Voice of Experience: PPE Regulatory and Consensus Standard Requirements
OSHA 29 CFR 1910 Subpart I and 1926 Subpart E cover the requirements of personal protective and lifesaving equipment. With the publication of OSHA’s final rule in April 2014, the general industry and construction standards are now essentially the same for electric utilities, and there are few if any differences in the PPE required by each standard.
In addition to OSHA’s regulatory standards, there are ANSI/ASTM and other consensus standards that govern the manufacturing, type and ratings for all PPE. These consensus standards change as the industry evolves and PPE improves. All PPE should meet the most recent standard requirements. In the remainder of this article, we will examine OSHA’s PPE requirements for electric utility workers, as well as some of the latest consensus standard requirements.
Assessment, Selection and Training
Let’s first look at what is required by OSHA 1910.132(d), “Hazard assessment and equipment selection.” Paragraph (d)(1) mandates that employers perform work site assessments to determine if hazards or potential hazards exist that necessitate the use of PPE. If any hazards are present, the employer must select PPE that fits each affected employee, communicate those selection decisions and ensure employees properly use the PPE.
Paragraph 1910.132(d)(2) then goes on to state that the “employer shall verify that the required workplace hazard assessment has been performed through a written certification that identifies the workplace evaluated; the person certifying that the evaluation has been performed; the date(s) of the hazard assessment; and, which identifies the document as a certification of hazard assessment.”
With regard to training, paragraph 1910.132(f) compels the employer to provide it to each employee who is required by this section to use PPE. Each employee must be trained to know, at the very least, when and what PPE is necessary; how to properly don, doff, adjust and wear it; the equipment’s limitations; and how to properly care for, maintain and dispose of PPE. And before employees are allowed to perform work that requires the use of PPE, they have to be able to demonstrate an understanding of the training they received. Also note that while employees may choose to provide their own PPE, the employer can approve or reject the equipment.
PPE Payment Rules
In paragraph 1910.132(h), OSHA provides information about what types of PPE employers do and do not have to pay for. Protective equipment, including PPE, used to comply with the 1910.132 standard must be provided by the employer at no cost to employees. This covers replacement PPE unless an employee has lost or intentionally damaged the equipment. However, keep in mind that when an employee provides adequate protective equipment that he or she owns, the employer is not required to reimburse the employee for the PPE. This includes instances when the employer provides metatarsal guards and allows the employee, at his or her request, to use shoes or boots with built-in metatarsal protection.
OSHA also states that employers are not required to pay for the following:
• Logging boots.
• Everyday clothing, such as long-sleeve shirts, long pants, street shoes and normal work boots.
• Ordinary clothing, skin creams or other items used solely for protection from weather, such as winter coats, jackets, gloves, parkas, rubber boots, hats, raincoats, ordinary sunglasses and sunscreen.
• Non-specialty safety-toe protective footwear – including steel-toe shoes or steel-toe boots – and non-specialty prescription safety eyewear, provided that the employer permits such items to be worn off the job site.
Head and Hearing Protection
After the OSH Act of 1970 was passed and the administration started writing the standards, one of the first requirements was head protection under 29 CFR 1926.100. More recently, the Type II Class E ANSI/ISEA Z89.1-2014 hard hat updated the ANSI Z89.1-1997 hard hat. The 1997 standard changed the class from B to E. Then the 2014 final rule came along and changed hard hat requirements once again with regard to color, useful life and environmental guidelines used today in the electric utility industry. The Type II hat is made for vertical and side impacts and to meet the 20,000-volt proof test.
Hearing protection is covered under OSHA standard 1910.95, “Occupational noise exposure.” The employer is required to administer a continuing, effective hearing conservation program, as described in the standard, whenever employee noise exposures equal or exceed an eight-hour, time-weighted average sound level of 85 decibels.
In addition to hearing protection, the employer must ensure – per standard 1910.133 – that “each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.” The standard goes on to state that the employer must ensure that employees use “eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (e.g., clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.”
When employees are performing work that involves eye hazards, employers must also make sure that any of those employees who wear prescription lenses use eye protection that incorporates the prescription in its design. Alternatively, those employees must don protection that can be worn over the prescription lenses. All PPE that protects the eyes and face must be distinctly marked so the manufacturer can be easily identified.
A final note about eye and face protection: It is required in the utility industry whenever there is the possibility of an electrical arc and heat energy. PPE marked ANSI Z87.1 or ANSI Z87+ meets the latest ANSI standard update. The specific requirements for safety glasses, as well as when face shields must be used, can be found in 1910.269.
Respiratory protection – which is addressed in standard 1910.134 – covers everything from dust masks to self-contained breathing apparatuses. Through this standard, OSHA requires employers to establish and implement a written respiratory protection program. This must be done to ensure that any employee who voluntarily uses a respirator is medically able to do so, and all respirators must be cleaned, stored and maintained so they don’t present any health hazards to users. There is one exception to the rules: A written respiratory protection program is not required for those employees whose only respirator use is voluntary utilization of filtering face pieces.
An administrator must be designated by the employer to oversee the respiratory protection program and conduct the required program effectiveness evaluations. Administrators are qualified by appropriate training or experience that is commensurate with the program’s complexity.
Additionally, the employer must provide respirators, training and medical evaluations at no cost to employees. A respirator is to be selected and provided based on the respiratory hazards that a worker is exposed to, as well as workplace and user factors that affect respirator performance and ability. Respirators should be certified by NIOSH and used in compliance with the conditions of its certification.
As to general requirements for respirators, the employer is obligated to identify and evaluate workplace respiratory hazards, including a reasonable estimate of employee exposure to hazards and identification of each contaminant’s chemical state and physical form. If the employer can’t identify or reasonably estimate employee exposure, the atmosphere must be considered immediately dangerous to life or health. Finally, employers are required by OSHA to select a respirator from a sufficient number of models and sizes so it fits correctly and is otherwise acceptable to the user.
Arc-Rated Apparel and Hand Protection
As readers are aware, arc-rated, flame-resistant PPE is now required by 1910.269. Arc-rated apparel must be ASTM F1506 rated and self-extinguishing. More specific information and requirements related to exposures can be found in 1910.269, NFPA 70E and the National Electrical Safety Code.
Finally, I want to briefly discuss hand protection, which is covered in standard 1910.138. Employers should properly select heavy-duty leather gloves to prevent employee hand injuries, including cuts, abrasions and lacerations. Site-specific hazards should be addressed in the written PPE certification and covered in the on-site job briefing. Also, be sure to read and understand 1910.269(l) and NFPA 70E; they include text that requires employees to wear properly rated gloves of the appropriate class when minimum approach distances are involved with the work being performed.
About the Author: Danny Raines, CUSP, safety consultant, distribution and transmission, retired from Georgia Power after 40 years of service and opened Raines Utility Safety Solutions LLC, providing compliance training, risk assessments and safety observation programs. He is also an affiliate instructor at Georgia Tech Research Center OSHA Outreach in Atlanta. For more information, visit www.electricutilitysafety.com.