Personal Protective Equipment (PPE) and Hazard Assessment: A Case Study

Why PPE is the Least Effective Control Method

Case Study

The lowest level of control method in the Occupational Safety and Health Administration’s (OSHA’s) Hierarchy of Controls is personal protective equipment (PPE). OSHA lists PPE as the least effective control method and requires employers to reduce the risks associated with workplace hazards to an acceptable level before they use PPE as the primary control method. 

The reason OSHA rates PPE as the least effective control method is very simple. PPE does nothing to reduce the level of the hazard in the workplace because it is not addressing the source of the problem; that only comes through elimination or substitution. Engineering controls reduce the level of the hazard in the workplace by diluting or removing airborne levels of chemicals, blocking noise at the source, or blocking radiation along the pathway of exposure. Some administrative controls also reduce the concentration of a hazard in the air (wet methods), while others reduce the amount of time an employee is exposed to the hazard. PPE does not remove the hazard from the work area, does not reduce the concentration of a hazard in the air, and does not reduce the amount of time an employee is exposed to a hazard. PPE is designed to reduce exposures to hazard by reducing the exposure at the exposure site (e.g., skin, lungs, or eyes). One major problem with the use of PPE as a control method is that not all employees use it consistently. Manufacturers design PPE to be used in a specific manner, and the effectiveness of it is tested, typically in a laboratory setting under ideal conditions. Unfortunately, the PPE design is rarely used by employees under conditions that mimic the laboratory testing. This results in actual protection factors that are lower in the workplace than in the laboratory.

A good example of the lower effectiveness of PPE in the workplace is hearing protective devices such as earplugs. Earplugs are tested in a laboratory setting to determine a Noise Reduction Rating (NRR). Ideally, an NRR of 30 would mean that the earplugs would reduce the level of noise by 30 dBA. Because there are differences between the laboratory testing and real-world use, a value of 7 must be subtracted from the published NRR to account for differences. Therefore, the NRR of 30 would be reduced to 23. This would mean you would expect to reduce noise levels by 23 dBA at the employee’s ear. However, OSHA tells their compliance officers working in the field to cut the level in half (50%) when evaluating earplug ratings. This reduction is recommended because of the differences in inserting and wearing earplugs by individuals. Using this method, the NRR of 30 would be reduced to 11.5. The same problems exist for other PPE such as respirators and safety glasses.

Choosing a Workplace Operation for a Hazard Assessment

Some PPE is more related to industrial hygiene hazards while others are more related to safety hazards. For example, respirators reduce exposures to chemical hazards, chemical protective gloves reduce dermal exposures, safety glasses reduce physical hazards from striking the eyes, and hard hats reduce the risk of hazards striking the head. In practice, PPE must be an integrated program providing protection from hazards associated with both industrial hygiene and safety. This will require cooperation between industrial hygienist and safety professionals at a facility. In some cases, one individual works as both the industrial hygienist and safety officer, making the process easier. In this unit, we will focus on PPE associated with industrial hygiene hazards. These include respirators, hearing protection, and chemically protective clothing.

1.OSHA allows respirator fit testing to be performed using either qualitative fit testing (QLFT) methods or quantitative fit testing (QNFT) methods that are specified in Appendix A of 29 CFR 1910.134. Discuss the fit testing methods with which you are familiar and which methods you prefer to use. If you have never been fit tested or performed fit testing, read Appendix A and discuss which of the methods you believe would be the easiest to perform. Give the reasons for your choice.

2.How can you apply what you learned in this course to your career or life success?

Requirement

Choose an operation for a workplace where you once worked or with which you are familiar where either chemical hazards or noise exposures were present. If you have never worked in a location where chemical hazards or noise are present, read about some examples on OSHA’s website and choose one that interests you. Complete the following tasks in a minimum two-page (500 word) essay:  

1.Summarize the steps you would take to perform a hazard assessment of your chosen operation. Make sure you list the chemical hazards or noise hazards that are present using the example hazard assessment from OSHA’s website or one with which you are already familiar. 

2.Discuss the use of personal protective equipment (PPE) for controlling occupational hazards in relation to the operation you chose.

3.Choose one hazard that you identified. The hazard can be a chemical or noise hazard. Summarize how you would evaluate employee exposures to the hazard. Include information about any sampling method you would use, how many samples you would collect, the types of samples you would collect (e.g., personal or area, TWA or short-term), and to which standards you would apply the results.

4.Assume there are several results indicating that employees are exposed to levels exceeding the applicable OSHA PEL. Using OSHA’s Hierarchy of Controls, summarize the control methods you would employ to reduce the risk for employees to an acceptable level. Your summary should include examples from each level of OSHA’s Hierarchy of Controls with a discussion of why you think the control would or would not be an effective method for reducing the exposure to an acceptable level.

5.Discuss how you would evaluate the effectiveness of the control methods you chose, both in the short-term and for the next 5 years.