PPE is used is effective guarding of equipment. We usually see this solution presented as the topic “Machine Guarding.” There are many examples of lack of, not installed and work around injuries related to engineering controls or machine guards. So, when all else has been exhausted the last solution is PPE.
What is the employers’ obligation to select, provide (by paying for the PPE) and enforce the use of PPE? Simply put, selection cannot be based solely on cost. Fitness for the task and meeting, say, an American National Standards Institute (ANSI) standard would be good start. If there is a job task where PPE should be used by the employee, generally, the employer must purchase suitable PPE and provide it to the employee.
One bit of advice on workers’ use of PPE, if you expect them to use what you provide, it is best to put the requirements in writing and have a signed acknowledgment accepting the policy. Even then, you should review the OSHA standards to determine when the employee must use the PPE.
Thanks for reading!